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PRIVACY POLICY

PRIVACY NOTICE

(pursuant to Articles 13 et seq. of Regulation (EU) 2016/679 (“GDPR”) and Legislative Decree No. 196/2003, as amended by Legislative Decree No. 101/2018)

 

This notice, issued pursuant to Article 13 of Regulation (EU) 2016/679 (“GDPR”), describes how Ager Sabini S.r.l., in its capacity as Data Controller, protects the personal data of users. For the purposes hereof, “User” means any natural person browsing our website (www.agersabini.com), hereinafter also referred to as the “Data Subject”.

 

1. Data Controller and Contact Details

The Data Controller is Ager Sabini S.r.l., with registered office at Via Umberto I, 46 – 02040 Roccantica (RI), represented by its legal representative pro tempore (the “Controller” or the “Company”).
The Controller can be contacted at: info@agersabini.com and/or +39 353 482 68 17.

 

2. Categories of Personal Data Processed

“Personal data” means any information that directly or indirectly identifies, or makes identifiable, a natural person. Without limitation, the personal data processed by Ager Sabini S.r.l. include:

 

Data knowingly provided by the User:
a) Identification and contact data: first and last name, municipality and province of residence, postcode, shipping address; telephone number, e-mail address.
b) Payment data: information on the chosen payment method, purchase amount and date, list of purchases.
c) Reviews, comments and other content: any content voluntarily shared by the User through interactive tools available on the Site (such as comments, reviews or contact forms). Such content is voluntarily provided by the User, who assumes responsibility for disclosing information—including relating to third parties—as well as for publishing any special categories of personal data concerning themselves (e.g., data relating to food intolerances).

 

Data collected automatically:
While browsing the Site, the IT system acquires certain technical data, including, by way of example, the IP address of the device connected to the network and used; date and time of access to the Site; country of origin of the connection; type of browser used to connect to the Site; domain names of the systems used by users to access the Site. Automatic acquisition also applies to non-registered Users who browse the Site.

 

Cookie-related data:
The Site uses first-party and third-party cookies to collect information on the User’s browsing. Such data may include, for example, display preferences, pages visited, time spent and interactions with content. Processing takes place in accordance with the “Cookie Policy” page on the Site.

 

Data received from third parties:
The Controller may receive personal data from third parties, i.e., natural or legal persons other than the Controller itself, such as couriers (e.g., GLS), payment service providers, IT service providers or consultants. Such data are transmitted where necessary for the provision of services, in particular for managing and fulfilling orders, delivering products or processing payments. Third parties process data as independent controllers in accordance with applicable law.

 

3. Purposes and Legal Bases of Processing

The personal data listed above (see Section 2) will be used by Ager Sabini S.r.l. for the following purposes:

a) Compliance with legal and regulatory obligations, including the issuance of tax documents, bookkeeping and mandatory communications with competent Authorities.
Legal basis: compliance with a legal obligation (Article 6(1)(c) GDPR).

b) Prevention and security, including IT security (prevention of fraud and unlawful activities).
Legal basis: legitimate interests of the Controller (Article 6(1)(f) GDPR).

c) Provision of our services and management of related pre-contractual activities (order management and fulfilment; payment processing).
Legal basis: performance of a contract or pre-contractual measures (Article 6(1)(b) GDPR).

d) Communications, assistance and support: providing the User with communications and updates on order status and purchased products, as well as assistance in response to any requests/enquiries/reports/complaints submitted through the Company’s channels.
Legal basis: performance of a contract or pre-contractual measures (Article 6(1)(b) GDPR).

e) Creation of a personal account on our Site: where the User chooses to register on our Site, their identification (first and last name, residential address) and contact details (e-mail, telephone number) will be processed to enable the creation and subsequent management of the personal account.
Legal basis: the User’s consent (Article 6(1)(a) GDPR).

f) Promotional and/or marketing purposes: subject to the User’s prior consent, Ager Sabini S.r.l. may process the User’s data (contact details such as e-mail) to send commercial and promotional communications, e.g., newsletters relating to products, services or initiatives undertaken by the Controller.
Legal basis: the User’s express consent (Article 6(1)(a) GDPR). The User may withdraw consent for this purpose at any time by contacting the Controller at the details provided above (see Section 1). Withdrawal will not affect the provision of services requested from Ager Sabini S.r.l.

g) Improvement of service and product quality: in order to continuously optimise the services and products offered, the Controller may collect feedback and conduct satisfaction surveys addressed to Users. Participation is always voluntary. Legal basis: the Controller’s legitimate interests in improving the user experience and services (Article 6(1)(f) GDPR).

h) Protection of the Controller’s rights, in judicial and out-of-court proceedings.
Legal basis: the Controller’s legitimate interests in establishing, exercising or defending legal claims (Article 6(1)(f) GDPR). Providing data for the purposes under letters c) and d) is necessary/mandatory to proceed with the sale and delivery of products purchased on our Site. In such cases, the User’s refusal to provide the requested data will prevent Ager Sabini S.r.l. from offering its services. Conversely, providing data for the purposes under letters e) and f) is optional. Therefore, lack of consent by the User—or subsequent withdrawal—will not in any way affect the provision of Ager Sabini S.r.l.’s services, but will prevent the User from receiving promotional and marketing communications, including personalised ones.

 

4. Methods and Place of Processing

The Company processes personal data using electronic means. Data are stored on servers located at our operating premises in Italy. The Controller ensures the use of appropriate security measures to preserve confidentiality, integrity and availability. Without limitation, the Company uses encryption protocols.
The Controller does not transfer personal data to countries where the GDPR does not apply (non-EU countries). Should such transfer become necessary, the User will be informed in advance and, where required, their consent will be obtained.

 

5. Disclosure of User Data

User data may be disclosed to:

  • suppliers and commercial partners;

  • couriers and freight forwarders;

  • technical and IT providers;

  • payment platforms used (PayPal, Google Pay);

  • consultants (legal, administrative, accounting, etc.);

  • Authorities.

 

6. Data Retention

Personal data are processed and retained for the period required by the specific purpose for which they were collected, and more precisely:
Contractual data: retained for the entire duration of the contractual relationship with the User. Payment data will be retained for ten (10) years, in accordance with statutory accounting and tax obligations.
Data collected for marketing/promotional purposes: retained until the User withdraws consent. In any event, if no interaction between the Site and the User is detected for a period exceeding two (2) years, the data will be deleted or irreversibly anonymised.
Data relating to the personal account: retained as long as the User keeps their account active or requests its deletion or objects to processing. Notwithstanding the foregoing, the Controller may be required to retain personal data for a longer period in order to comply with a legal obligation or pursuant to an order of an Authority.

 

7. Data Subject Rights under the GDPR and Contacts

With regard to the processing of their personal data, the Data Subject has the right to:
• Withdraw consent at any time;
• Access their data (Article 15 GDPR): obtain information on the data we process and certain aspects of the processing, and receive a copy of the data;
• Verify and request rectification of their data (Article 16 GDPR): verify correctness and request updates and/or corrections;
• Obtain erasure of personal data (“right to be forgotten”) pursuant to Article 17 GDPR;
• Obtain restriction of processing (see Article 18 GDPR): where processing is restricted, personal data shall be processed only with the Data Subject’s consent or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the Union or of a Member State;
• Receive their data and have them transmitted to another controller (“right to data portability”), Article 20 GDPR;
• Object to processing (Article 21 GDPR), where the processing is based on a legal basis other than consent.

Please note: where personal data are processed for direct marketing purposes, the Data Subject has the right to object at any time to the processing of personal data concerning them for such purposes, including profiling to the extent that it is related to such direct marketing.
• Lodge a complaint with a Supervisory Authority (Article 77 GDPR): the Data Subject may lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work, or place of the alleged infringement, or bring proceedings before the courts. In Italy, the supervisory authority is the Garante per la protezione dei dati personali (https://www.garanteprivacy.it/home/footer/contatti).

To exercise your rights, you may submit a specific request by contacting the Controller (see contact details in Section 1).

 

8. Protection of Minors

The services of Ager Sabini S.r.l. are not intended for persons under 18 years of age.

 

9. Updates

This notice has been in force since 11/08/2025.
The Controller reserves the right to amend it at any time. Users are invited to consult this page periodically and to refer to the “last updated” date indicated at the bottom, from which any amendments will take effect.

 

Last updated: 08/09/2025

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