PRIVACY POLICY according to art. 13 and 14 of EU Reg. 2016/679, “Regulation” or “GDPR”
This document was drafted according to art. 13 and 14 of EU Regulation 2016/679 (henceforth: “GDPR”) in order to make you aware of our privacy policy and of the way your personal information is processed when using when using websites associated with Cantine Settesoli S.C.A. (https://www.cantinesettesoli.it/ – https://www.mandrarossa.it/ – https://www.settesoli.it/it – https://inyconwines.com/) or its social media channels. We therefore invite you, before giving the data proprietor any personal data, to read this Privacy Policy carefully, as it includes some important information about the protection of your personal data.
The company Cantine Settesoli sca (henceforth “Settesoli”) based in Menfi in Strada Statale 115 snc, is the Proprietor of the personal data collected by this website (“Website”) and shall process it as required by the current regulations and in accordance with our Privacy Policy, as regards the navigation on our website. Please read our Privacy Policy for further information.
By means of this document, according to art. 13 and 14 of the GDPR, Article 122 of Legislative Decree 196/2003, as amended by Legislative Decree 101/2018, and the ‘Guidelines on cookies and other tracking tools’ issued by the Italian Data Protection Authority on 10 June 2021, Cantine Settesoli S.C.A., as Proprietor of Data, provides the user with some information about the cookies used. For further details please refer to the Cookie Policy published on the relevant websites.
1) Categories of personal data
Among the data collected by browsing this website, by us or by third parties, there are: e-mail, name, surname, message content. When browsing this website, data or information may be automatically collected during use, and this is necessary to access the website resources and improve the browsing experience itself.
1.1. Personal data automatically collected
- Browsing data. The information systems and the software procedures responsible for the functionality of this website collect, throughout the course of usual activity, some personal data the transfer of which is implicit to the use of communication protocols on the Internet. This information is not gathered to be associated to identified data subjects, but – due to its nature – could allow users to be identified through elaborations and associations with data stored on our behalf also by Data Processor companies. This data is only used to obtain anonymous statistical information on the use of the website and to control if it is working correctly, to find potential problems and/or abuses, or to assess responsibilities in case of potential cyber-crimes against the website or third parties referred to in point 2.d. “Data Usage” as defined below is part of this category. The updated list of Data Processors can always be requested from the proprietor.
- Information on an aggregate basis related to users’ behaviour on the website collected by the use of Cookies. Any use of Cookies – or of other tracking tools – by this website or by the owners of third-party services used by this website, if not otherwise specifies, serves the purpose of providing the service required by the user, in addition to any other purposes described in the present document and in the Cookie Policy. For further information about the Proprietor’s use of cookies, please read our Cookie Policy.
Any processing of personal data that has been made publicly available by the data subject will, in any event, be carried out in accordance with the principles and conditions of lawfulness set out in the GDPR and limited to purposes compatible with the context in which such data was made publicly available.
1.2. Personal data provided by you
Contact or other personal data, (included in the email), possibly provided by you when voluntarily compiling forms on our website or when signing a supply agreement;
Potential contacts through our emails to communicate with the company Settesoli, information, communications, complaints or the optional or voluntary sending of messages, by post or email, to the addresses indicated on the website, involves the subsequent acquisition of sender’s address and email address, as this is necessary for response to requests, as well as any other personal data included in the relevant communications.
1.3 Promotion and marketing, and data provided by third parties
- Contact details provided by you when voluntarily completing forms on our website for the purpose of participating in promotional and marketing campaigns under our own brands, or obtained via platforms such as https://www.wineplatform.it/ and similar sites. You will be able to subscribe to mailing lists or newsletters in order to receive commercial information about products and promotional initiatives relating to Settesoli’s brands, or to take part in market research and/or customer satisfaction surveys.
- The activation of tools related to browsing our websites (general applications), such as widgets, involves the disclosure of the user’s data (contact details, email address) to the application owner, who is responsible for the processing as set out in their privacy policy. The information collected through these applications may be shared with the owner of the Settesoli website, who may use it for promotional and marketing campaigns under their own brands.
1.4 Data collected via the ‘Careers’ section
Via the ‘Careers’ section, data provided by the applicant when submitting their application may be collected, such as first name, surname, email address, telephone number, years’ experience, preferred place of work, sector of interest, CV, LinkedIn profile (if applicable), cover letter and any further information voluntarily included in the CV or application. Candidates are asked not to include data that is irrelevant to the recruitment process and, in particular, unnecessary special categories of personal data.
2) Purposes and legal basis of personal data processing
Personal data is collected and processed electronically, also using information and electronic services, according to the principles of necessity, lawfulness, correctness, proportionality and transparency for the purposes and according to the conditions of lawfulness (known as legal basis) indicated below:
Purpose (A)
- To enable you to browse the Websites and use the services available; to manage and respond to requests for information, assistance or contact submitted via forms, email or telephone. The legal basis is, depending on the case, the performance of pre-contractual measures taken at the data subject’s request pursuant to Article 6(1)(b) of the GDPR, or the Data Proprietor’s legitimate interest in managing the requests received pursuant to Article 6(1)(f) of the GDPR.
- Any communications strictly necessary to respond to a specific request made by the user do not constitute marketing in their own right. The subsequent sending of unsolicited newsletters, offers, promotional or advertising communications in connection with that individual contact is carried out only where there is an appropriate legal basis, usually the data subject’s consent, except in cases expressly permitted by applicable legislation.
Purpose (B)
- In order to take part in marketing and promotional campaigns, users who have given their specific consent may receive, via newsletters, emails, automated systems, follow-up messages and other authorised channels, commercial information on products, initiatives and promotions relating to the brands of Cantine Settesoli S.C.A., as well as invitations to take part in market research and customer satisfaction surveys. For contacts originating from platforms controlled by third parties, Cantine Settesoli S.C.A. will only use such data for direct marketing purposes where consent or another appropriate legal basis clearly and verifiably covers such use. The legal basis is consent pursuant to Article 6(1)(a) and Article 7 of the GDPR.
Purpose (C) – Applications and ‘Careers’
- To manage unsolicited applications and applications for open positions, assess the candidate’s professional profile, contact them and carry out activities related to the recruitment process. The legal basis is the implementation of pre-contractual measures taken at the request of the data subject pursuant to Article 6(1)(b) of the GDPR. Where the CV contains special categories of data that are relevant and necessary for the recruitment process, the processing of such data will take place within the limits permitted by Article 9(2)(b) of the GDPR and applicable national legislation. Consent is not required for the mere processing of the application.
Candidates’ data will be retained for the time necessary for the selection process and, as a general rule, for a period not exceeding 24 months from receipt or the last update of the application, unless an employment relationship is established or further retention is necessary to safeguard rights.
For the ‘Careers’ section, a specific privacy notice for candidates, consistent with this Privacy Policy, must be made available alongside the application form.
- Protection of the rights and respect for the conditions of use of the Website and the verification of compliance of the provisions required by the sector regulation
To ascertain responsibilities in case of potential cyber-crimes against the website or third-parties and to manage possible conducts in violation of what provided for in the sector regulation, as well as to protect our rights before judicial courts or for the various stages leading to the possible commencement of proceedings. It is therefore possible, on request of the public authority, to reveal your personal Data. Legal basis for the processing is the necessity to pursue our legitimate interests (protection of our rights before judicial courts and verification of compliance of the legal provisions required by the sector regulation).
- Fulfilment of legal obligations
To fulfil the obligations required by the laws or regulations or by instructions from the Authorities in charge. Legal basis for the processing is the necessity to fulfil a legal obligation.
- Protection of rights in the event of disputes
In case it is necessary to defend ourselves, take legal action or make a claim against you or third parties, we can store the personal data we regard as necessary to process for these purposes and for the time in which this claim may be prosecuted. Legal basis for the processing is the necessity to pursue our legitimate interests (protection of our rights in the event of disputes).
- Social media
This website can send or request some authorisations (if activated) linked to Social media, allowing the performance of activitys with the user’s personal account and the collection of information, including personal data. Details on the authorizations can be viewed in the specific section “authorisation documents” available on our social media and in our privacy policy.
Basic information that can be processed within this application can concern: id, name, picture, gender, language, localization information and in some cases contacts and friends connected in relation to the privacy policy set up by the user on their own profile.
3) Nature of personal data provision
The provision of personal data via the Websites is optional, except for data indicated as necessary in the individual forms. Failure to provide the necessary data may prevent the Data Proprietor from responding to the enquiry or providing the requested service. For the ‘Careers’ section, the provision of data marked as mandatory is necessary to enable the processing and assessment of the application.
Subscription to mailing lists, newsletters and commercial or promotional communications is optional and is carried out on the basis of the data subject’s specific consent, where required.
The forms on the Websites must clearly distinguish between the purposes requiring optional consent and the activities necessary to process the user’s request. Consent must not be sought for processing operations where the legal basis is other than consent.
4) Recipients of personal data
In order to pursue the above indicated purposes, Your personal data will be processed only by authorised personnel,
a) subjects acting as data processors as: i) people, companies or professional offices which provide assistance and consultation to Settesoli in accounting, administrative, legal, tax, financial and debt collection matters; ii) subjects with whom it is necessary to interact for the supply of services; iii) subjects entrusted to carry out technical maintenance services (including the maintenance of network devices or supply of services);
b) subjects, institutions or authorities to whom it is mandatory to communicate your personal data by virtue of legal obligations or instructions from the authorities;
c) people authorised by Settesoli to the processing of Personal Data necessary to carry out activities strictly related to the supply of Services, who committed to preserve confidentiality or have an appropriate legal obligation of confidentiality, as Settesoli employees;
The list of data processors and persons authorised to process data, which is constantly updated, is kept at the Data Proprietor’s registered office.
The list of data processors or authorised persons is available on request by sending a written enquiry to Settesoli at the following address: privacy@cantinesettesoli.it.
As regards the technical management of the Websites and online communication platforms, the Data Proprietor engages service providers appointed as Data Processors in accordance with Article 28 of the GDPR, where the conditions for this apply. The up-to-date list of Data Processors may be requested from privacy@cantinesettesoli.it. As at the date of revision of this policy, the Cantine Settesoli corporate website is developed and managed with the support of external technology providers; the continued status of individual providers must be verified periodically before their names are included in the Privacy Policy.
5) Retention period, place of personal data storage and transfer
Cantine Settesoli S.C.A. processes your personal data at its own premises and at any other locations where the parties involved in the processing are situated. Where data is transferred to countries outside the European Economic Area or to international organisations, the transfer will take place in accordance with Articles 44 et seq. of the GDPR and, in particular, on the basis of adequacy decisions pursuant to Article 45 or appropriate safeguards pursuant to Article 46 of the GDPR, where applicable.
Where required by the applicable legislation and taking into account the transfer mechanism used, the Data Proprietor also assesses the circumstances of the transfer and any need for additional measures, documenting the assessments carried out.
Cantine Settesoli S.C.A. and the Data Processors acting on its behalf retain the data for the time necessary to fulfil the specific purposes and in accordance with the criteria set out below. Data relating to contact enquiries are retained for the time necessary to handle the enquiry and for any subsequent protection of rights; data processed to comply with legal obligations are retained for the periods provided for by the applicable legislation; candidates’ data are normally retained for no longer than 24 months from receipt or the last update of the application, unless an employment relationship is established or there is a need to protect rights.
Documentation relevant for administrative, contractual, accounting or tax purposes is retained for the periods prescribed by law and, where necessary, to safeguard the Data Proprietor’s rights.
For marketing purposes based on consent, data is retained until consent is withdrawn and, in any event, is subject to periodic review to assess the continued existence of the interest and the necessity of the processing; as a general organizational principle, retention for promotional purposes does not normally exceed 24 months from the last significant interaction, unless consent is renewed or there is another documented justification compatible with the applicable legislation.
6) User’s rights
As a user, according to art. 7 and from 15 to 22 of the “Regulation”, you have the right to:
- withdraw the consent, if given, at any time and without prejudice to the lawfulness of the processing based on the consent given prior to the withdrawal (art. 7 right to withdrawal of consent);
- obtain confirmation of the existence of your personal data, access the content and receive a copy of them (art. 15 right to access);
- update, modify and/or correct Your personal data (art. 16 right to rectification);
- ask for the deletion or restriction of the processing of data in cases provided for by the “Regulation”, including cases of data processed in violation of the law or in case the storage of data is not necessary for the purposes for which they were collected or otherwise used (art. 17-18 right to deletion and right to restriction);
- within the limits of the provisions of the Regulation, receive a copy of data provided by you in a structured, commonly used format readable by automatic devices and ask for the transmission of such data to another proprietor of data (if technically feasible) (art. 20 right to data portability);
- you also have the right to object the processing of your data at any time (art. 21 right to object);
- you also have the right to know about a possible automated decision process, including profiling (not provided).
You can exercise your rights at any time by writing an email to the following address: rpd@cantinesettesoli.it, or by sending a registered letter with return receipt to the following address: Cantine Settesoli S.C.A., Strada Statale 115, 92013 Menfi (AG).
We remind you that to update your personal data you can call +39 092577111 fax 092575707 at any time or write to the address Cantine Settesoli sca Strada Statale 115 92013 Menfi (AG) for any further question or support.
You have the right to complain to the Protection authority at any time in case of violation of the law regarding the protection of personal data. For further information please visit the website of Privacy Authority www.garanteprivacy.it
7) The data proprietor and person responsible for data protection’s contact details
The data proprietor is Cantine Settesoli S.C.A., based in Menfi, via Strada Statale 115 snc, VAT NUMBER 00071330849, tel. 092577111, available at the following email address: privacy@cantinesettesoli.it tel. 092577111 fax 092575707, or by sending a registered letter with return receipt.
According to art. 37 of GDPR, the Data protection supervisor, on behalf of the Data proprietor Cantine Settesoli sca, is the company NEOS S.r.l., based in Palermo, via Vincenzo di Marco n. 1/b, available at the following email address: rpd@cantinesettesoli.it .
8) Automated decision-making
Personal data is not subject to automated decision-making or profiling according to Article 22 of the GDPR.
9)Updates
The Proprietor of Data has the right to change this privacy policy at any time by informing the Users on this page. You may want to check it often, taking as reference the last date of change date indicated.
Last update: 26/08/2026 – rev.04.