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SIMPLIFIED DISCLOSURE |
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| Data controller | Sushi Nokoe Srl Via Rubra n. 42 00188 - Rome |
| Purpose of processing | Communication and dissemination of information about the Owner's products, services and initiatives. Customer retention. |
| Data processed | Municipalities |
| Nature of conferment |
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| Legal Basis | Contractual and pre-contractual activities, consent of the Data Subject, legitimate interest |
| Storage terms | 1 day for browsing data and messaging. Until cancellation or termination request in other cases. |
| Cookie | (technical, statistical, marketing, analytical) |
| Communication and outreach |
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| Transfer abroad | Possible for the use of some information society services |
| Rights of the Interested Party | Access, rectification, supplementation, deletion, restriction and opposition, portability, recourse to the Control Authority |
| Automated decision-making processes | NO |
| Control authority | Guarantor Authority for the Protection of Personal Data Piazza Venezia n. 11, 00187 - Rome |
The company Sushi Nokoe Srl, with registered office in Rome, Via Rubra n. 42, P. Iva 07255171006, as Data Controller,
INFORMS
the users of the website www.darumasushi.com that personal data, collected by the Controller or spontaneously provided by the interested parties, will be processed lawfully and fairly, in accordance with the principles enshrined in the EU and Italian law. The main regulations governing the processing of personal data are European Regulation 679/2016 and Legislative Decree 196/2003, as amended by Legislative Decree 101/2018.
1. Definitions
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Interested |
Natural person to whom the data processed by the Data Controller or Data Processor belongs |
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Holder |
The natural or legal person, public authority, service or other body that, individually or jointly with others, determines the purposes and means of the processing of personal data (in this case, Sushi Nokoe Srl, in the person of its legal representative p.t.) |
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Responsible |
The natural or legal person, public authority, service or other body that processes personal data on behalf of the data controller on the basis of a contract governing the terms of the entrustment (in this case, Secret Key Srl, the Web Agency that maintains the site) |
2. Purposes of processing
2.1 The data collected through the website are managed at the company's premises by authorized and trained individuals, using manual and computerized procedures, to allow the user a simple and gratifying browsing experience, to collect useful elements to improve the offer of products and services, to execute specific requests of the Data Subject (pre-contractual and contractual), for ordinary administrative and accounting activities and for any other related activities.
2.2 The processing, subject to the acquisition of specific consent, may be carried out, also by third parties expressly appointed by the Data Controller, for further purposes:
statistical analysis on the operation of the site and the effectiveness of communication;
detection of the degree of satisfaction, tastes, preferences and habits of the customer;
sending of commercial information or advertising material;
issuance of fidelity cards related to particular conditions of sale
participation in games, contests or sweepstakes;
user involvement in events and manifestations
market research and other operations directly or indirectly related to marketing activities
3 Data subject to processing
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Navigation data |
Municipalities |
IP address, operating system and browser used for browsing, date and time of connection and disconnection, time spent on the site, pages visited, activity performed, location (if the relevant service is active) and any other information made available or transmitted by the Data Subject's device, according to the options selected |
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Reservations and takeout |
Municipalities |
First name, Last name, e-mail address and phone/cell phone number, delivery address |
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Contact |
Municipalities |
First name, Last name, e-mail address, telephone or cell phone number, other data submitted by the Data Subject to the Controller's e-mail addresses or through forms on the site |
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Newsletter |
Municipalities |
Name and email address of the Data Subject, for sending periodic communications about the Controller's products, services and initiatives |
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Work with us |
Municipalities |
First name, Last name, e-mail address, telephone and postal contact details, place and date of birth, educational background and previous work experience, other information useful for the selection of personnel and the possible establishment of an employment relationship(among the data forwarded by the Interested Party there may be special data, for which reference should be made to the specific information for the selection of personnel) |
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Daruma card |
Municipalities |
First name, last name, e-mail address, cell phone number, gender and date of birth, favorite food |
Filling out forms on the website, in order to receive information about products and services, involves the acquisition of customer data in the Holder's computer system. The information is protected by an authentication system and can be accessed only by those in possession of the relevant credentials. In other cases, the procedure generates an e-mail message addressed to the Data Controller, which is encountered according to the requests of the Data Subject. E-mail communications involve the storage of the e-mail address of the Interested Party, which is necessary to respond to the requests made. This includes the data stored in the message. The Data Controller suggests not to transmit the data or personal information of third parties, unless absolutely necessary.
4. Data of Minors
The data of minors are processed exclusively with parental consent and within the limits imposed by law, subject to the requirements of Article 2-quinquies, Legislative Decree 196/2003, as introduced by Legislative Decree 101/2018. The Holder will not be in any way responsible for any false statements that may be provided by minors and, should it ascertain that the statement is false, it will provide for the immediate deletion of any personal data and information acquired.
5. Nature of conferment
5.1 The processing of contact data is indispensable to meet the requests of the Interested Party and fulfill contractual obligations. The provision is therefore necessary, as otherwise the processing cannot take place. Any erroneous or insufficient communication of the requested data may result in the total or partial impossibility to execute the requests of the Interested Party and the possible mismatch of the results of the processing with the agreements made or the obligations imposed by rules and regulations. Additional information is required for the purposes of personnel selection (professional training, past work experience) and business collaboration (past work experience, financial solvency).
5.2 Other data, on the other hand, are collected for the sole purpose of adjusting navigation, promotional campaigns, offers, production and stocks, as well as, in general, the company's activity, to the tastes and interests of customers. Their provision, therefore, is not mandatory and any refusal to process or withdrawal of consent already given will not affect the establishment and continuation of the main relationship.
6. Legal bases of the processing carried out by the Controller are the fulfillments related to the pre-contractual and contractual stages of the relationship, the legitimate interest of the Controller in managing the data necessary to improve the offer of products and services, and the consent expressed by the data subjects. It is possible to request the Data Controller to specify the legal basis of each processing.
7. Storage terms
The data processed by the Data Controller, without prejudice to legal obligations, are retained until expressly requested for deletion by the Interested Party and in any case periodically checked, including by automatic procedures, in order to ensure that they are up to date and actually meet the purposes of processing. If the purpose for which the data was acquired has ceased to exist, the data will be deleted, unless it must be processed to comply with regulatory obligations or to protect rights in a court of law
Specific terms:
Browsing data are retained for 1 day after collection and then deleted.
Data related to the contact form and online reservations are kept for the time strictly necessary to execute the data subject's requests and subsequently deleted.
For data related to CVs in the "work with us" section, please refer to the specific recruitment notice
After the processing is completed and the data subject's rights are deleted, they can no longer be exercised.
8. Browsing Data
The IT system and software used for the company's web portal acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication products: IP addresses and domain names of the computer used by the user to connect to the site, URL (Uniform Resource Locator) of the requested resource, time of the request, method used to send the request to the server, size of the file received, numeric code used to indicate the status of the response given by the server (executed or error, etc.) and other parameters related to the user's operating system and computer. This information is not stored to identify the data subjects but, due to its nature, may, through processing and association with other data, allow identification of the user. They are used to carry out statistics on the use of the site and to check its proper functioning. They are normally deleted after processing. They may be used and provided to law enforcement agencies and the judiciary to ascertain responsibility in the event of damage to the site or offenses perpetrated through the network.
9. Cookies
Some information regarding navigation is stored on the client's computer and read by the system the next time it is connected. Such a file, called a "cookie," contains data that are not personal in nature but may allow indirect identification by association with other information.
The information contained in cookies makes it possible to see the frequency of visits to a site and the activity performed while browsing. This makes it possible, over time, to improve the content of the site and make it easier for the user to use. Companies that transmit content to the site or whose sites are accessible through links may also use cookies when the user selects the relevant link. In these cases, the use of cookies is not under the direct control of the Data Controller. Most browsers automatically accept cookies, but it is possible to reject them or select only some of them, according to the preferences set by the user. However, if the user inhibits the loading of cookies, some components of the site may stop working and some pages may be incomplete.
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Essential technical cookies |
These cookies are necessary to ensure the proper and smooth operation of the site: they allow page navigation, content sharing, storage of login credentials to make it faster to enter the site and to keep preferences active while browsing, facilitating the browsing or purchasing experience. Without these cookies, it is not possible to provide, in whole or in part, the services for which users access the site. |
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Statistical cookies |
They allow us to understand how users use the site so that we can then evaluate and improve its operation in order to produce increasingly appropriate content. They allow to know which pages are the most and least frequented, how many visitors are on the site, how much time is spent on the site by the average user, and how visitors arrive on the site. In this way, it is possible to determine what works best and what content is most liked, and how the content and functionality of the pages can be improved. |
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Analytics cookies |
They serve to keep track of the user's searches in order to submit products and services to the user that conform to previous browsing and searches. They are normally used for remarketing operations, through which advertising related to previous consultations and similar products and services is conveyed to the user during navigation |
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Profiling cookies |
These are tools suitable for storing the choices made by the user during browsing and consultation, in order to create personal profiles capable of classifying and filing tastes, preferences, browsing and consumption habits. Through the generation of such profiles, the user's browsing experience can be improved, but above all be oriented to his or her preferences, capabilities and possibilities to purchase or use services. They can be deactivated without creating any obstacle or impediment to navigation. |
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Third-party cookies |
These are cookies used by third parties not directly controlled by the Owner. The company cannot provide guarantees with respect to the use that will be made of the data, the processing of which is directly operated by an external party Cookies from third-party operators enable advanced functionality, more information and personal features, including the ability to share content through social networks and have a personalized site experience based on preferences expressed through the pages visited. If you use such external services, those who provide them may be able to know that you have visited the Controller's site. The use of data collected by such external operators is subject to their data protection policies. Third-party cookies are identified by the names of their respective operators and can be disabled. |
10. Managing cookies
The buttons displayed by the banner in present on the first page of the site allow you to accept the preset cookies, to select others, to refuse their installation.
The preferences expressed can still be changed through the browser settings, which also allows you to proceed to the deletion of all cookies already installed.
To adjust or change the browser settings, the manufacturer's guide should be consulted. More information is available at the following addresses: Google Chrome, Mozilla Firefox, Apple Safari, Microsoft Internet Explorer, Microsoft Edge. Further information about the cookies used by the site can be requested directly from the Data Controller
11. Third-party sites.
The site, even occasionally, may contain links to third-party sites and applications (Google Adwords, Analitycs, Youtube, Vimeo, etc.), to provide additional services and information to the user. When the user uses these links, he or she is leaving the corporate site and accessing resources that are not under the direct control of the Data Controller, who, therefore, will not be responsible for the procedures related to navigation, security and processing of personal data operated by the other sites, even when co-branding or displaying the corporate logo. Careful examination of the security and privacy procedures of the visited site is recommended, which may transmit additional cookies, read those already on the user's hard drive, and ask for/acquire additional personal information.
12. Newsletter management services
The newsletter is managed by software that uses a database of e-mail addresses to send communications to registered users (no data is automatically acquired for this purpose). At the bottom of each communication is a link to proceed to unsubscribe one's data from that address list and stop receiving messages.
13. Personnel Search Forms.
Through these forms, the Owner acquires the information necessary for an initial assessment of the candidate in order to decide whether to call him or her in for an interview and for the examination of whether he or she actually fits the position he or she should hold in the company. Normally, a set of standard information (first name, last name, telephone and postal contact information, telematic contact information, level of education and previous work experience) is associated with the CV drafted and produced by the candidate. If the selection is successful, the data are forwarded to the appropriate office for hiring, otherwise they are retained for a period deemed appropriate with respect to the necessary updating by the candidate (consult the specific recruitment information).
14. Interaction with social networks and external platforms
The site, through widgets and buttons, can interact with external platforms and social networks. In this case, the information acquired depends on the settings of the profiles used by the user.
Facebook's "Like" buttons, Twitter's "Tweet" buttons, Linkedin's "Recommend" buttons, etc., allow sharing pages or topics of the site with the respective social platforms and acquire the data of the Data Subject. More information can be requested from the companies offering the service. The user's personal data, in such cases, is not managed by the Data Controller, which links such buttons only to offer an additional service to the Data Subject but has no control over them.
15. Automated decision-making processes
The Owner does not make use of automated decision-making processes
16. Communication and dissemination
The data processed through the site are exclusively of a common nature and are not intended for dissemination.
They will be communicated to third parties, who may assume, depending on the type of relationship, the status of data controller ex art. 28, Reg. EU 679/2016 or mere recipient of the communication, for activities related to or deriving from that of the Data Controller or in the fulfillment of obligations arising from laws or regulations (Institutions, Law Enforcement, Judicial Authority, etc.). Examples include but are not limited to:
Companies that need to know the data of the Data Subject for purposes concerning the relationship with the Controller (Credit Institutions, electronic money and payment management institutions, communication companies, etc.);
Consultants, collaborators, service companies, to the extent necessary to carry out the assignment given by the Data Controller;
Postal services, couriers, transporters;
The updated list of data processors is available at the Controller's office.
17. Transfer abroad
The user's personal data may be transferred abroad for the use of certain information society services. In any case, the transfer will take place exclusively within the European Economic Area or to countries that guarantee the same level of protection required by EU Reg. 679/2016 and subject to the application of the standard contractual clauses indicated by the European Commission.
18. Rights of the Data Subject.
Data subjects are granted the rights set forth in Articles 15 to 22 of GDPR 679/2016. In particular, the Data Subject has the right to access his or her data (Art. 15) to ask for its rectification, updating, integration (Art. 16) and deletion (Art. 17), to limit its use by the Data Controller (Art. 18), to obtain a copy in a structured, commonly used and machine-readable format (Art. 20), and to object to its processing if the conditions are met (Art. 21 and 22). The rights are exercisable to the extent that the processing is not mandatory by provisions of law or regulation. Instances relating to the exercise of the rights of the Data Subject may be forwarded to the Data Controller at [email protected] The Data Subject, if not satisfied with the response provided to his or her requests, may lodge a complaint with the Data Protection Authority. The citizen of another European Union member state has the right to appeal to the Supervisory Authority of his country.
