1) DATA CONTROLLER AND DATA PROCESSOR
The Data Controller is LUIGI LAVAZZA S.p.A. (hereinafter "Lavazza" and/or the "Data Controller") with registered office in Turin - Via Bologna 32, in the person of its legal representative pro tempore.
The Data Processor is Lavazza Australia Pty Ltd (hereinafter "Lavazza" and/or the "Data Processor") with registered office at 117 Church Street, Hawthorn (VIC) 3122 – ABN 94 605 275 107 in the person of its legal representative pro tempore.
2) DATA PROTECTION OFFICER - DPO
Our company is part of the Lavazza Group, under the coordination and direction of the parent company Luigi Lavazza S.p.A. (Lavazza Italy). In accordance with the provisions of the European General Data Protection Regulation (Gdpr), the Lavazza Group has a Data Protection Officer (DPO), who is responsible for monitoring compliance with the Gdpr as well as with the national Data Protection Laws of the companies part of the Group, and will be the contact person for data subjects, as well as for the Italian Data Protection Authority. The DPO can be contacted at the email address PrivacyDPO@lavazza.com
We can be contacted about privacy issues by email sent to AU.firstname.lastname@example.org. Alternatively, you can write to us at Privacy Officer, Lavazza Australia, 117 Church Street, Hawthorn Victoria 3122.
3) PERSONAL DATA PROCESSED
Lavazza collects the following types of personal information where it is reasonably necessary for our business purposes:
- email address
- telephone number
- Geo-location and/or Internet browsing data (including IP addresses)
- browsing history
- where you apply for employment with Lavazza, information which may be contained in a resume and which may be recorded during any interview or pre-employment checking
We do not generally collect sensitive information about you.
The provision of your Personal Data is optional. However, the failure to provide your Personal Data may result in the impossibility to use certain services (e.g. to place orders and make purchases, to participate in competitions and give-aways, to be sent the newsletter, etc.).
The compulsory or optional nature of the provision of your Personal Data will be marked each time using symbols (e.g. “*”) placed next to the information that requires the provision of data for the respective purpose
4) HOW LAVAZZA COLLECTS PERSONAL INFORMATION ABOUT YOU
We collect personal information from you in the following ways:
- when you make a purchase via our website
- when you contact our consumer information services via telephone or our contact us web page
- when you sign up to receive our newsletter or other marketing materials
- when you enter a promotion
- when you apply for employment with us and during the recruitment process
- when you conduct business with us
- when you provide your information to our staff
- when you supply goods and/or services to us
We may also collect personal information about you from publicly available sources (such as the internet) and from third parties (such as your referees provided during the recruitment process if you apply for a job with us).
5) PURPOSE & LEGAL BASIS OF THE PROCESSING OF PERSONAL INFORMATION
We collect your personal information for the following purposes:
- to fulfil an order you have placed on the Site
- to conduct business with you
- to respond to your query submitted via our consumer information service
- to process your entry into a promotion
- to consider your application for employment
- to send you marketing materials (but only where you have consented to receive those marketing materials or where we are permitted to do so by law)
- for any other purpose that was communicated to you at the time of collection
Any additional purpose for the collection of personal information (not set out in this policy) will be identified at the time that we collect personal information from you, or as soon as practicable afterwards.
In accordance with the needs associated with accessing the various sections of the Lavazza Websites (and without prejudice to the individual initiatives that involve the provision of specific Personal Data, for which specific privacy notices will be published on a case-to-case basis), the purposes of the processing of your Personal Data and the related legal grounds are indicated below:
- Registration to the Website: the procedure of registering to our Website, through the creation of an account or the use of an already-existing social network account, is aimed at allowing you to use the Website as a "Registered User" and to access a series of exclusive services offered through it. The provision of data is optional. The legal basis for processing is the implementation of pre-contractual measures to which the data subject is party. Access via the use of social networks may involve accessing personal data other than the data provided at the time of registration to our portal, on the basis of the authorisations you have provided to these social networks and which are to be referred to in relation to the policies on the management of your privacy.
- Purchase of products: by using our Website you may purchase Lavazza products as a Registered User (and in this case you do not need to re-enter your Personal Data every time you purchase a product) and as a Non-Registered User (re-entering the required data each time in order to complete a purchase). Both these cases require the processing of your Personal Data. Your Personal Data will be processed in order to manage orders and payments, and to fulfil consequent administrative and accounting obligations, as well as to contact you for any information regarding your purchases (for example, information on the status of your orders). The provision of personal data is optional, but necessary to complete the purchase order. The legal basis for the processing is the performance of the Contract to which the data subject is party.
- Management of requests: the Personal Data will be collected in order to manage and answer requests about the products and initiatives of the various brands of the Lavazza Group. The legal basis for this processing is the implementation of pre-contractual measures to which the data subject is party.
- Marketing: Subject to your specific consent, we may process your Personal Data in order to send you commercial communications, as well as to invite you to take part in our promotional initiatives, to participate in our events and to register for our newsletter. The legal basis of this processing is the Consent of the Data Subject, which can be withdrawn at any time.
- Participation in competitions and give-aways: we may process your Personal Data so that you can participate in competitions and give-aways. The legal basis for this processing is the implementation of pre-contractual measures to which the data subject is party.
In addition to the previous cases:
- Analysis purposes: the Personal Data you have provided when interacting with the Lavazza world and the information regarding this interaction will be collected in our database and will be used to anonymously analyse and improve the services we offer, to assess the efficiency of the activities and initiatives promoted by Lavazza and to conduct statistical analysis on the composition of the database. The legal basis of the processing is the legitimate interest of the Data Controller.
- Any other purpose for which you have provided your specific consent can be withdrawn at any time.
We may disclose your personal information to third parties in connection with one or more of the purposes outlined above.
In particular, we may disclose your personal information to any one or more of the following third parties:
• our parent company, Luigi Lavazza S.p.A. (Lavazza Italy), subsidiaries, and affiliated companies, in the course of our business operations. We share your personal information with employees and personnel of Lavazza as necessary for business purposes, such as processing your order, customer service, system administration, and promotion and marketing
• any third parties to whom you have directed us to disclose your personal information (e.g. referees);
• our contractors (such as mailing houses, prize providers, marketing agencies, insurance providers, website and data hosting providers and other IT suppliers) and others persons who provide services to us;
• companies who may use your personal information in order to tailor electronic advertising to you (e.g. on a webpage) in relation to our products and services;
• our accountants, insurers, lawyers, auditors and other professional advisers;
• in the event that our assets are or may be acquired by a third party, to that third party and their advisors;
• in certain circumstances, third parties that require the information for law enforcement or to prevent a serious threat to public safety; and
• otherwise as permitted or required by law.
7) OVERSEAS DISCLOSURE & STORAGE
Personal information which we collect will be transferred to Lavazza Italy in the European Union and accessed by Lavazza Italy personnel for processing. Personal information processing by Lavazza Italy is compliant with relevant data protection laws, including the provisions of the European Union’s Regulation 679/2016 (“GDPR – General Data Protection Regulation”). We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
In order to ensure compliance with the principles of necessity and proportionality of the processing, we have defined various Personal Data storage periods for the individual purposes pursued;
- Registration to the Website: The Personal Data you have provided in order to register to the Website will be stored for the entire period of time that you are registered on the Website. If your Account is inactive for 24 months, it will be deleted.
- Invoice data will be stored for an appropriate period of time to ensure the proper performance of the agreement and in any case for an additional 10 years for the purposes of the fulfilment of connected administrative and tax obligations.
- The data collected for the management of competitions and give-aways will be stored for the entire duration of the give-away and for an appropriate period of time to ensure its proper performance. This is without prejudice to the fulfilment of administrative and tax obligations for which the data storage period is provided for by law.
- The data collected for profiling purposes and for the sending of promotional and advertising material, for which consent has been given, will be stored for a period of time of no longer than 12 and 24 months respectively or for any other period of time that may be indicated by the supervisory authorities. If you have not provided the above consent, your personal data will be made anonymous and used for statistical analysis.
- The data collected in order to manage and answer requests about the products and initiatives of the various brands of the Lavazza Group and the data provided when interacting with the Lavazza world will be stored for the period necessary to carry out the requests and will subsequently be cancelled if there is no further contact.
8) RIGHTS OF THE DATA SUBJECT
You can exercise the rights set out in articles 15 et seq. of the Regulation vis-à-vis the Data Controller at any time, including:
a) the right to obtain confirmation as to whether or not personal data concerning you exists, regardless of it being already recorded, and communication of such data in intelligible form;
b) the right to withdraw the consent you have given for the purposes of the processing at any time;
c) the right to access, rectify, erase and limit the processing and portability of your personal data;
d) the right to object to its processing any time you wish;
e) the right to commence proceedings before the competent supervisory Authority, if you think that the processing of your data is contrary to the laws in force.
9) COOKIES & INFORMATION COLLECTED FROM OUR WEBSITE
Lavazza will receive and store information that you provide or that is generated by your use of our website, www.lavazza.com.au (Website).
10) STORAGE & SECURITY
We may store personal information on computer databases and/or in hard copy, and will employ reasonable commercial physical and electronic security measures to protect any records which contain your personal information.
We may also engage third party service providers to assist in storing and processing certain types of personal information for us. Some of these service providers may be located overseas, or use facilities located overseas to provide us with services.
We will take reasonable steps to keep any personal information that we hold about you secure from misuse, interference and loss, and from unauthorised access, modification or disclosure as required by the privacy legislation.
However, except to the extent that liability cannot be excluded due to the operation of law, we exclude all liability (including in negligence) for the consequences of any unauthorised access to your personal information. Please notify us immediately if you become aware of any breach of security.
11) CONTACT INFORMATION
You can contact us if:
• you want to access or correct any personal information that we hold about you
• you want to unsubscribe from our marketing database
• you think that we have breached the Australian Privacy Principles and you want to make a complaint
We can be contacted about privacy issues by email sent to AU.email@example.com.
Alternatively, you can write to us at Privacy Officer, Lavazza Australia, 117 Church Street, Hawthorn Victoria 3122.
When contacting us, please provide as much detail as possible in relation to your query, issue or complaint
Please note that:
• Your complaints are will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner and in accordance with the privacy legislation. If you are not satisfied with the outcome of our assessment of your complaint, you may wish to contact the Office of the Australian Information Commissioner.
• If you require access to the personal information that we hold about you, we may charge a fee for providing access to this information and we may refuse access where the privacy legislation allows us to do so.
Version update: April 2020