Privacy Policy

1. Data Controller

EUROPE DISTRIBUTION TRADE D.O.O., Porporela ulica 2, 52466 Novigrad, Croatia. Email: info@sicilyfinestfood.it.

Privacy contact: Salvatore Agosta, who can be contacted at the same address. The indication of the contact person does not constitute the appointment of a data protection officer (DPO).

2. Categories of data processed

Identification and contact data of company contacts, tax and company data to the extent that they identify natural persons, shipping and billing addresses, account data, orders, products, quantities, tracking, communications, payment outcomes and identifiers, browsing data and online identifiers, cookies, preferences and consent records are processed. Full card details are handled by payment service providers in accordance with their respective procedures. Data relating to legal entities are distinguished from the personal data of natural persons acting on their behalf.

3. Purposes and legal bases

3.1 Management of requests, B2B commercial relationships, orders, payments, shipments and support: performance of the contract or of pre-contractual measures where the data subject is a party to the contract (Art. 6.1.b GDPR); for contacts of a legal entity, legitimate interest in managing the commercial relationship (Art. 6.1.f GDPR), while respecting the data subject’s rights.

3.2 Accounting, tax and administrative obligations (invoicing, document retention): legal obligation (Art. 6.1.c GDPR).

3.3 Site security, prevention of abuse/fraud, management of disputes, legal protection: legitimate interest of the Data Controller (Art. 6.1.f GDPR).

3.4 Sending newsletters, catalogue updates and promotional communications by email: consent (Art. 6.1.a GDPR), which may be withdrawn at any time via the unsubscribe link or by writing to the Data Controller.

3.5 Analysis of visits through Google Analytics and advertising activities or measurement through Google Ads: consent for cookies and non-essential tools where required by applicable law (Art. 6.1.a GDPR). Preferences are managed through the Site’s consent tools.

4. Processing methods and security measures

Processing is carried out using IT tools and appropriate organisational measures. Access to data is limited to authorised personnel and contractually bound suppliers. Transmission takes place over secure channels (TLS/HTTPS), and reasonable measures are adopted to reduce the risks of unauthorised access, loss or alteration.

5. Recipients and categories of suppliers

The necessary data may be disclosed to Shopify for the ecommerce platform; n8n for operational automations; Google Sheets and Drive for documents and order management; GLS for transport; the relevant producers, limited to fulfilling the items within their responsibility; payment service providers and credit institutions; email, support, IT and security services; and accounting and legal consultants where necessary. Google Analytics and Google Ads process the data provided for by their respective functionalities and by the applicable consent choices.

Depending on the service and applicable agreements, recipients act as processors on behalf of the Data Controller or as independent controllers for their own purposes. Information about recipients and processors may be requested at info@sicilyfinestfood.it.

6. Place of processing and transfers outside the EEA

The digital services used may involve processing or access from countries outside the European Economic Area. Such transfers must take place in compliance with Chapter V of the GDPR, on the basis of an applicable adequacy decision or appropriate safeguards, such as standard contractual clauses, and any necessary supplementary measures. For information about transfers relating to their data and the applicable safeguards, data subjects may contact the Data Controller.

7. Retention

Contractual, tax and accounting data are retained for the periods required by the legislation applicable to the Croatian company and to the individual transaction, taking into account retention obligations and any need for legal protection. Support and complaint data are retained for handling the matter and for the subsequent period necessary to protect rights within the applicable time limits.

Data used to send newsletters are processed until consent is withdrawn or the purpose ceases; the minimum information necessary to document consent and withdrawal or to prevent further unwanted mailings may be retained. Technical logs, analytical data and advertising identifiers are retained according to the purpose, service settings and periods indicated in the consent management tools, where available. Once the purpose and applicable obligations cease to apply, the data are deleted or anonymised. Data subjects may request the criteria and periods applicable to their data.

8. Nature of the provision of data

Providing the data necessary to manage the commercial relationship (order, invoicing, shipment, support) is necessary; failure to provide them prevents performance of the contract. Consent for marketing and non-essential cookies is optional.

9. Data subject rights and complaints

Subject to the conditions provided for by the GDPR, data subjects may exercise the rights of access, rectification, erasure, restriction, portability and objection. They may withdraw consent without affecting the lawfulness of processing carried out before its withdrawal and may object to direct marketing. Requests must be sent to info@sicilyfinestfood.it. A complaint may be lodged with the competent supervisory authority, including the Croatian authority AZOP, or with the authority of the Member State of the data subject’s habitual residence, place of work or the place of the alleged infringement, pursuant to Art. 77 GDPR.

10. Cookies and similar tools

The Site uses technical tools necessary for its operation and analytical or advertising services, including Google Analytics and Google Ads. The banner allows users to accept or reject non-essential cookies and manage the available choices. Use of tools requiring consent is subject to the user’s consent, which may be withdrawn or modified through the consent settings available on the Site. Browser settings also allow cookies to be deleted or blocked. Refusal of non-essential cookies is not a condition preventing purchase.

11. Data relating to products subject to age limits

If products subject to age restrictions are purchased, any data required to verify compliance must be limited to what is necessary and processed in accordance with applicable law. This notice neither describes nor presupposes any specific automated age-verification procedure.

12. Profiling and automations

Order data are also used in operational automations through n8n for document management, communications and logistics. The automation of these activities does not in itself constitute a solely automated decision producing legal effects or similarly significant effects within the meaning of Art. 22 GDPR. Advertising activities and any profiling through the indicated services are subject to the applicable consent choices. If decisions falling within Art. 22 are introduced, the information and safeguards required by law must be provided.

13. Minors

The Site is not intended for minors. If data relating to minors are provided without the legal requirements being met, the Data Controller will delete them upon request.