WhatsApp Privacy Policy

Privacy Policy for Customer Service via WhatsApp

Tenute Ruffino S.r.l. Società Agricola (hereinafter "Ruffino," "we," "us") with registered office in Via Poggio al Mandorlo 1, Loc. Quarate, Bagno a Ripoli (FI), as data controller, in full compliance with the provisions of EU Regulation 2016/679 - General Data Protection Regulation - (hereinafter "GDPR") and Legislative Decree no. 196 of June 30, 2003, as amended by Legislative Decree no. 101 of August 10, 2018, No. 101 (collectively, the "Applicable Privacy Legislation"), wishes to provide users of the Ruffino website and customers of its facilities (hereinafter the "Data Subjects") who intend to use the WhatsApp support channel with clear and simple information about the processing of their personal data.

Service Features

The assistance service provided through the WhatsApp channel is entirely optional, voluntary, and optional, activated upon express request by the individual Data Subject. For further information on the conditions applicable to the use of the WhatsApp service, please consult the relevant terms of use of the service: https://www.whatsapp.com/legal?lang=en If you have any doubts or questions regarding the information provided below, please contact Ruffino at the addresses indicated below.

Origin and type of personal data processed

Personal data is provided by the data subject when requesting assistance via WhatsApp. By way of example, the following personal data will be processed: first and last name, username and/or image associated with the WhatsApp profile used, mobile phone number.

The profile picture may be viewed by the operator responsible for handling the request and duly authorized to process it, but it will not be stored in any database. If the interaction takes place via chatbot systems, the profile picture will not be used or stored in any way. Ruffino will not process any personal data of the Data Subject other than those strictly necessary for the provision of the assistance service and possibly provided by the Data Subject by uploading unsolicited files (e.g., special categories of data, geolocation data).

Purposes of processing and legal bases

Personal data is processed to respond to a specific - and voluntary - request for assistance via WhatsApp by the data subject, as well as to manage related/instrumental activities. For this purpose, the legal basis for the processing is the performance of a contract or pre-contractual measures at the request of the data subject (Art. 6 (1) b GDPR).

Methods of processing, provision, and storage of data

The personal data of the data subject will be processed using IT/telematic tools and in such a way as to ensure the confidentiality and security of the data, in compliance with the provisions of the applicable privacy legislation. Therefore, personal data will be processed and stored in full compliance with the principles of necessity, data minimization, and storage limitation, through the adoption of technical and organizational measures appropriate to the level of risk of the processing and for a period of time not exceeding the achievement of the purposes for which they are processed, in any case for the time strictly necessary to achieve the purposes of managing requests for assistance relating to the services requested.

The provision of data is necessary in order to allow the correct provision of the assistance service via WhatsApp. Failure to provide such data would make it impossible to execute the requests received.

Categories of recipients of personal data

Without the need for explicit consent, Ruffino may communicate personal data to the following categories:

  • authorized personnel of Ruffino and other companies of the Ruffino Group;
  • our third-party service providers, who act as data processors and are appointed and commissioned on the basis of a specific contract. Service providers will process the personal data of the Data Subject on our behalf only to the extent necessary to perform their support functions (e.g., payment processing), in accordance with our instructions and applicable privacy regulations. You can request an updated list of data processors by contacting us at the addresses listed below;
  • third parties such as auditors, legal advisors, or other professional advisors;
  • entities to whom such communication must be made in order to comply with national and EU regulations (e.g., judicial or administrative authorities or other public entities entitled to request such data, in cases provided for by law).

You can obtain an updated list of the parties with whom we share personal data by contacting us at the addresses indicated below in this Privacy Policy.

Transfer of data outside the EU

The use of WhatsApp and the transmission of data may temporarily involve the transfer of data to the United States, where WhatsApp Inc. is based, which will act as an independent data controller for this part of the process. For more information on the processing of personal data by WhatsApp Inc., please refer to the privacy policy at https://www.whatsapp.com/legal/privacy-policy-eea?lang=en The transfer of personal data to the US will be carried out with adequate safeguards to ensure a level of data protection substantially equivalent to that guaranteed by the European Economic Area. In particular, we will rely on the Data Privacy Framework ("DPF"), which regulates the transfer of data between the European Union and the US.

You can obtain more information about the countries to which we transfer personal data and the safeguards we adopt for such transfers by contacting us at the addresses indicated at the bottom of this Privacy Policy.

Rights of Data Subjects

Data subjects may contact Ruffino at the contact details provided below to exercise their rights under the applicable privacy legislation, including:

  • Right of access: you may request access to your data and verify its origin and accuracy.
  • Right to portability: in some cases, you may also obtain a copy of your personal data in a commonly used and machine-readable format to enable you to exercise your right to data portability and transfer your data to another data controller, or ask us to transfer your data directly to another data controller, to the extent that this is technically possible.
  • Right to rectification: The data subject may request the integration of incomplete data and the rectification or updating of inaccurate data.
  • Right to erasure: the data subject may request the erasure of their data and the portability thereof.
  • Right to restrict processing: the data subject may request the restriction of processing and object to the processing of their personal data.
  • Right to withdraw consent: the Data Subject may withdraw any consent given. However, such withdrawal shall not affect the lawfulness of processing carried out prior to the withdrawal of consent.
  • Right to lodge a complaint: the data subject may lodge a complaint with the competent supervisory authority (in Italy, the Garante per la Protezione dei Dati Personali) and contact the authority if the exercise of your rights is subject to delays, restrictions, or exclusions.
  • Right to object: as provided for by the applicable privacy legislation, the data subject has the right to object at any time to the processing of their personal data for reasons related to their particular situation, and we may be required to no longer process their personal data, unless we demonstrate compelling legitimate grounds for the processing or for the establishment, exercise, or defense of legal claims.

Contact details

If you have any questions or comments about this Privacy Policy or our privacy practices, if you wish to exercise your rights as set out above, or receive an up-to-date list of our data processors and third parties with whom we share your personal data, or receive further information on the balancing test carried out when we rely on our legitimate interest for data processing and on the transfer of personal data to third countries, please write to:

Tenute Ruffino S.r.l. Società Agricola with registered office in Via Poggio al Mandorlo 1, Loc. Quarate, Bagno a Ripoli (FI), email: tenuteruffino@ruffino.it or hospitality@ruffino.it