Privacy notice | Sorridi

1) Data controller

Sorridi S.R.L. – Via Curtatone, 19 – 04100 Latina (LT), Italy – VAT no. 03167100597 – email: info@allineatorisorridi.com. The controller determines the purposes and means of processing in connection with the website, the Sorridi app and the “Win with a Smile!” competition.

2) Scope

This notice covers use of the website and the Sorridi app, participation in the “Win with a Smile!” competition, and service and promotional communications.

3) Categories of data processed

Identification data (first name, surname, Instagram username, email), content (photos and captions uploaded for the competition), technical data (logs, IP address, device ID, timestamps) and social media data (Instagram profile). No special categories of data under Article 9 GDPR or biometric data are processed.

4) Purposes and legal bases

Running the competition (Article 6(1)(b)); publishing images on Sorridi brand channels (Article 6(1)(a)); legal obligations and defence of legal claims (Article 6(1)(c), (f)); newsletters and direct marketing (Article 6(1)(a)); security and prevention of misuse (Article 6(1)(f)).

5) Providing your data

Data needed to enter the competition is mandatory. Consent to image publication and marketing is optional; withholding it does not affect participation.

6) Processing methods and security

Electronic processing with appropriate technical and organisational measures under Article 32 GDPR, including access controls, encryption, backups, data minimisation and privacy by design.

7) Retention periods

Competition data: for the duration of the competition plus 12 months. Images published with consent: until consent is withdrawn. Technical logs: 12 months, unless required for legal defence or security.

8) Recipients

The controller's authorised staff; data processors (hosting, IT, advisers, CRM); competent authorities. Instagram acts as an independent controller.

9) Transfers outside the EU

Any transfers to third countries will comply with Chapter V GDPR, using Standard Contractual Clauses or adequacy decisions.

10) Your rights

You can exercise your rights of access, rectification, erasure, restriction, objection, portability and withdrawal of consent by writing to info@allineatorisorridi.com. You can also lodge a complaint with the Italian data protection authority at www.garanteprivacy.it.

11) Privacy contact and DPO

Privacy contact: info@allineatorisorridi.com. No Data Protection Officer has currently been appointed.

12) Cookies and similar technologies

We use technical and analytics cookies and, with consent, profiling cookies. See the cookie policy for details.

13) Updates

The controller may update this notice to reflect legal or technical changes. Last updated: October 2025.