This information note is provided by the company Gilmar Divisione Industria S.P.A and refers to the websites listed below and to the domains which legitimately link with these:
We wish to offer you the best service possible while respecting your rights and choices. Your data are processed only for the explicit and legitimate purposes stated below.
- Data Controller
- Contact information
- Categories of personal data & the source from which they originate
- Purpose & Legal basis
- Protection of minors
- Legitimate interest
- Possible recipients or categories of recipients of personal data. Dissemination.
- Data retention location & transfer to countries outside the EU
- Processing duration
- Data Subject’s rights
- Right of withdrawal
- Communication of personal data and consequences of failing to communicate data
- Processing method & automated decision-making process
- Changes & Updates
Gilmar Divisione Industria S.P.A. via Malpasso no 723-725 San Giovanni in Marignano (RN) 47842 Italy hereinafter Company or Data Controller
For any request concerning the processing of your data and in order to exercise your rights you can write to: email@example.com
We will answer your requests as soon as possible.
Categories of personal data & the source from which they originate
Data communicated by the user
Contact details (e-mail address, postal address, mobile phone);
Identification and tax data (name, surname, tax code, gender, place and date of birth);
Website registration data (user name and password);
Purchasing data (product category);
Data relating to financial transactions (payments made);
Information released via the “contact” form (name, surname, e-mail, country, subject, comments, telephone, province, order number);
Information provided through the “Work with us” section should the relevant form be present (name, surname, date of birth, gender, place of residence, e-mail,
education, curriculum file, telephone, current employment and level of experience, LinkedIn profile, comment/cover letter);
Information provided for marketing and/or profiling purposes (e-mail, gender, country, name, surname, state/province, town, mobile phone, date of birth, purchase data).
Technical navigation cookies
Data collected automatically during navigation, necessary for the operation of the website:
IP addresses or domain names of the computers used by users who connect to the website, URI addresses of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successfully completed, error, etc.), other parameters concerning the operating system and the user’s computer environment.
These data are only used to obtain anonymous statistics concerning website usage and to check its correct functioning and are deleted immediately after their processing.
The data could be used to ascertain responsibility in case of hypothetical computer crimes against the website or in order to protect our rights.
Data obtained through cookies
With your explicit and prior consent we automatically record your personal data through cookies and/or similar, for statistical, marketing and profiling purposes.
Should you register to the website through “Facebook” or “Google Login”, some data will automatically be collected by the Company and you will only need to complete the form with the missing data.
Purpose & Legal basis
We legitimately process your data for the following purposes:
Management of contractual relationships and supply of products requested through the Store Online, the legal basis is the fulfilment of a contract or of pre-and post-contractual measures taken on the basis of your requests
We process your data to fulfil your requests and to provide you with the requested products and/or services. To purchase products sold in the Store, mandatory registration to the Company’s website is not required.
However, in order to manage purchase orders, finalise the transaction and deliver the requested product, the Company will necessarily process some of your personal contact, identification and tax data, as well as data related to the financial transactions.
These data will also be used to enable us to provide you with any after-sales assistance (changes, returns, refunds, etc.).
Browsing and registering on the “Store Online”, the legal basis is the legitimate interest in pursuing our business
During their normal operation, computer systems and software procedures used to operate this website acquire some personal data whose transmission is implicit when using Internet communication protocols.
The Company processes this data to ensure that the Website is up-to-date, to offer you a service that meets your needs and a user-friendly browsing experience.
Furthermore, the Company processes these data for IT security purposes.
Section “Contacts”, the legal basis is the legitimate interest in pursuing our business
You can contact us to request support in navigating our website, for information on collections and promotions in progress and, in general, on our products.
You can contact the Press and Human Resources Office.
information on any returns, refunds, shipments etc…
The data provided in this circumstance will be used to allow us to deal with your specific requests and to perform the related service.
Section “Work with us” (where present), the legal basis is the execution of pre-contractual measures required for the search and selection of personnel based on your requests. If you provide us with special categories of data, the legal basis is consent
You can voluntarily give your personal data to send spontaneous applications or to take part in selections related to open positions at the Company.
If you provide us with special categories of data, we can only process these with your consent and exclusively for the purposes of search and selection of personnel, otherwise we will be forced to delete them.
Subscription to our newsletter, the legal basis is consent
Based on your consent, the Company processes your data to enable you to subscribe to our newsletter and to receive information concerning news and our products.
You can revoke your consent or request the cancellation of your data at any time.
Marketing and / or profiling activities, the legal basis is the prior, free and explicit consent
Based on your consent, the Company will process the data you have provided when making a purchase on the Store Online, registering with the website, subscribing to the newsletter.
The Company processes your personal data to allow registration to the website, through the creation of a personal account also in order to improve the browsing experience on the Store Online (for example, by creating a so-called “wish list” or to keep track of orders and of any returns as well as to keep any potential user basket active). These are data which, based on your consent, the Company also processes with marketing and / or profiling purposes.
You may withdraw your consent at any time without this affecting the lawfulness of the processing based on consent given before its withdrawal.
Processing your data for marketing purposes will allow us to offer you promotions, discounts, benefits and other services, as well as to send you commercial or promotional information and free products. It will also allow us to offer you attendance at exhibitions or events, to conduct market research and to inform you about all the special initiatives dedicated to our customers.
Processing your data for profiling purposes will allow us to analyse your behaviour and your preferences through the detection of the type, frequency and amount of purchases in order to send advertising and/or commercial messages and to customise products and services based on your profile and, for example, to offer you contents in line with your interests/preferences and to develop products and services which are increasingly closer to your needs.
Personal data collected for website security, for the protection of our assets and our rights, the legal basis is the legitimate interest for reasons of computer security, the protection of assets and rights
The Company processes your personal data collected through technical navigation cookies for reasons of computer security, the protection of assets, the protection of its rights.
Personal data processed to fulfil a legal obligation, regulations or community legislation, the legal basis is the fulfilment of a legal obligation which the Company must abide by
The Company processes your personal data (name, surname, postal address, e-mail address, mobile phone number, tax code, gender, place and date of birth, data related to financial transactions) to fulfil tax, accounting and administrative obligations (including anti-money laundering legislation) and to make a legal claim or to provide a defence against one.
Protection of minors
Data of minors
The Company does not intentionally collect or store data of minors and although the website is aimed at a general public, we are committed to taking measures to protect your data, particularly if you are a minor.
If you are under 18, we ask you not to subscribe to the newsletter, not to register on the website and to make no financial transaction. Therefore, if you wish to buy anything, the online purchase must be made by your parents or your guardian and in any case by an adult. If despite our efforts we realise that the data provided refer to a minor we will delete these.
Legitimate interests of the Company
We treat your data for our legitimate interest in:
– pursuing our business;
– for direct marketing activities;
– to protect our assets and our rights;
– for the safety of the website and for ascertaining responsibility in case of hypothetical computer crimes against the website or to protect our rights.
Possible recipients or categories of recipients of personal data. Dissemination.
Data recipients and dissemination
Your data will be transmitted to third parties to whom the Company entrusts or could entrust some activities (or part of these) to pursue the purposes indicated above. In this case, these subjects will act as independent Data Controllers or will be designated as Data Processors.
The Company will issue appropriate operational instructions to the Processors, where appointed, with particular reference to the adoption of technical and organisational security measures, in order to guarantee the confidentiality and security of the data. The third parties mentioned above are essentially included in the following categories:
a) Companies, consultants and professionals for tax, accounting and administrative consultancy;
b) Financial administration and any Authorities authorised in accordance with the procedures and methods required by law;
c) Credit and digital payment institutions, banks/post offices;
d) Law firms for the protection of contractual and property rights and the defence of our rights;
e) Companies, consultants and IT service providers;
f) Communication agencies;
g) Law enforcement or public security institutions, judicial authorities in the context of a legal or administrative procedure, or in order to fulfil a legal obligation or to protect our rights, including in court.
h) Group companies.
Your data will be processed by personnel inside our Company, within the limits of the respective authorisations, in accordance with the obligations of confidentiality and with the specific purposes indicated above.
The complete list of data processors is available at our company and to obtain information on this matter, you can contact us at the addresses indicated.
Your data will not be disclosed to the general public.
Data retention location & transfer to countries outside the EU
The data collected are processed at the Data Controller’s headquarters.
Some processes (or parts of these) may be carried out at the offices of designated Processors, always within the European Union.
Your data will not be transferred to a country outside the European Union.
The website is hosted by the platform of Magento Adivision of x.commerce Inc. 10451 Jefferson BLVD., Suite 200 – 90232 Culver City, California, which collects, as data controller, some of your personal data such as browsing data and cookies in order to offer the web browsing service on the Company’s website.
The processing takes place outside the EU towards a country adhering to the Privacy Shield.
For services obtained through cookies and/or similar, we will select suppliers by checking the adequacy of the transfer each time, in order to guarantee the same European data protection standards in the case of non-EU transfers.
Your data will be kept for the period strictly necessary in relation to the purposes of the processing indicated above and in any case for the maximum period allowed by applicable law.
Data collected for tax, accounting and administrative purposes will be retained for a period of 10 fiscal years at the end of which they will be deleted or destroyed or made anonymous.
Data collected for fulfilling a contract and/or in order to perform pre and post contractual measures will be kept for the period necessary to exercise our right of defence in case of legal disputes, up to a maximum of 10 years (tax) from the conclusion of the provision of the service and/or supply of the product, on the basis of the ordinary limitation period prescribed by the Italian Civil Code.
Data provided in the “contact” section are kept for the time strictly necessary to execute your requests, at the end of which they will be deleted.
Data communicated in the “Work with us” section (where present) are kept for 24 months after their provision and then they will be cancelled.
Data processed for sending our newsletter are kept for a period of 24 months from their receipt/update.
Website registration data are kept until you request us to close the account or until consent is withdrawn.
Personal data relating to the details of purchases, for which you have given consent to processing for profiling and marketing purposes, are stored for a period of 12 and 24 months respectively from their receipt.
Upon expiry of this period, your data will be permanently deleted or made anonymous.
Data Subject’s rights
Data Subject’s rights.
You may at any time request:
– access to your personal data, for example to know the purposes and categories of the processed data, who they are transmitted to and if they are transferred to a third country, how long they are stored for and all that is provided for by art. 15 of EU Regulation 2016/679;
– their rectification in case of inaccuracy, according to art. 16 of EU Regulation 2016/679;
– their erasure should the reasons provided for by art. 17 of EU Regulation 2016/679 occur; for example, should they no longer be necessary for the purposes of the processing or should it be considered illegal;
– restriction of their processing in the cases provided for by art. 18 of EU Regulation 2016/679.
We will notify your requests to each recipient to whom your personal data have been communicated, unless this proves impossible or involves a disproportionate effort.
You will also have the right:
– to the portability of data in the cases provided for by art. 20 of EU Regulation 2016/679, obtaining said data in a structured format, commonly used and readable by automatic device;
– to object to the processing of your data for the Company’s pursuit of a legitimate interest, for purposes of direct marketing, including profiling in so far as it is related to such direct marketing, as required by art. 21 of EU Regulation 2016/679.
For any request concerning the processing of your data and in order to exercise your rights you can write to: firstname.lastname@example.org
We will process your request with the utmost commitment towards ensuring the effective exercise of your rights, providing you with the appropriate confirmation without unjustified delay and, in any case, within one month of receiving your request, unless the extension of a further month should be required, and in that case we will keep you informed.
Right of withdrawal
Right of withdrawal
You have the right to withdraw your consent to the processing of data for marketing and/or profiling purposes at any time, both in the case of your direct provision and in the case of automatic collection through cookies, without this affecting the lawfulness of the processing based on consent given before its withdrawal.
To make it easier for you to exercise this right, every marketing communication contains a link which will allow you to withdraw the consent given.
You have the right to lodge a complaint with the Authority for the protection of personal data, following the procedures and instructions published on the Authority’s official website.
Communication of personal data and consequences of failing to communicate data
The communication of your personal data is a legal or contractual obligation or a necessary requirement for fulfilling the contract for the following purposes:
– fiscal, accounting, administrative obligations;
– performance of a contract, an order, pre and post sales services. Failure to notify such data will make it impossible to fulfil the contract and/or sale and to provide you with all the services you request.
The submission of the date of birth (where required) will allow us to protect the rights of minors to whom the Company, in compliance with the fundamental principles of the GDPR, reserves a specific protection.
Failure to submit this, will not allow us to offer such protection and will not allow registration.
The submission of your data in an automated way through technical cookies is necessary in order to allow you to view the contents of our website.
Disabling these cookies will not allow us to offer you a suitable transmission for the best use of the service.
Failure to provide the data necessary to complete the “Contact” section will make it impossible to answer your requests.
Failure to submit the data necessary for completing the “Work with us” section (where present) will make it impossible to carry out the activities necessary for selecting personnel and, in general, for adopting pre-contractual measures taken at your request.
Failure to submit the data necessary for registration on the Store Online and necessary to register for the newsletter implies, respectively, the impossibility to use additional services or to receive commercial communications.
In any case, purchases as a simple “guest” are allowed.
Failure to consent to the processing of data for marketing purposes will not allow us to offer you promotions, discounts, benefits and other services, nor to send commercial or promotional information.
Failure to give your consent to the processing of data for profiling purposes will not allow us to offer contents in line with your interests/preferences and to develop products and services which are closer to your needs.
Failure to give your consent to the processing of data for marketing and/or profiling purposes does not affect the possibility of making purchases, to use the requested services (shipments) and/or post-sales assistance (changes, returns, refunds, etc.)
Processing method & automated decision-making process
Processing methods and automated decision making
Your data will be processed with the aid of electronic, paper and computer tools; this processing will be based on the principles of correctness, lawfulness and transparency and of protection of your rights and your privacy.
Data collected automatically through our websites are processed anonymously and in aggregate form.
The processing of data which you have voluntarily submitted, including for profiling purposes, may also be carried out using automated processes, for example through comparison and comparative analysis of your purchase choices (types, quantities), during a given period and/or season and by analysing the type and number of any requests for product information made during a predetermined time frame.
We ask you to cooperate with us in order to offer you the best possible protection. Please ensure you periodically update your antivirus system, verify that your Internet service provider has adopted security measures such as firewalls, spam filters, and keep your credentials (e-mail and password) confidential and change the password periodically.
In the unlikely event of the violation of personal data, in our possession or under our control, we will act according to legislative provisions and if necessary, we will keep you informed.
We do not use automated decision-making procedures which produce legal effects or which may significantly affect you.
Changes & Updates
Changes and updates
We do not use your data for purposes other than or different from those stated.
Changes to this policy will only affect communication methods that make it easier to understand and access information or to exercise your rights. Therefore, we ask you to periodically check for any updates.
Any modification of the purposes will be communicated to you and we will request your prior consent should this be necessary.
Last update: February 2019