top of page

 

Information on the processing of personal data on GILMAR.IT

Gilmar Divisione Industria S.p.A. (hereinafter referred to as “Gilmar”) respects your privacy and is committed to processing your personal data with the utmost care and in full compliance with the relevant provisions governing the protection of personal data, including Regulation (EU) 2016/679 (General Data Protection Regulation or “GDPR”) and Italian legislative decree no. 196/2003, also updated pursuant to Italian legislative decree no. 101/2018.

This Privacy Policy therefore aims to inform, with the utmost transparency, the users of the website www.gilmar.it (hereinafter referred to as the “Website”) on the personal data processing activities carried out by the company on the website.

This Privacy Policy does not apply to other websites, web pages or online services accessible from the Website.

For us, it is important to provide clear and complete information on how we collect, use and store the personal data obtained through your interaction with the Website. For this reason, we encourage you to carefully read this Privacy Policy before sending Gilmar any information and/or personal data of any type.

Personal data refers to any information that makes it possible to identify a person, including indirectly (e.g. by combining said data with other information). By way of example, your email address, first and last name, phone number, mailing address, profession, etc. are considered to be personal data.

THE DATA CONTROLLER

The Data Controller for the processing of personal data that you may provide to us is Gilmar Divisione Industria S.p.A., with registered office in San Giovanni in Marignano (RN), Italy, Via Malpasso no. 723-725, reachable by phone or email at:

Tel: +39 0541 959111

Email address: privacy@gilmar.it

THE DATA PROTECTION OFFICER

Pursuant to art. 37 of the Regulation (EU) 2016/679, Gilmar Divisione Industria S.p.A. has voluntarily appointed a Data Protection Officer (“DPO”), reachable at Gilmar Divisione Industria S.p.A., Via Malpasso n.o 723-725, 47842 San Giovanni in Marignano (RN), Italy, or by email atdpo@gilmar.it.

TYPES OF PERSONAL DATA PROCESSED

When browsing our Website or interacting with the features offered therein, Gilmar processes the following types of personal data:

  1. browsing data which, although constituting information that is not collected in order to be associated with identified users, could, by its very nature, make it possible to identify the site users if processed and associated with data held by third parties. This category of data includes data collected automatically while browsing the Website and necessary for the functioning of the same, such as IP addresses, domain names of computers used to connect to the Website, addresses in URI (Uniform Resource Identifier) notation of requested resources, the time the request is made, the method used to submit the request to the server, the file size obtained in response, the numerical code indicating the response status from the server (successful, error, etc.) and other parameters related to the user’s operating system and computer environment;

  2. data that you provide to Gilmar when you fill out the “Contact Us” form available on the Website, such as your first and last name, email address, the country where you are located, the information you wish to provide by filling out the “Comments” field found on the same form and your telephone number, if necessary;

  3. data that you provide to Gilmar when you fill out the “Work with us” form available on the Website, such as your first and last name, date of birth, gender, address, email address, the data contained in your CV, your professional training and, if you decide to also fill out the additional fields included on the form, your telephone number, your current job, your level of experience, the information contained in your LinkedIn profile and in your cover letter, and the information that you provide by filling out the “Comments” field found on the same form.

PURPOSE AND COMPULSORY OR OPTIONAL NATURE OF THE DATA PROCESSING

Gilmar processes your personal data for the following purposes:

  1. to allow you to browse the Website and for computer security purposes;

  2. to provide a reply to your requests for information, assistance and/or to be contacted, made using the “Contact Us” form available on the Website;

  3. to handle any complaints and/or to fulfil obligations imposed by the law;

  4. for recruitment purposes, also by using the “Work with us” form;

  5. to assert its rights and, more generally, to protect its prerogatives.

The provision of your personal data is not mandatory under any circumstance. However, your refusal to provide the requested data in the fields marked with an asterisk in the “Contact Us” and “Work with us” forms shall make it impossible to complete the procedure for sending your request, with consequent impossibility on the part of Gilmar to provide a reply.

Failure to provide data to be entered in the fields not marked with an asterisk shall not in any way affect the completion of the procedure for sending your request.

LEGAL BASIS OF THE DATA PROCESSING

Gilmar processes your personal data based on the following conditions of legitimacy:

  1. to fulfil your requests for information or to be contacted, to establish a possible contractual relationship with you, including of a business or commercial nature (and therefore as relating to the implementation of pre-contractual measures), pursuant to Article 6, letter b) of the GDPR;

  2. to allow Gilmar to pursue its legitimate interests, consisting of carrying out and promoting the company’s business also through the Website, the protection of its rights and the adoption of computer security systems, pursuant to Article 6, letter f) of the GDPR;

  3. on the basis of the legitimate interest of Gilmar to recruit personnel and to eventually establish a working relationship in case an individual is hired, pursuant to Article 6, letter f) of the GDPR.

Personal data is also processed to ensure compliance with Gilmar’s legal obligations pursuant to Article 6, letter c) of the GDPR, as well as for the possible protection of the company’s rights in court and/or before the competent authorities, pursuant to Article 6, letter f) of the GDPR.

SUBJECTS THAT HAVE ACCESS TO PERSONAL DATA

Gilmar limits access to personal data as much as possible, making such data available to its staff, duly authorised to access and/or process the data in order to carry out their professional duties.

Gilmar’s staff shall process the personal data within the limits and in compliance with the provisions entrusted to it by the same.

Personal data may also be shared with companies affiliated with Gilmar and disclosed to independent subjects through which Gilmar carries out its business activities.

These subjects shall process personal data as Data Processors, according to the instructions provided by Gilmar, or as independent Data Controllers.

Gilmar provides to said subjects only the personal data strictly necessary to perform the agreed-upon services.

The suppliers of such services fall into the following categories:

  • companies, consultants and IT service providers;

  • consultants and lawyers that provide assistance to Gilmar in relation to the conduction of its business activity and the necessary measures to protect its rights and to fulfil the requests of judicial and administrative authorities, as well as for other reasons related to the protection of the rights and freedoms of others.

DATA PROCESSING METHOD AND SCOPE OF CIRCULATION OF PERSONAL DATA

Gilmar processes personal data on paper and with the help of electronic and automated means, within the limits of the purposes set out in this Privacy Policy and taking the appropriate measures required to maintain the confidentiality and privacy of such data.

Gilmar pays great attention to the protection and privacy of personal data and consequently does not engage in the dissemination and/or marketing of personal data.

In some cases, your personal data may be transferred outside the European Union. This transfer shall take place ensuring adequate protection levels for your data, in compliance with Articles 45 and 46 of the GDPR.

In particular, personal data shall be transferred outside the European Union to countries that provide an adequate level of data protection, as determined by the specific decisions of the European Commission.

In other cases, transfers of personal data outside the European Union may take place where adequate assurances and safeguards for the protection of your personal data are issued by Gilmar’s suppliers and sub-suppliers receiving such data, for example, by signing the standard contractual clauses for the protection of personal data adopted by the European Commission.

DATA RETENTION PERIOD

Your personal data shall be retained by Gilmar for the limited period of time required to achieve the purposes of each data processing activity specified above. At the end of this period, your personal data shall be deleted or made anonymous.

Personal data used to reply to your requests for information, assistance and/or to be contacted, made using the “Contact Us” form available on the Website, shall be retained by Gilmar for the time strictly necessary to respond to your requests and then deleted.

The personal data communicated by you by submitting the “Work with us” form shall be retained by Gilmar for a period of 24 months from the receipt of said data.

YOUR RIGHTS

You may contact Gilmar at any time, by sending an email to privacy@gilmar.it, requesting to receive the list of Data Processors (i.e. Gilmar’s service providers entrusted to process your personal data according to the instructions and guidelines provided by Gilmar).

Also by sending an email to privacy@gilmar.it, you can request to exercise the rights provided for by the applicable legislation on the protection of personal data (pursuant to the provisions set out in Articles 15 to 22 of the GDPR), and in particular

  1. the right to obtain confirmation of whether your personal data is being processed or otherwise, to have access to your personal data processed by Gilmar, to know the purpose of such processing, the categories of data processed and the recipients or categories of recipients to whom your data have been or will be communicated;

  2. the right to verify the accuracy and correctness of your personal data and its origin, to request the integration, updating, correction, deletion or anonymisation of your personal data, as well as the limitation of the processing of your personal data as well as the limitation of the processing of your data or object to the processing (pursuant to the cases provided for in Articles 17 and 18 of the GDPR);

     

  3.  submita complaint to the Supervisory Authority (the Italian Authority for the Protection of Personal Data or Garante);

  4. the right to oppose the processing of personal data, carried out by Gilmar on the basis of its legitimate interest, for reasons related to a particular situation, provided that no prevailing motives exist to allow Gilmar to continue with the data processing (e.g. the need to protect its rights in court);

  5. the right to be informed of the existence of an automated decision-making process,
    including profiling, as referred to in Article 22, paragraphs 1 and 4 of the
    GDPR and, in such cases, to obtain meaningful information about the logic
    involved, as well as the significance and the expected consequences of such
    processing for the Data Subject;

  6. the ability to exercise the right to portability of your personal data.

Once your request has been received, Gilmar shall process it as quickly as possible and with utmost seriousness, in order to allow you to exercise your rights, providing a reply without delay and, in any case, within one month from receiving the request. In cases of particular complexity, the timeframe for replying to your request may be extended to up to 2 months. In this case, Gilmar shall keep you informed on the status of the fulfilment of your request.

​

(last updated on 19 April 2023)

 

 

General conditions of participation in the promotional activity associated with the GILMAR OUTLET card

Industry Division S.p.A. (hereinafter also just “Gilmar”) has dedicated the GILMAR OUTLET card to its end customers to offer them advantages in purchasing products at sales points managed by Gilmar or by companies controlled by or under common control with Gilmar (hereinafterAlso only the "sales points"), or on the websites (hereinafter also only the "websites") that participate in the initiative, according to the provisions of thethese general conditions.

​

The GILMAR OUTLET card (hereinafter also just the "Card") is issued free of charge to customers who decide to join Gilmar's promotional activity and after completing the form.

​

The Card is issued at the discretion of Gilmar, which reserves the right to modify these general conditions at any time; any changes will be effective following their communication by Gilmar to cardholder customers, for example through publication of the updated general conditions on https://www.gilmar.it/legal/.

​

  1. The Card is attributed by Gilmar to the adult end customer who has filled out the appropriate form (hereinafter also just the "Customer"). The card is nominative, unique, strictly personal, non-transferable and any use by Customers for commercial purposes is prohibited.

  2. The Card is issued upon acceptance by the Customer of these general conditions.

  3. The Customer can return the Card at any time, thereby renouncing the advantages offered by the latter to the Customer. The Card must be returned by sending it, at the Customer's expense, to: Gilmar Difesa Industria S.p.A., c.a. Retail Outlet Office, via Malpasso n. 723/725, 47842 San Giovanni in Marignano (RN), Italy.

  4. The revocation of the Customer's consent to the promotional activity carried out by Gilmar does not entail the forfeiture of the benefits provided by the Card. The Customer therefore always remains free to exercise this right, as more fully illustrated in the information on the processing of personal data.

  5. The Card can be used by the Customer at all points of sale and websites participating in the initiative, upon presentation of the same or insertion of the relevant details and, in any case, upon recognition of the Customer, to benefit from discounts on the products purchased personally. The amount of the discount applied to individual products and the location in which it can be benefited (for example, at points of sale and/or on websites) are variable and may be determined at the discretion of Gilmar.

  6. The Card has an unlimited duration; however, Gilmar reserves the right to suspend or interrupt its effectiveness at any time upon notice to the Customer. At its sole discretion, Gilmar may revoke the Customer's right to use the Card and benefit from the related benefits. Without prejudice to any further initiative for its own protection, Gilmar reserves the right to deactivate the Card in the event that the Customer uses it abusively and/or in any case harmful to Gilmar's image and/or trademarks. Likewise, Gilmar may deactivate the Card for failure to use it for a period exceeding 5 years.

  7. In the event of loss, damage or theft of the Card, the Customer is required to promptly notify Gilmar of the circumstance by sending an email to info@gilmar.it or by calling 0541/959111. Gilmar, after verifying the Customer's identification data, will be able to provide the Customer with a new Card.

​

(last update on 23 June 2025)

​

 

 

Privacy Policy - GILMAR OUTLET card

Gilmar Divisione Industria S.p.A. (hereinafter referred to as “Gilmar”) respects your privacy and is committed to treating your personal data with the utmost care and in full compliance with the relevant provisions governing the protection of personal data, including Regulation (EU) 2016/679 (General Data Protection Regulation or “GDPR”) and Legislative Decree no. 196/2003, also updated pursuant to Legislative Decree no. 101/2018. 196/2003, also updated pursuant to Legislative Decree no. 101/2018.

 

For us, it is important to provide clear and complete information on how we collect, use and store the personal data you provide to us within the context of Gilmar’s promotional activity through the obtainment and use of the GILMAR OUTLET card (hereinafter referred to as “Card”). For this reason, we encourage you to carefully read this Privacy Policy before sending Gilmar any information and/or personal data of any type.

 

Any entry into force of new rules and provisions (also relating to the protection of personal data), the opening of new stores and the ongoing update of the services related to the Card, could require the need to modify this privacy policy. We encourage you to periodically consult the most updated version, which can be found at the address https://www.gilmar.it/en/legal/ .

 

THE DATA CONTROLLER

The Data Controller for the processing of personal data that you may eventually provide to us is Gilmar Divisione Industria S.p.A., with registered office in San Giovanni in Marignano (RN), Italy, in Via Malpasso no. 723-725, reachable by phone or email at:

Tel: +39 0541 959111 Email address: privacy@gilmar.it

 

THE DATA PROTECTION OFFICER

Pursuant to art. 37 of the Regulation, Gilmar Divisione Industria S.p.A. voluntarily appointed a Data Protection Officer (“DPO”) available at Gilmar Divisione Industria S.p.A., 47842 San Giovanni in Marignano (RN), via Malpasso no. 723-725, and at the email address: dpo@gilmar.it.

 

TYPES OF PERSONAL DATA PROCESSED

Within the context of the promotional activity associated with the Card, Gilmar processes identification and contact data, which, subject to your consent, can be processed for marketing purposes. Subject to your consent, Gilmar may also process data relating to your purchasing habits (for example, type of products purchased, amounts spent and purchasing date).

 

PURPOSE AND COMPULSORY OR OPTIONAL NATURE OF THE DATA PROCESSING

Gilmar processes your personal data for the following purposes:

 

  1. Gilmar processes your data: 

    • to allow you to use the discounts connected with the Card;

    • subject to your consent, to carry out the promotional activity associated with the Card. Your personal data will be processed for marketing purposes, e.g., to send you our newsletter, commercial or promotional information, free products, invitations to events, to offer promotions, discounts, benefits or other services.

    • The provision of your personal data for this purpose is not mandatory, but refusal to provide them will make it impossible for Gilmar to deliver you the Card and make you benefit from the discounts reserved to holders of the same.

  2. Subject to your consent, Gilmar uses your data to carry out profiling activities including carrying out an analysis of your purchases (identifying the type, frequency and amounts spent) in order to send you commercial and promotional offers in line with your specific interests and your purchasing habits, developing products and services closer to your personal needs.

    • The provision of personal data which Gilmar may use for marketing and profiling purposes is entirely optional. However, if you do not provide such data, it shall be impossible for Gilmar to carry out.

    • marketing and profiling activities and therefore to send you communications of a commercial nature, discounts and promotions, including those associated with the Card, as described above.

 

LEGAL BASIS OF THE DATA PROCESSING

Gilmar processes your personal data based on the following conditions of legitimacy

  1. to perform its contractual obligations to you following the acceptance of the “General conditions to apply to the promotional activity associated with the GILMAR OUTLET card”, pursuant to Article 6, letter b) of the GDPR;

  2. your consent to the processing of your personal data for marketing and/or profiling purposes, pursuant to Article 6, letter a) of the GDPR;

  3. in respect of the obligations of law by Gilmar, pursuant to Article 6, letter c) of the GDPR;

  4. for the possible protection of its rights and prerogatives (among which, ensuring compliance with the “General conditions to apply to the promotional activity associated with the GILMAR OUTLET card” and guarantee an orderly management of the promotional activity associated with the GILMAR OUTLET card, pursuant to Article 6, letter f) of the GDPR.

 

SUBJECTS WHO HAVE ACCESS TO YOUR PERSONAL DATA

Gilmar limits access to personal data as much as possible, making such data available to its staff, duly authorised to access the data in order to carry out their professional duties.

Gilmar’s staff shall process the personal data within the limits and in compliance with the provisions entrusted to it by the same.

 

Your personal data may also be shared with companies affiliated to Gilmar or subject to joint control by Gilmar (for example, who manage specific stores) and disclosed to independent subjects on which the latter relies to carry out its normal business activities.

 

These subjects shall process your personal data in a capacity of Data Processors, according to the instructions provided by Gilmar, as well as in a capacity of Data Controllers.

Gilmar provides to said subjects only the data strictly necessary to perform the agreed-upon services.

 

The suppliers of such services fall into the following categories:

  • companies, consultants and IT service providers;

  • consultants and legal representatives who assist Gilmar in carrying out its business activities, in initiatives necessary to protect its rights, to fulfil requests of the Judicial and administrative Authority, as well as for other reasons connected to the protection of rights and freedom of others.

 

DATA PROCESSING METHOD AND SCOPE OF CIRCULATION OF PERSONAL DATA

Gilmar processes personal data on paper and with the help of electronic and automated means, within the limits of the purposes set out in this Privacy Policy and taking the appropriate measures to maintain the confidentiality and privacy of said data.

 

With specific reference to marketing purposes, Gilmar processes personal data by sending newsletters via email and possibly by sending invitations to initiatives with exclusive access via post and/or with calls from operators, as well as via SMS and/or via chat.

 

Gilmar pays great attention to the protection and privacy of personal data and consequently does not engage in the dissemination and/or marketing of personal data. Gilmar also processes the data in full compliance with the principles of confidentiality, correctness, necessity, relevance, lawfulness and transparency imposed by the GDPR.

 

In some cases, your personal data may be collected and processed outside the European Union, for example if a specific store is located in a third country. In such case, your personal data will be processed ensuring an adequate level of protection as set out by the European Commission’s decisions, pursuant to art. 45 of the GDPR, or through the adoption of data protection clauses, as per art. 46 of the GDPR.

 

DATA RETENTION PERIOD

Your personal data shall be retained by Gilmar for a limited period of time, necessary to achieve the purposes identified above. At the end of this period, your data shall be deleted or made anonymous.

 

The personal data processed in order to fulfil contractual commitments resulting from your acceptance of the “General conditions to apply to the promotional activity associated with the GILMAR OUTLET card” shall be retained by Gilmar for a period of 5 years from the last purchase made using the Card, or, in the case that the Card has never been used, from its issue date.

 

Within 24 months from the time data has been collected for delivery of our newsletter and fulfilment of marketing activities, Gilmar shall attempt to obtain a new consent to pursue these activities, in the absence of which the data in question shall be deleted.

 

Personal data used for profiling purposes shall be deleted or made anonymous by Gilmar within 12 months from its receipt. After 12 months, Gilmar may continue to process your data only if you provide a new consent to the processing of your data for profiling purposes.

 

WITHDRAWAL OF CONSENT

You may, at any time, object to the processing of your personal data by Gilmar for marketing purposes (such as sending newsletters), for the fulfilment of any profiling activities and for carrying out profiling activities, including sending promotional messages, invitations to events, discounts and free products.

You may revoke your consent to such data processing activities by sending an email to privacy@gilmar.it, or by following the instructions provided at the bottom of the newsletter or of promotional communications received from Gilmar.

 

Once your request has been received, we will make sure to immediately stop the processing of your personal data based on the consent that you have revoked. Data processing based on different conditions of legitimacy from the consent revoked, shall continue to be conducted as provided for in this Privacy Policy and in full compliance with applicable regulations.

 

The withdrawal of consent to the processing of your personal data for marketing and/or profiling purposes shall not affect the legitimacy of data processing carried out by Gilmar based on consent given before such withdrawal.

 

YOUR RIGHTS

You may contact Gilmar at any time, by sending an email to privacy@gilmar.it, requesting to receive the list of Data Processors (i.e. Gilmar's service providers entrusted to process your personal data on the basis of the instructions and guidelines provided by Gilmar).

Also by sending an email to privacy@gilmar.it you can request to exercise the rights provided for by the applicable legislation on the protection of confidentiality of personal data (pursuant to the provisions set out in Articles 15 to 22 of the GDPR), and in particular:

  1.  the right to obtain confirmation of whether your personal data is being processed or otherwise, to have access to your personal data processed by Gilmar, to know the purpose of such processing, the categories of data processed and the recipients or categories of recipients to whom your data have been or will be communicated.

  2. the right to verify the accuracy and correctness of your personal data and its origin, to request the integration, updating, correction, deletion or anonymisation of your personal data, as well as the limitation of the processing of your data or object to the processing (pursuant to the cases provided for in Articles 17 and 18 of the GDPR);

  3. submit a complaint to the Supervisory Authority (the Italian Authority for the Protection of Personal Data or Garante);

  4. the right to oppose the processing of personal data, carried out by Gilmar on the basis of its legitimate interest, for reasons related to a particular situation, provided that no prevailing motives exist to allow Gilmar to continue with the data processing (e.g. the need to protect its rights in court);

  5. the right to be informed of the existence of an automated decision-making process, including profiling, as referred to in Article 22, paragraphs 1 and 4 of the GDPR and, in such cases, to obtain meaningful information about the logic involved, as well as the significance and the expected consequences of such processing for the Data Subject;

  6. the ability to exercise the right to portability of your personal data.

 

Once your request has been received, Gilmar shall process it as quickly as possible and with utmost seriousness, in order to allow you to exercise your rights, providing a reply without delay and, in any case, within one month from receiving the request. In cases of particular complexity, the timeframe for replying to your request may be extended to up to 2 months from receiving the request. In this case, Gilmar shall keep you informed on the status of the fulfilment of your request.

​

 

(last updated on 16 December 2024)

Privacy Policy for economic operators and consultants working with Gilmar Divisione Industria S.p.a.

Gilmar Divisione Industria S.p.A. (hereinafter referred to as “Gilmar”) respects your privacy and is committed to processing your personal data with the utmost care and in full compliance with the relevant provisions governing the protection of personal data, including Regulation (EU) 2016/679 (General Data Protection Regulation or “GDPR”) and Italian legislative decree no. 196/2003, also updated pursuant to Italian legislative decree no. 101/2018.

This Privacy Policy therefore aims to inform, with the utmost transparency, the economic operators and consultants as well as their staff that work with Gilmar on the personal data processing activities carried out by Gilmar during its business activities and within the scope of its business relations.

For us, it is important to provide clear and complete information on how we collect, use and store the personal data obtained while conducting our business and within the scope of our business relations. For this reason, we encourage you to carefully read this Privacy Policy before sending Gilmar any information and/or personal data of any type.

Personal data refers to any information that makes it possible to identify a person, including indirectly (e.g. by combining said data with other information). By way of example, your email address, first and last name, phone number, mailing address, profession, etc. are considered to be personal data.

THE DATA CONTROLLER

The Data Controller for the processing of personal data that you may provide to us is Gilmar Divisione Industria S.p.A., with registered office in San Giovanni in Marignano (RN), Italy, Via Malpasso no. 723-725, reachable by phone or email at:

Tel: +39 0541 959111

Email address: privacy@gilmar.it

THE DATA PROTECTION OFFICER

Pursuant to art. 37 of the Regulation (EU) 2016/679, Gilmar Divisione Industria S.p.A. has voluntarily appointed a Data Protection Officer (“DPO”), reachable at Gilmar Divisione Industria S.p.A., Via Malpasso n.o 723-725, 47842 San Giovanni in Marignano (RN), Italy, or by email atdpo@gilmar.it.

TYPES OF PERSONAL DATA PROCESSED

In conducting its business and within the scope of its business relations, Gilmar also processes the personal identification and/or contact data related to individuals who refer to economic operators and/or consultants, as well as identification data referred to individual firms.

PURPOSE AND COMPULSORY OR OPTIONAL NATURE OF THE DATA PROCESSING

Gilmar processes your personal data for the following purposes:

  1. to provide a reply to your requests for information and/or to be contacted as well as, more generally, to verify the possibility of establishing a contractual relationship with you and/or with the firm to which you refer;

  2. to enforce contracts related to the conduction of the business activity and, more generally, to manage relations with economic operators and/or consultants, also in relation to requests for assistance;

  3. to handle any complaints and/or to fulfil obligations imposed by the law, including those related to accounting and fiscal matters;

  4. to assert its rights and, more generally, to protect its prerogatives.

The provision of your data is not mandatory under any circumstance. However, your refusal to provide it may have different consequences.

For example, your refusal to provide the personal data requested by Gilmar within the scope of pre-contractual activities and/or to formalise contracts, including just potential contracts, with economic operators and/or consultants might make it impossible for Gilmar to provide the service requested and hence the possibility to conclude any contracts.

In other cases, your refusal to provide the personal data requested by Gilmar might make it impossible for Gilmar to reply to requests for information and/or to be contacted as well as to timely enforce contracts with economic operators and/or consultants also in relation to requests for assistance.

LEGAL BASIS OF THE DATA PROCESSING

Gilmar processes your personal data based on the following conditions of legitimacy:

  1. to allow Gilmar to pursue its legitimate interests, consisting of carrying out and promoting the company’s business, also through the implementation of pre-contractual measures, as well as protecting its rights, pursuant to Article 6, letter f) of the GDPR;

  2. to enforce contracts required for the conduction of its business activity, pursuant to Article 6, letter b) of the GDPR;

  3. to ensure compliance with Gilmar’s legal obligations, pursuant to Article 6, letter c) of the GDPR;

  4. to protect Gilmar’s rights in court and/or before the competent authorities, pursuant to Article 6, letter f) of the GDPR.

SUBJECTS THAT HAVE ACCESS TO PERSONAL DATA

Gilmar limits access to personal data as much as possible, making such data available to its staff, duly authorised to access and/or process the data in order to carry out their professional duties.

Gilmar’s staff shall process the personal data within the limits and in compliance with the provisions entrusted to it by the same.

Personal data may also be shared with companies affiliated with Gilmar and disclosed to independent subjects through which Gilmar carries out its business activities.

These subjects shall process personal data as Data Processors, according to the instructions provided by Gilmar, or as independent Data Controllers.

Gilmar provides to said subjects only the personal data strictly necessary to perform the agreed-upon services.

The suppliers of such services fall into the following categories:

  • companies, consultants and IT service providers;

  • consultants and lawyers that provide assistance to Gilmar in relation to the conduction of its business activity and the necessary measures to protect its rights and to fulfil the requests of judicial and administrative authorities, as well as for other reasons related to the protection of the rights and freedoms of others.

DATA PROCESSING METHOD AND SCOPE OF CIRCULATION OF PERSONAL DATA

Gilmar processes personal data on paper and with the help of electronic and automated means, within the limits of the purposes set out in this Privacy Policy and taking the appropriate measures required to maintain the confidentiality and privacy of such data.

Gilmar pays great attention to the protection and privacy of personal data and consequently does not engage in the dissemination and/or marketing of personal data.

In some cases, your personal data may be transferred outside the European Union. This transfer shall take place ensuring adequate protection levels for your data, in compliance with Articles 45 and 46 of the GDPR.

In particular, personal data shall be transferred outside the European Union to countries that provide an adequate level of data protection, as determined by the specific decisions of the European Commission.

In other cases, transfers of personal data outside the European Union may take place where adequate assurances and safeguards for the protection of your personal data are issued by Gilmar’s suppliers and sub-suppliers receiving such data, for example, by signing the standard contractual clauses for the protection of personal data adopted by the European Commission.

DATA RETENTION PERIOD

Your personal data shall be retained by Gilmar for the limited period of time required to achieve the purposes of each data processing activity specified above. At the end of this period, your personal data shall be deleted or made anonymous.

Personal data processed in order to fulfil the commitments provided for by contracts, including pre-contractual activities, shall be retained by Gilmar for a period of 10 years from the execution of the contractually provided service.

Personal data processed as part of the management and keeping of company accounts and for billing purposes shall be retained by Gilmar for the time necessary to fulfil the company’s tax and record keeping obligations, and no later than 10 fiscal years from the invoicing date.

YOUR RIGHTS

You may contact Gilmar at any time, by sending an email to privacy@gilmar.it, requesting to receive the list of Data Processors (i.e. Gilmar’s service providers entrusted to process your personal data according to the instructions and guidelines provided by Gilmar).

Also by sending an email to privacy@gilmar.it, you can request to exercise the rights provided for by the applicable legislation on the protection of personal data (pursuant to the provisions set out in Articles 15 to 22 of the GDPR), and in particular:

  1. the right to obtain confirmation as to whether or not your personal data is being processed, to have access to your personal data processed by Gilmar, to know the purpose of such processing, the categories of personal data processed and the recipients or categories of recipients to whom your personal data have been or will be communicated or disclosed. You are also entitled to know the retention period of your personal data or, where this is not possible, the criteria used to determine this period;

  2. the right to verify the accuracy and correctness of your personal data and its origin, to request the integration, updating, correction, deletion or anonymisation of your personal data, as well as the limitation of the processing of your personal data;

  3. the right to oppose the processing of your personal data;

  4. the right to lodge a complaint with the Supervisory Authority (the Italian data protection supervisor is called “Garante per la protezione dei dati personali”);

  5. in case of transfer of your data to a third country, the right to be informed of the existence of adequate safeguards relating to such transfer, pursuant to Article 46 of the GDPR;

  6. the right to oppose the processing of your personal data, carried out by Gilmar on the basis of its legitimate interest, for reasons related to a particular situation, provided that no prevailing motives exist to allow Gilmar to continue with the data processing (e.g. the need to protect its rights in court);

  7. the right to be informed of the existence of an automated decision-making process, including profiling, as referred to in Article 22, paragraphs 1 and 4 of the GDPR and, in such cases, to obtain meaningful information about the logic involved, as well as the significance and the expected consequences of such processing for the data subject;

  8. the right to exercise the right to portability of your personal data.

Once your request has been received, Gilmar shall process it as quickly as possible and with utmost seriousness, in order to allow you to exercise your rights, providing a reply without delay and, in any case, within one month from receiving the request. In cases of particular complexity, the timeframe for replying to your request may be extended to up to 2 months. In this case, Gilmar shall keep you informed on the status of the fulfilment of your request.

​

(last updated on 7 October 2020)

Notice on the processing of personal data for video surveillance

Gilmar Divisione Industria S.p.A. (hereinafter referred to as “Gilmar”) respects privacy and undertakes to process personal data with utmost care, in compliance with the relevant applicable regulations, including the Regulation (EU) 2016/679.

This notice thus aims at informing you with utmost transparency about the processing of personal data carried out by Gilmar through the video surveillance system installed at its premises, boutiques and outlets.

For further information about the processing of your personal data as well as to exercise your rights as better explained below, you can send an e-mail to privacy@gilmar.it.

DATA CONTROLLER

The data controller of personal data is Gilmar Divisione Industria S.p.A., with registered office in Italy, in San Giovanni in Marignano (RN), Via Malpasso no. 723-725.

DATA PROTECTION OFFICER

Pursuant to art. 37 of the Regulation (EU) 2016/679, Gilmar Divisione Industria S.p.A. has voluntarily designated a Data Protection Officer (“DPO”), which can be contacted at Gilmar Divisione Industria S.p.A., Via Malpasso no. 723-725, 47842 San Giovanni in Marignano (RN), Italy, or by sending an e-mail to dpo@gilmar.it.

PURPOSES OF THE PROCESSING

The personal data acquired through the video surveillance system shall be processed:

  • to ensure the safety and protection of people (Gilmar’s employees, collaborators and customers, and third parties in general) and Gilmar’s assets against possible attacks, thefts, robberies, damage, acts of vandalism and other illegal activities;

  • to help organize Gilmar’s production processes, in compliance with the principle of proportionality between means of processing being used and aims pursued;

  • indirectly, also for purposes connected with the employment relationship, as also specified in the relevant agreements with the bargaining units.

LEGAL BASIS

The personal data acquired through the video surveillance system shall be processed on the basis of the legitimate interest of Gilmar:

  • to protect the safety of people and its assets at its premises, boutiques and outlets;

  • to ensure the adequate exploitation of its resources, also with the aim of helping its personnel carry out their tasks.

The personal data acquired through the video surveillance system may also be processed to fulfil Gilmar’s legal obligations, for example if the images acquired are requested by the judicial authorities to prosecute any offences or to conduct any investigations.

DATA PROCESSING METHODS AND STORAGE PERIOD

In relation to the above purposes, personal data shall be processed using computer systems, taking adequate precautions and safety measures at the technical and organizational level according to the provisions of applicable regulations.

The images acquired shall be saved on a digital support and stored for no longer than it is necessary for the achievement of the above purposes and in any case for no longer than 72 hours from the moment they are taken.

DISCLOSURE AND DISSEMINATION

Gilmar shall limit access to the images acquired by the video surveillance system, making them available only to its duly authorized personnel within the limits of their specific task.

The images acquired by the video surveillance system may be made available to the judicial authorities in order to identify any offences and relevant details (also to identify the relevant perpetrators).

For the achievement of the above purposes, the images may be made accessible to external subjects responsible for the management and maintenance of the video surveillance system.

Gilmar shall be also allowed to make the images available to its lawyers in order to protect its rights and interests and to fulfil any requests of the judicial authorities.

Any subjects external to Gilmar that shall have access to the images acquired by the video surveillance system may process personal data both as data processors according to the instructions received from Gilmar and as independent data controllers.

RIGHTS OF THE DATA SUBJECT

To exercise your rights provided for by the regulations on the protection of personal data, including the ones listed below, you can contact Gilmar at any time, by sending an e-mail to privacy@gilmar.it:

  1. the right to obtain access to your personal data and confirmation as to whether or not your personal data are being processed as well as the right to know the purposes of the processing, the categories of personal data being processed, and the recipients and storage period of your personal data;

  2. the right to request the erasure of your personal data within the limits provided for by applicable regulations;

  3. the right to object to the processing of your personal data within the limits provided for by applicable regulations.

To exercise the above rights, you shall provide Gilmar with suitable information to demonstrate your identity as well as specify, even just indicatively, when and where you deem to have been filmed by the video surveillance system. Gilmar shall reserve the right, if necessary, to ask you for further explanations in order to identify the images about which you are requesting to exercise your rights.

In addition to the above rights, you shall also have the right to lodge a complaint with a supervisory authority (the competent authority in Italy is the Garante per la protezione dei dati personali (Italian Data Protection Supervisor)).

​

(last update on 17 July 2020)

​

Summary of the procedure for WHISTLEBLOWING Reports

Through this portal (hereinafter the "Portal"), it is possible to submit reports of information on violations, including well-founded suspicions, of national and European Union regulations that harm the public interest or the integrity of Gilmar Divisione Industria S.p.A. (hereinafter "Gilmar") committed in the course of its activities, learned by the whistleblower in the work context (as more fully illustrated below), in accordance with the provisions of Legislative Decree 24 of March 10, 2023 (hereinafter the "Whistleblowing Decree"), issued in implementation of Directive (EU) 2019/1937.

Such information may also concern violations not yet committed that the whistleblower reasonably believes may be committed based on concrete elements. These elements may also be irregularities and anomalies (symptomatic indices) that the whistleblower believes may give rise to one of the violations provided for by the Whistleblowing Decree.

For more information regarding the reports that can be submitted through the Portal, please refer to paragraph 2 below and the full version of the "whistleblowing reporting procedure" of Gilmar Divisione Industria S.p.A.

​

1. Who can submit a report

Authorized to submit a report are individuals who operate in the work context of Gilmar, including in particular (both during the legal relationship with Gilmar and before or after the establishment of such relationship):

employees and self-employed workers;
freelancers and consultants;
workers and collaborators who carry out their activities at Gilmar and/or who supply or purchase goods or services at Gilmar;
volunteers;
interns;
shareholders, and persons with management, administration, control, supervision, and representation functions at Gilmar.


2. What can be reported

Violations, even if only presumed, that involve behaviors, acts, or omissions that harm the public interest or the integrity of Gilmar can be reported, consisting of:

administrative, accounting, and criminal offenses;
conduct relevant under Legislative Decree 231/2001;
violations of Gilmar's Code of Ethics;
offenses that fall within the scope of European Union acts indicated in the Whistleblowing Decree or national acts that implement the European Union acts indicated in Directive (EU) 2019/1937, even if not expressly mentioned in the Whistleblowing Decree, and related to the specific sectors indicated therein;
acts or omissions that harm the financial interests of the European Union, as specified in Article 325 of the Treaty on the Functioning of the European Union and relevant derived European Union law;
acts or omissions concerning the internal market of the European Union.
For more information regarding the violations that can be reported through the Portal, please refer to the "whistleblowing reporting procedure" of Gilmar Divisione Industria S.p.A.

However, the following cannot be reported through this procedure:

disputes, claims, or requests related to a personal interest of the whistleblower, which pertain exclusively to their individual employment relationships, or concerning their employment relationships with hierarchically superior figures;
violations already regulated by European Union acts or national acts indicated in Part II of the annex to the Whistleblowing Decree or national acts that implement the European Union acts referred to in Part II of the annex to Directive (EU) 2019/1937;
violations concerning national security, as well as contracts related to aspects of defense or national security.
 

3. How to submit a report

Reports can be submitted through the internal channel established by Gilmar (https://portal.gilmar.it/whistleblowing), preferably through the Portal or, alternatively, by requesting a meeting with the recipient of the reports, identified by Gilmar as its Human Resources Manager (hereinafter, the "Recipient").

Alternatively, under certain conditions indicated below, it is possible to submit the report through the external reporting channel, i.e., directly to the National Anti-Corruption Authority ("ANAC").

​

a. Internal reporting channels

The Portal allows reports to be submitted in two different ways.

i. Anonymous reports

Unless the whistleblower selects the option to disclose their personal data to the Recipient and thus allows additional data to be entered on the Portal beyond the email address (which must always be indicated by the whistleblower), reports submitted through the Portal will be anonymous. This means that the Recipient will receive the report without being informed of the whistleblower's personal data, including their email address.

As mentioned, when submitting an anonymous report, the email address must be necessarily indicated to allow the Recipient, if necessary, to contact the whistleblower (for example, regarding any clarifications about the content of the report), while ensuring that the email address will not be disclosed to the whistleblower. It is understood that, to ensure the report submitted in this manner is truly anonymous, the whistleblower must avoid including information and/or personal data within their report that reveal their identity. For anonymous reports, the protection measures referred to in paragraph 4 below apply, in cases where the whistleblower has been identified and has suffered retaliation as a result of their report.

ii. Ordinary reports

Only if the whistleblower selects the option to disclose their personal data to the Recipient, then the whistleblower can also fill in the additional fields related to these data, which will be provided to the Recipient, including the email address. The protection measures referred to in paragraph 4 also apply to ordinary (i.e., non-anonymous) reports.

At the end of submitting a report, the whistleblower must note the date and the Unique Identification Code automatically generated by the Portal, which allows them to follow the processing status of the report over time, ensuring confidentiality and privacy.

Upon receipt of the report, the Recipient (the only person with access to each report):

conducts a preliminary analysis of the report and, in cases where it is deemed inadmissible (e.g., due to manifest groundlessness and/or generality of its content), archives the report, providing the whistleblower with written reasons for the archiving;
within seven days of receiving the report, issues an acknowledgment of receipt to the whistleblower;
maintains communications with the whistleblower, possibly requesting additional information from them, and, if necessary, seeks support from internal functions and/or external consultants, requests clarifications from the individuals indicated in the report as responsible for the violation or otherwise implicated in it, conducts appropriate investigations (possibly also appointing an internal or external person to Gilmar);
diligently follows up on the reports received;
provides feedback (even if only interlocutory) to the report no later than three months from the expiration of the seven-day period from the submission of the report;
if a violation is confirmed, may (i) initiate disciplinary proceedings against the individuals indicated in the report as responsible for the violation or otherwise implicated in it; (ii) assess the opportunity to initiate disciplinary proceedings against the whistleblower in the case of reports in which bad faith and/or merely defamatory intent are confirmed, also by the groundlessness of the report itself; (iii) agree on any necessary action plan to address identified control weaknesses, ensuring monitoring of its implementation;
retains the report and related documentation for the time necessary to manage the report, in any case, no longer than five years from the date of communication of the final outcome of the report.
Reports transmitted to persons other than the Recipient and clearly falling within those governed by the "whistleblowing reporting procedure" of Gilmar Divisione Industria S.p.A. will be transmitted immediately, in any case no later than seven days, to the Recipient, notifying the whistleblower and maintaining the utmost confidentiality regarding the whistleblower's identity and the contents of the report.

​

b. External reporting channel

It is possible to use the external reporting channel by submitting a report to ANAC according to the procedures provided on its official website (www.anticorruzione.it), exclusively in one of the following cases:

failure to activate the internal reporting channel or non-compliance of such channel with Article 4 of the Whistleblowing Decree;
failure by Gilmar to follow up on the report submitted through the internal reporting channel;
well-founded reason to believe that, if a report were submitted through the internal reporting channel, it would not be effectively followed up or that it could pose a risk of retaliation;
well-founded reason to believe that the violation may constitute an imminent or obvious danger to the public interest;
well-founded reason to believe that the Recipient of the report is in conflict of interest with the report itself.


4. Protection of the whistleblower and equivalent persons

Gilmar guarantees the confidentiality of the whistleblower throughout the reporting procedure.

The confidentiality of the whistleblower is also guaranteed in the context of any criminal (in the manner and limits of Article 329 of the Criminal Procedure Code) and/or disciplinary proceedings that may be initiated following the report. If the disciplinary charge is based in whole or in part on the report and the knowledge of the whistleblower's identity is essential for the defense of the accused, the report will be usable for disciplinary proceedings only with the express consent of the whistleblower to disclose their identity and after written communication of the reasons for disclosing confidential data.

The whistleblower and persons equivalent to them under the Whistleblowing Decree are also guaranteed the following protection measures, provided that the report is made in good faith and in accordance with the provisions of the Whistleblowing Decree and the "whistleblowing reporting procedure" of Gilmar Divisione Industria S.p.A.:

prohibition of retaliatory measures;
protection from retaliation suffered as a result of the report (including dismissal, discrimination, unfavorable treatment, change of functions, etc.), which includes (among other things) the possibility of reporting to ANAC the retaliations they believe they have suffered following a report, the nullity of acts taken in violation of the prohibition of retaliation, and the possible imposition of an administrative sanction on those responsible for the retaliations;
support measures regarding the reporting methods and the provisions of the Whistleblowing Decree (including information, assistance, free advice from third sector entities);
limitation of criminal, civil, and administrative liability in case of disclosure of certain information related to violations (e.g., information covered by secrecy obligations);
limitation of criminal, civil, and administrative liability (unless the act constitutes a crime) for acquiring information about violations or accessing them;
application of administrative pecuniary sanctions in case of violations of the provisions of the Whistleblowing Decree as provided by Article 21 of the Decree;
invalidity of waivers to transactions not made in one of the protected venues indicated by the Whistleblowing Decree.


For more information regarding the above protection measures and the conditions for their application, please refer to the "whistleblowing reporting procedure" of Gilmar Divisione Industria S.p.A.

​

Download the procedure here:

Whistleblowing Procedure Gilmar.pdf

​

​

(last update on 9 April 2024)

​

Publication of STATE AID (pursuant to Article 1, paragraph 125, of Law No. 124 of August 4, 2017)

​​​

Download the related documentation here:

State Aid.pdf

​​

​

(last update on 18 June 2025)

​

bottom of page