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 Legislative Decree no. 196/2003, also updated pursuant to Legislative Decree no. 101/2018.
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, in Via Malpasso no. 723-725, reachable by phone or email at:
Tel: +39 0541 959111
Email address: email@example.com
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 firstname.lastname@example.org.
TYPES OF PERSONAL DATA PROCESSED
When browsing our Website or interacting with the features offered therein, Gilmar processes the following types of personal data:
a) 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
b) 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 eventually your telephone number.
c) data that you provide to Gilmar when you fill out the (tolto form) “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 phone number, your current job, your level of experience, the information contained in your LinkedIn profile, in your cover letter and the information that you provide by filling out the “Comments” field found on the same form
In conducting its business and within the scope of its business relations, Gilmar may also process the personal identification and/or contact data related to individuals who refer to its professional clients and/or suppliers, as well as identification data referred to individual firms and/or suppliers.
PURPOSE AND COMPULSORY OR OPTIONAL NATURE OF THE DATA PROCESSING
Gilmar processes your personal data for the following purposes:
to allow you to browse the Website and for computer security purposes.
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;
to enforce contracts related to the conduction of the business activity and, more generally, to manage relations with professional clients and/or suppliers;
to handle any complaints and/or to fulfil obligations imposed by the law, including those related to accounting and fiscal matters;
for recruitment purposes;
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
With regard to the data communicated through the Website, failure to enter the data in the fields marked with an asterisk shall make it impossible to complete the procedure for sending the 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 the request.
Failure to provide the data requested by Gilmar within the scope of pre-contractual activities and/or to formalise contracts with its professional clients and/or suppliers shall make it impossible for Gilmar to provide the service requested and hence the possibility to conclude any contracts.
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), as well as to fulfil any contracts concluded, 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 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 art. 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 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 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.
Your personal data may also be shared with companies affiliated with Gilmar 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 independent 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 which provide assistance to Gilmar with regards to the conduction of its business activity, to the necessary initiatives to protect its rights, 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 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, including in accordance with the requirements set out in 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 received by the latter. Such parties, in fact, are required to sign appropriate agreements that include the standard contractual clauses for the protection of personal data adopted by the European Commission.
Moreover, the legitimacy of the transfer of personal data in the United States is guaranteed by the adherence of Gilmar’s providers located in that territory to the “Privacy Shield” principles.
Additional information on the Privacy Shield (the agreement governing the transfer of data between the EU and the United States) is available by consulting the following links:
Information page on the Privacy Shield published by the Italian Authority for the Protection of Personal Data / Garante.
DATA RETENTION PERIOD
Your personal data shall be retained by Gilmar for a limited period of time, necessary to achieve the purposes of each data processing activity identified above. At the end of this period, your 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.
Personal data processed in order to fulfil the commitments provided for by the contracts, including pre-contractual activities, shall be retained by Gilmar for a period of 10 years from the execution of the contractually provided service, or, in the case where the pre-contractual activities do not lead to the conclusion of a contract, the data provided by filling out the Contact Us form shall be retained for the time strictly necessary to respond to your requests and then deleted.
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.
The personal data and information 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.
You may contact Gilmar at any time, by sending an email to email@example.com, 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 firstname.lastname@example.org, 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:
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 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.
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 to oppose the processing (pursuant to the cases provided for in Articles 17 and 18 of the GDPR);
submit a complaint to the Supervisory Authority (the Italian Authority for the Protection of Personal Data or Garante).
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 transfers, pursuant to Article 46 of the GDPR.
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);
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.
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.