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, data relating to your purchase order, etc. are considered to be personal data.
Gilmar does not sell products available on its Website to minors and does not process the personal data of such individuals.
For this reason, if you are under 18 years old, please do not provide us with any personal information, do not subscribe to the Gilmar newsletter, do not register on the Website and do not carry out financial transactions to purchase products online. Purchases on the Website may be made by your parents, by your guardian or by a person over eighteen years of age. In the event that we determine that personal data belonging to a minor has been communicated to Gilmar, such data shall be deleted.
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: firstname.lastname@example.org
TYPES OF PERSONAL DATA PROCESSED
When you browse, interact or make purchases on the Website, Gilmar processes the following types of personal data:
PURPOSE AND COMPULSORY OR OPTIONAL NATURE OF THE DATA PROCESSING
Gilmar collects and processes your personal data for the following purposes:
Failure to consent to the processing of your personal data for marketing and profiling purposes, or the subsequent revocation of your consent for such purposes, shall not prevent you from browsing the Website and making purchases through the same.
LEGAL BASIS OF THE DATA PROCESSING
Gilmar processes your personal data based on the following conditions of legitimacy:
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 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:
Gilmar may also disclose your personal data to its legal representatives and/or consultants, to enforce its general conditions of sale and/or legal regulations, to fulfil the requests of judicial and administrative authorities and/or to protect its rights in judicial, arbitration or similar legal proceedings, 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 personal data, including pursuant to 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 or subcontractors 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:
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 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.
Credentials for access to the private area of the Website shall be retained by Gilmar until such time that you request to close your account.
Data provided in the “my orders” and “my returns” sections shall be retained by Gilmar for the time needed to complete your requests and deleted once such requests have been fulfilled.
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 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 new consent to the processing of your data for profiling purposes.
CLOSING OF THE ACCOUNT - WITHDRAWAL OF CONSENT
To request to close your account, you can send an email to email@example.com.
You may, at any time, object to the processing of your personal data by Gilmar for profiling purposes, for sending newsletters and for the fulfilment of any marketing 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 firstname.lastname@example.org, or by following the instructions provided at the bottom of the newsletter or of promotional communications received from Gilmar.
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.
You may, at any time contact Gilmar, 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:
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 January 14, 2020)