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Disclosure

ON THE PROCESSING OF PERSONAL DATA

pursuant to art. 13 of Regulation (EU) 2016/679

  Last updated: September 15, 2020

  GENERAL INFORMATIONS

With the current statement, the company GTO S.R.L. based in Via Canale 300 - 42013 Casalgrande (RE), Tax Code and VAT number 02173440351, R.E.A. RE - 257962, Share capital € 10,000.00 IV, Tel. +39 0536 823688 fax +39 0536 823686, e-mail [email protected], PEC [email protected], as Data Controller of personal data ( hereinafter simply "Controller") - wishes to inform you about the processing of personal data that you will provide by browsing this Website www.gtogts.it, hereinafter simply “Website”.

 

For any clarification, information, exercise of the rights listed in this statement, the contact details of the Controller are: 

e-mail: [email protected] ;

address for registered mail with return receipt: Via Canale 300 - 42013 Casalgrande (RE).

 

EU Reg. 2016/679 and Legislative Decree 196/2003, as amended by Legislative Decree 101/2018, establish the rules to protect and safeguard individuals with regard to the processing of their personal data and this information is drafted in accordance with the new legislative provision.

 

The statement may undergo changes as a result of the introduction of new rules, so we invite you to periodically visit this section for updating.

 

The Privacy Policy you are reading refers exclusively to the Website www.gtogts.it  e il sito Europeo e Americano and the Data Controller is not responsible for the methods of managing the processing of personal data carried out by third-party websites that can be linked through the Cookie section, or through any window-links present on the Homepage.

 

According to the law, the processing of personal data is based on the principles of correctness, lawfulness, transparency, accuracy, purpose limitation and retention, minimization, data integrity, protection of the user's privacy as well as protection of his rights.

The Data Controller undertakes to observe the aforementioned principles and, also for this purpose, informs you immediately that - with the exception of those treatments which the law requires your explicit consent - browsing this Website, uploading or providing personal data , you accept and agree to be bound by the conditions and terms set out in this statement. The consent to the processing of data issued by the user can be revoked at any time by contacting the aforementioned addresses.

 

The Data Controller will process this data in compliance with applicable legislation, assuming that they refer to the user or to third parties who have expressly authorized him to provide them on the basis of an appropriate legal basis that legitimizes the processing of the data in question. With regards to that scenario, the user stands as an independent data controller, assuming all the obligations and responsibilities of the law. In this sense, it confers on the point the widest indemnity with respect to any dispute, claim, request for compensation for damage from treatment, etc. that should reach the Data Controller from third parties whose personal data have been processed through its use of the Site in violation of the applicable legislation.

 

If you are under the age of 16, your consent is legitimate only if given or authorized by the person holding parental responsibility towards you, in accordance with the provisions of art. 8 EU Reg. 2016/679. For the interested parties who are on Italian territory, the consent is legitimate, under the same conditions as above, even for the person who has reached the age of 14.

 

In any case, we want to give you some information on the personal data processing activities carried out by this Website and on the subjects that manage them.

 

SUMMARY 

 

  1. DATA CONTROLLER
  2. PERSONAL DATA PROCESSED
  3. PURPOSE OF DATA PROCESSING
  4. LEGAL BASIS FOR DATA PROCESSING
  5. DATA CONSERVATION PERIOD
  6. PROCESSING METHODS
  7. RECIPIENTS OF PERSONAL DATA
  8. SCOPE OF CIRCULATION OF DATA
  9. USER RIGHTS ACCORDING TO REG. EU 2016/679

 

 

 

1. DATA CONTROLLER.

 

The Data Controller is the natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of processing personal data. It also deals with security profiles.

With regard to this Website, the Data Controller is the company GTO S.R.L., as specified above, and for any clarification or exercise of your rights you can contact it at the following e-mail address: [email protected].

 

2. PERSONAL DATA PROCESSED.

 

“Personal data” means all information that could directly or indirectly permit the identification of users.

 

   1.  Navigation data.

  

The computer systems and software procedures used to operate this Site acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.

 

This category of data includes IP addresses or domain names of the computers and terminals used by users, the URI / URL (Uniform Resource Identifier / Locator) addresses of the requested resources, the time of the request, the method used in submit 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 (successful, error, etc.) and other parameters relating to the operating system and the user's computer environment.

 

These data, necessary for the use of web services, are also processed for the purpose of:

 

  • obtain statistical information on the use of services (most visited pages, number of visitors per time or day, geographical areas of origin, etc.);
  • check the proper functioning of the services offered.

 

   1. User communicated data.

 

The optional, explicit and voluntary sending of messages to the e-mail address of the Data Controller, the private messages sent by users to the social profiles of the Data Controller, as well as the compilation and forwarding of the contact forms on the Website, involve the acquisition of the sender's contact data, necessary to reply, as well as all personal data included in communications.

 

In particular, the Website uses the plugins of some Social Networks, namely Facebook, Instagram and Youtube. To prevent the transmission and storage of data relating to Internet browsing via Social Networks, the user must log out of these before visiting the Website. For more information on this topic, we recommend that you read the Cookie Policy.

 

As for the modules

 

As for the modules "LEAVE US YOUR DATA AND RECEIVE THE GTO BROCHURE", "SIGN UP NOW TO THE GTO ACADEMY" and "CONTACT US", "ARE YOU INTERESTED IN THIS MODEL?" the release of the requested data does not depend on a legal or contractual obligation. Their release is therefore optional, however the omission of the data to be entered in the mandatory fields does not allow the Data Controller to match the request sent.

 

The data retention period ends with the completion of the requested service, unless the stipulation of a contract derives from this. In this case, the data will be kept for ten years from the signing of the contract for judicial protection in the event of disputes arising from the contract itself.

 

, the release of the requested data does not depend on a legal or contractual obligation. Their release is therefore optional, however the omission of the data to be entered in the mandatory fields does not allow the Data Controller to find the request sent.

 

The data retention period ends with the completion of the requested service, unless the stipulation of a contract derives from this. In this case, the data will be kept for ten years from the signing of the contract for judicial protection in the event of disputes arising from the contract itself.

 

The affixing of the check on the consent flag for the use of data for marketing purposes is optional. In the event that the user wishes to consent, his contact details will also be used for this specific purpose. Consent may be revoked at any time in the manner indicated at the bottom of each e-mail or in the manner indicated below.

 

By completing the form “SUBSCRIBE TO OUR MAILING LIST”, the user agrees that his / her e-mail address will be used to receive advertising and promotional e-mails. The release of such data does not depend on a legal or contractual obligation and is therefore optional, however, failure to provide the requested data does not allow the company to perform the requested service. The processing of such personal data is aimed at sending informative and commercial material and the processing takes place through computerized systems. The user can unsubscribe from the newsletter at any time by using the "unsubscribe" link at the bottom of any commercial communication received, or by contacting the e-mail address [email protected]. The retention period of the released data ends with the revocation of the consent previously issued by the user.

 

 1. Cookies and other tracking systems.

 

Cookies are not used for user profiling, nor are other tracking methods used.

 

With regard to the types of cookies loaded on this Website, we recommend that you read the Cookie Policy.

 

3. PURPOSE OF DATA PROCESSING.

 

Except as provided for on the individual processing activities of personal data present within the Site, in general the purposes of the processing pursued are as follows:

 

  1. respond to requests for information and, in general, contact the user;
  2. execute precontractual and contractual obligations relative to legal relations established, even at a distance;
  3. to send the customer news or commercial communications relating to services similar to those already purchased and therefore in line with the user's interests (so-called Soft Spam). It is possible to oppose such treatment at any time by writing to [email protected] without any consequence (other than that of no longer receiving any informative or promotional communication);
  4. permit registration and, subsequently, forward the newsletter for commercial purposes;
  5. fulfill legal obligations;
  6. to fulfill management, administrative, accounting and tax obligations;
  7. storage, hosting and management of the Site's backend infrastructure;
  8. interaction with social networks and external platforms;
  9. statistics and cookie management;
  10. visualization of contents from external platforms;
  11. prevention and detection of any abuse in the use of the Website, or any fraudulent activity and therefore allow the Controllers to protect themselves in court. 

 

4. LEGAL BASIS FOR DATA PROCESSING. 

 

The legal bases for the processing of personal data provided by the user during the navigation on the Site are:

  • the fulfillment of a legal obligation to which the Holder ex 6 co 1 lett. c) GDPR with respect to the fulfillment of obligations under the law, regulations, community legislation or an order of the Authority;
  • the execution of a contract of which the interested party is a party or the execution of pre-contractual measures adopted at the request of the same, pursuant to 6 co 1 lett. b) GDPR regarding the data collected for registration to the GTO Academy, as well as to respond to requests for information from users sent through the appropriate contact forms;
  • the consent of the user pursuant to Art. 6 co 1 lett. a) GDPR for the management of the newsletter. Consent is expressed by checking the appropriate consent flag;
  • the legitimate interest pursuant to Art. 6 co 1 lett. f) GDPR for the management of the backend infrastructure of the Site, for the management of the technical and analytical cookies on the Site and, more generally, for the exercise of their rights in the context of the information society.

 

 

5. DATA CONSERVATION PERIOD.

  

The data processed to fulfill legal obligations will be kept until their completion, and in any case for the period of time necessary to demonstrate compliance; the data processed to fulfill contractual purposes until the fulfillment of the same and, if a contract is concluded or there have been pre-contractual negotiations, for ten years from the signing of the same in order to allow any judicial or extrajudicial protection as well as the demonstration the correct fulfillment of the obligations contractually assumed.

With regard to the activity of sending newsletters via e-mail, personal data will be kept until revocation of the consent expressed by the user through a request for cancellation from the service. In general, if the processing of personal data is based on the user's consent, the Data Controller may keep the personal data until the consent is revoked.

When the processing of personal data is necessary for the pursuit of a legitimate interest of the Data Controller, the personal data will be kept until such interest is satisfied or until any opposition by the interested party, to be exercised in the manner indicated below.

The data processed for the purposes of Prevention of Abuse and Fraud for the time strictly necessary to allow the Data Controller to defend himself in court.

 

6. PROCESSING METHODS.

  

On this Website, the data is collected electronically and processed through operations carried out mainly with the aid of electronic tools, ensuring the use of suitable measures for the security of the data processed and guaranteeing its confidentiality.

This Website does not provide for the existence of an automated decision-making process for commercial profiling purposes (targeted marketing technique which includes the set of activities for the collection and processing of user data in order to understand their choices and their behavior at in order to divide the interests into “profiles”, or in homogeneous groups for increasingly specific behavior or characteristics).

 

 7. RECIPIENTS OF PERSONAL DATA.

 

The categories of recipients that may be aware of their personal data during or after the performance of the contract are:

  

  1. subjects who process data in execution of specific legal obligations;
  2. external consultants who provide functional services for the purposes indicated above, identified in writing and to whom specific written instructions have been given with reference to the processing of personal data;
  3. subjects with which it is necessary to interact to execute the requested services (eg hosting provider, etc.);
  4. subjects necessary for the provision of the services offered by the Site including, by way of example, the sending of e-mails and the analysis of the functioning of the Site who typically act as data processors on behalf of the Owner;
  5. persons authorized by the Data Controller to process personal data necessary to carry out activities strictly related to the provision of the Services, who are committed to confidentiality or have an adequate legal obligation of confidentiality (eg employees and collaborators of the Data Controller);
  6. in general, to all those public and private entities for which communication is necessary for the correct and complete fulfillment of the purposes indicated.

 

Users' personal data may be disclosed to Judicial Authorities and Police Forces only in cases where this is required by law and used by the Data Controller for the purposes of any defense of his rights in court, where strictly necessary.

  

8. SCOPE OF CIRCULATION OF DATA.

 

The processing of personal data relating to the services of the Website takes place at the headquarters of the Data Controller and is only handled by authorized personnel. The collected data will not be disclosed.

However, for the actual execution of the requested service, some data will be shared with external parties called to carry out specific tasks on behalf of the Data Controller (e.g. hosting providers, housing, cloud, e-mail service providers for the publication needs of the Website and management of the e-mail / PEC service, web agency, marketing consultants, professionals, etc.).

The collected data will not be transferred to third countries or international organizations.

If to provide some services personal data were to be transferred to organizations or third countries (for example where the hosting servers or suppliers are located), the Data Controller ensures that the processing of your personal data by these recipients takes place in compliance with the applicable legislation, or basing it on an adequacy decision pursuant to art. 45 of EU Regulation 2016/679 or, where there is no such decision, on the use of standard contractual clauses approved by the European Commission pursuant to art. 46 of the 2016/679 EU Regulation.

More information is available from the Data Controller by writing to the following address: [email protected].

The Data Controller undertakes to protect the security of personal data by adopting all the IT and physical measures necessary for the protection of the personal data provided. No security system guarantees this protection with absolute certainty, therefore, except in cases of liability for fault, the Data Controller is not liable for the fait accompli by third parties who illegally access the systems without the necessary authorizations. For these reasons, users of the Site are advised to ensure that their computer is equipped with adequate software for the protection of data transmission over the network (for example, updated antivirus) and that their Internet provider has adopted suitable measures for the security of transmission. of data on the network.

 

9. USER RIGHTS ACCORDING TO REG. EU 2016/679

 

Art. 13 par. 2 and Articles. 15 to 22 of the EU Reg. 2016/679 (GDPR) list the user rights.

 

The Data Controller therefore intends to inform you of the existence:

 

  • the right of the interested party to ask the holder for access to personal data (Article 15 of the GDPR), the correction (Article 16 of the GDPR) or the limitation of the processing that concerns him (Article 18 of the GDPR) or to oppose, for reasons legitimate, to their treatment (art.21 GDPR), in addition to the right to data portability (art.20 GDPR);

 

  • the right to request cancellation (Article 17 of the GDPR), transformation into anonymous form or blocking of data processed in violation of the law, including those that do not need to be kept for the purposes for which the data were collected or subsequently treated.

 

Requests can be addressed to the Data Controller, without formalities or, alternatively, using the model provided by the Guarantor for the Protection of Personal Data available on the Site:

 

http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/1089924, by sending an e-mail to the address: [email protected].

 

If the processing is based on art. 6, paragraph 1, letter a) or on art. 9, paragraph 2 lett. a), the user has the right to withdraw consent at any time without prejudice to the lawfulness of the processing based on the consent given prior to the withdrawal.

  

Likewise, in the event of a violation of the law, the user has the right to lodge a complaint with the Guarantor for the Protection of Personal Data, as the authority responsible for monitoring the processing in the Italian State. The form for submitting a complaint to the Privacy Guarantor can be found at: 

http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524.

  

For a more in-depth examination of the rights that compete with you, see articles 15 and ss. GDPR.

 

For the exercise of one or more of the aforementioned rights, you can contact us at the following e-mail address: [email protected].

 

 

 

INFORMATION ON COOKIES

 

The Privacy Policy is an integral part of the following Cookie Policy, including the rights that the user can assert by contacting the addresses already indicated. 

Pursuant to art. 13 and 14 EU Reg. 2016/679 (GDPR), as well as on the basis of the provisions of the Guarantor for the protection of personal data with the resolution of 08.05.2014 for the identification of simplified procedures for the information and the acquisition of consent to the use of cookies - published in the Official Gazette no. 126 of 03.06.2014 - and in compliance with all subsequent clarifications, with this information the Data Controller provides its own Cookie Policy.

The Cookie Policy aims to provide the user with all information relating to articles. 13 and 14 EU Reg. 2016/679 (GDPR), as well as describing in a specific and analytical manner the characteristics and purposes of the cookies installed on the Website, with the possibility for the user to select / deselect which cookies to accept or not.

  

What are cookies?

Cookies are small code strings that the sites visited by the user send to his terminal (usually to the browser: Google Chrome, Internet Explorer, Mozilla Firefox, etc.), where they are stored before being re-transmitted at each occurrence or later. access to the same sites by the same user.

  

Why are they useful?

Through the use of cookies, the visited website recognizes the user's device and this leads to an improvement in the browsing experience. Among the different purposes of cookies is to allow the user to effectively navigate between the pages of the Website, remind him of his favorite sites, memorize the language, etc.

  

How do you select or disable cookies?

By changing the settings of your browser, cookies can be limited or blocked. To manage cookies, refer to the instruction manual or the instructions provided by your browser by following the following paths (relating to the most common browsers):

  

Explorer:

https://support.microsoft.com/it-it/help/17442/windows-internet-explorer-delete-manage-cookies

 

Safari:

https://support.apple.com/kb/PH21411?locale=it_IT

 

Chrome:

https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en

 

Firefox:

https://support.mozilla.org/it/kb/Eliminare%20i%20cookie

 

If the user uses multiple browsers, the procedure for deleting cookies must be carried out for each of them. If the user uses different devices (such as smartphones or tablets), to uninstall the cookies, it is necessary to refer to the instruction manual of their device.

It should be noted that if you choose to block the receipt of cookies this could compromise or prevent the proper functioning of the Website as some cookies are strictly necessary for navigation.

 

How many types of cookies are provided?

Cookies are classified into different types:

in relation to the DURATION, the cookie can be "session" (automatically deleted when the browser is closed) or "persistent" (active until its expiration date or its cancellation by the user);

in relation to the ORIGIN, the cookie can be "first party" (sent to the browser directly from the site you are visiting) or "third party" (sent to the browser from other sites and not from the site you are visiting);

in relation to the PURPOSES, the cookie can be "technical" or "profiling". The “technical” cookie is that of navigation, indispensable, performance, process or security; the functionality, language preference, session status cookie is also "technical"; finally, the first-party or third-party statistical-analytical cookie with IP masking, without data crossing, is "technical" cookies. Your prior consent is not required for the installation of "technical" cookies. Instead, the third-party statistical-analytical cookie that uses the entire IP address is "profiling" cookies; in addition, the advertising, advertising, tracking or conversion cookies are "profiling". Your prior consent is required for the installation of "non-technical" cookies.

 

What cookies does this site use?

We only use first-party technical cookies, necessary for the correct and efficient functioning of the site and the services contained therein, and analytical cookies, including from third parties, to analyze site usage data in an aggregate and anonymous form.

 

Technical cookies:

This Website uses “technical” cookies, without the use of which some operations would be very complex or impossible to perform. Technical cookies do not require the user's prior consent for the purpose of their installation or reading of information.

 

These are technical cookies so strictly necessary that allow you to navigate effectively on Website and to exploit its essential features, such as memorizing previous actions. By blocking the use of these cookies, the user's browsing experience may be compromised and some essential services may not be provided.

 

This Website also uses so-called technical cookies. functionalities that improve the browsing experience by memorizing the preferences expressed by the user, such as language, name, place. Furthermore, these cookies can be used to proactively provide services or to prevent the user from receiving services that he has previously refused. By blocking these cookies the browsing experience will not be compromised, but the user will not be able to take advantage of the useful services offered.

 

This Website may also have installed technical cookies for storing consent. It is advisable not to block these cookies that allow the owner of the Website to store the provision of consent by the user.

 

Third party cookies:

This Website also uses third-party cookies, some of which are session cookies and some are permanent.

The third-party analytical technical cookies installed on this Website allow for the collection of information on how users interact with the Website, analyzing the number of pages visited, the time spent on the Website, the most visited pages and any other events that have emerged. during navigation, such as any errors coming from the page visited. These cookies allow the Website Owner to obtain statistical data relating to navigation and, on the basis of these, can improve the services offered to the user. The "analytical" technical cookies used on this Website do not determine the processing of personal data (such as the user's name and surname, or IP address) since the data are collected in aggregate form for mere statistical purposes and the Site Owner has adopted tools suitable for reducing the identifying power of the analytical cookies used (for example, by masking significant portions of the IP address).

 

The third-party cookies used on this website are not controlled directly by the owner of the site and consequently, for the deactivation of the same or for more information, the user must observe the following procedures:

 

1) by clicking http://www.youronlinechoices.com/it/ the user can obtain more information on third-party cookies and the cookies stored on their terminal. The user can proceed to deactivate all or some of these cookies by clicking the following link: http://www.youronlinechoices.com/it/le-tue-scelte

 

or

 

2) the third-party cookies used on this website will be listed below. To manage and deactivate these cookies, it is necessary to access the information and consent forms of these third parties by clicking on the links indicated.

 

To monitor the correct functioning of the site, the Owner uses a web traffic analysis service called Google Analytics provided by Google which, through the use of cookies, anonymously collects some information (e.g. browser used, area geographic, IP address assigned to the device in use, etc.) to analyze the use of the site by users. Since the service is used anonymously, Google Analytics tracking cookies are similar to first-party technical cookies for which consent is not required.

The data generated by Google Analytics are stored in the terms indicated in the information available at the following address:

https://support.google.com/analytics/answer/2838718

The privacy policy of Google Inc. can be found at the following address:

http://www.google.com/intl/en/policies/privacy/

The user can disable Google Analytics by installing the opt-out add-on provided at the following address on their browser:

https://tools.google.com/dlpage/gaoptout

Blocking these cookies will not compromise the user's browsing experience.

 

On the pages of the Website there are buttons and Social Networks widgets to facilitate interaction with social platforms. In particular, on the pages of this Site there are Facebook and Instagram buttons in order to improve the user's browsing experience and allow him to view the contents shared by the Owner through Social Networks or interact with him through these channels.

The management of the information collected by third parties is governed by the relevant information to which reference must be made for any clarification. The Data Controller is not responsible for the operation on its Site of third-party cookies / plugins. However, for convenience and transparency, the web addresses of the various information and methods for managing cookies / plugins are shown below.

 

To this end, see:

 

  • the Facebook privacy and cookie information available on the site:

https://www.facebook.com/privacy/explanation and https://www.facebook.com/policies/cookies/

 

  • the Instagram privacy and cookie information available on the site:

https://help.instagram.com/155833707900388 and https://www.facebook.com/policies/cookies/

 

Furthermore, on the homepage of the Site, there is a link to the company's channel on Youtube. Youtube's privacy and cookie information can be found on the site:

https://policies.google.com/privacy?hl=it&gl=en

 

To deactivate YouTube profiling cookies, the user clicks the following address:

https://policies.google.com/privacy?hl=it

 

 

Blocking all the aforementioned third-party cookies does not compromise the user's browsing experience, but could decrease the quality of the services offered by the Website.

For more information, also relating to the disabling of Third-party profiling cookies sent to the user's browser while browsing this Website, see: http://www.youronlinechoices.com/it/

or contact the addresses:

by sending an e-mail: [email protected]

for sending rec. a / r: Via Canale 300 - 42013 Casalgrande (RE).