- Data Controller
Data Controller is GS & T GLOBAL SYSTEMS & TECHNOLOGIES S.R.L. (GST) with registered office in Torino, Via Giovanni Servais n.176/2, C.F. e P.Iva: 07790560010. You can contact Data Controller at the following e-mail address: email@example.com.
- Personal Data processed and purposes of processing
When users use the Website, GST will collect and process information regarding them such as follow.
The Website’s operation, as is standard with any websites on the Internet, involves the use of computer systems and software procedures, which collect information about the Website’s users as part of their routine operation. While GST does not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information, or by using other information collected – as such, this information must also be considered Personal Data.
This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the Website, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on.
These data are used to compile statistical information on the use of the Website, as well as to ensure its correct operation and identify any faults and/or abuse of the Website. Save from this last purpose, these data do not persist for more than 7 working days.
Name, contact details, other Personal Data and special categories of Personal Data
Certain areas of the Website (such as the form to request) include free text fields where you can provide GST with some information, which users may use to submit information such as your name, phone number, e-mail address.
By filling in the contact form with their Data, the users consent to their use to respond to requests for information or any other kind.
Where these fields are completely free, users may use them to disclose (inadvertently or not) more sensitive categories of Personal Data, such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership. The content upload in these fields may also (inadvertently or not) include other types of sensitive information relating to you, such as genetic data, biometric data or data concerning health, sex life or sexual orientation.
GST asks that users do not disclose any sensitive Personal Data on the Website, unless they consider this to be strictly necessary. As it is totally optional to provide this information, if users do, please mind that GST needs your explicit consent to process this kind of Personal Data. GST would stress on the importance of providing explicit consent to process this sort of Personal Data if users decide, nonetheless, to share it.
These messages may (inadvertently or not) also include Personal Data related to other persons. In any situation where users decide to share Personal Data related to other persons, users will be considered as an independent data controller regarding that Personal Data and must assume all inherent legal obligations and responsibilities. This means, among other things, that users must fully indemnify GST against any complaints, claims or demands for compensation for damages which may arise from the processing of this Personal Data, brought by the third parties whose information you provide through the Website.
As GST does not collect this information directly from these third parties (but rather collects them, indirectly, from you), users must make sure that you have these third parties’ consent before providing any information regarding them to GST; if not, then you must make sure there is some other appropriate grounds on which you can rely to lawfully give GST this information.
- Lawful basis for processing and mandatory / discretionary nature of processing
Legal bases for processing users’ Personal Data, according to the purposes identified in Section 2, are as follows:
– Service Provision: processing for these purposes is necessary to provide the Services. It is not mandatory for users to give GST their Personal Data for these purposes; however, if users do not, GST will not be able to provide any Services to them.
– Soft Spam: processing for this purpose is based on the interest of GST of sending users direct e-mail marketing communication regarding products and services similar to those they have asked for information through the use of the Website. Users can block these communications, and they will suffer no consequence if you do so (aside from not being able to receive further communications).
– Profiling: processing for this purpose is based on users’ consent collected by means of the banner cookie. It is not mandatory for users to give consent to GST for use of your Personal Data for this purpose, and they will suffer no consequence if you choose not to. Any consent given may also be withdrawn at a later stage.
– Compliance: processing for this purpose is necessary for GST to comply with its legal obligations. When users provide any Personal Data, GST must process it in accordance with the laws applicable to it, which may include retaining and reporting users Personal Data to official authorities for compliance with tax, customs or other legal obligations.
– Misuse/Fraud: Information collected for this purpose is used exclusively to prevent and detect fraudulent activities or misuse of the Website (for potentially criminal purposes).
- Recipients of Personal Data
Users Personal Data may be shared with the following list of persons / entities (“Recipients”):
– Persons, companies or professional firms providing GST with advice and consultancy regarding accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services and which act typically as data processors on behalf of GST;
– Entities engaged in order to provide the Services (e.g., hosting provider or e-mail platform providers);
– Persons authorized to perform technical maintenance (including maintenance of network equipment and electronic communications networks);
– Persons authorized by GST to process Personal Data needed to carry out activities strictly related to the provision of the Services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees of GST);
– Public entities, bodies or authorities to whom your Personal Data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities;
- Data processing
This website treats users’ Personal Data in a lawful and correct manner, adopting the appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of Personal Data. The treatment is carried out using IT and / or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. The management and storage of personal data will take place in Europe, on servers physically located within the EU Economic Area.
The extent and adequacy of the Personal Data provided will be assessed from time to time, in order to determine the consequent decisions and avoid the processing of excess data with respect to the purposes pursued.
- Transfer of Personal Data
Due to the interactions with Google Analytics, some of your Personal Data may be shared with Recipients who are located outside the European Economic Area. The Data Controller ensures that the processing of your Personal Data by these Recipients takes place in compliance with the applicable legislation. Indeed, transfers are made through adequate guarantees, such as adequacy decisions (see Privacy Shield), Standard Contractual Clauses approved by the European Commission or other guarantees considered adequate.
- Personal Data Retention
Personal Data processed for Service Provision will be kept by GST for the period deemed strictly necessary to fulfil such purposes – in any case, as these Personal Data are processed for the provision of the Services, GST may continue to store this Personal Data for a longer period, as may be necessary to protect GST interests related to potential liability related to the provision of the Services.
Personal Data processed for Marketing and Profiling will be kept by GST from the moment you give consent until the moment you withdraw the consent given. Once consent is withdrawn, Personal Data will no longer be used for these purposes, although it may still be kept by GST, in particular as may be necessary to protect GST’s interests related to potential liability related to this processing.
Personal Data processed for Soft Spam will be kept until you object to such processing.
Personal Data processed for Compliance will be kept by GST for the period required by the specific legal obligation or by the applicable law.
Personal Data processed for preventing Misuse/Fraud will be kept by GST for as long as deemed strictly necessary to fulfil the purposes for which it was collected.
- Data subject’s rights
Data subject are entitled to exercise the following rights before GST, at any time:
Ø obtain confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data (art.15 GDPR);
Ø obtain the following information:
– where personal data have been obtained;
– processing purposes and means
– in case of automated decision-making, including profiling, at least in those cases, meaningful information about the logic involved;
– the identity and the contact details of the controller, processor and, where applicable, of the controller’s representative;
– the recipients or categories of recipients of the personal data;
Ø obtain: a) rectification of inaccurate personal data; b) the erasure of personal data, the transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed. Data controller must give evidence that the operations referred to in the letters a) e b) have been brought to the attention, also with regard to their content, of those recipients to whom the data have been communicated, except in the case where this fulfillment proves impossible or involves a use of means manifestly disproportionate to the protected right;
Ø obtain the restriction of processing;
Ø receive the personal data concerning him, which he has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided;
Ø object to the personal data processing;
Ø withdraw your consent to processing (for Marketing and Profiling or Soft Spam).
Ø lodge a complaint with a supervisory authority (Garante Privacy www.garanteprivacy.it).
We inform you that the rectification of most of the Personal Data provided to GST as well as for the exercise of the other rights that the GDPR recognizes to Data Subjects, you can contact Data Controller at the following email address: firstname.lastname@example.org.
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Cookies present on the Website
In detail, the cookies present on the Website are as follows:
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