INFORMATION ON THE PROCESSING OF PERSONAL DATA
Pursuant by art. 13 European Regulation 2016/679
In compliance with the provisions provided by art. 13 of EU Regulation 2016/679 (hereinafter "GDPR"), Guala Closures S.p.A., with registered office in via Rana 10/12, fraz. Spinetta Marengo, Alessandria (AL) – 15122, in its capacity of data controller (hereinafter also the “Data Controller” or the “Company”), informs on the purposes and methods of processing the personal data collected and/or provided by the user (hereinafter also the "Data Subject"), in relation to the domain https://www.gualaclosures.com (the "Website").
1. PROCESSING OF PERSONAL DATA
The Website is used by the Company to promote, among others, its values and principles, product lines, economic and commercial information, and social and marketing initiatives. Through the user's consultation of the Website, the Company may process data relating to identified or identifiable natural persons as Data Controller.
2. TYPE OF PROCESSED DATA
- Data communicated by user
The Website allows the optional, explicit and voluntary sending of messages to the Company's contact e-mail addresses, including through an online form that involves the acquisition of the sender's contact data (first name, last name, e-mail and telephone) necessary to respond to the requests made, as well as any personal data included in the communications themselves.
- Cookies and other tracking devices
No user profiling cookies are used. The only data processing performed is related to the creation of statistics via pseudonymised data concerning navigation on the Website. The implemented configuration, which does not rely on identifying information, collects the following information:
- IP address, which is masked by setting the final 2 bytes to ‘0’ (xxx.xxx.0.0)
- Operating system
- Browser type
- Device type (PC, smartphone, etc.)
Necessary cookies are used as strictly necessary to allow secure, efficient navigation on the Website. Specifically, necessary cookies allow tracking the cookie consents, including the ones for marketing cookies that user may have provided. Please refer to the dedicated Cookie Policy for more detailed information regarding cookies on the Website.
3. LEGAL BASIS AND PURPOSES OF THE PROCESSING – RETENTION PERIOD
The Data Controller processes the personal data of the user collected through the Website on the basis of:
- the user's consent (art. 6 lett. a of the GDPR) in the event that personal data were transmitted through the Website directly by the user, either by using the appropriate online form or by sending an e-mail to the Company's addresses. The collected personal data will be used exclusively to respond to user’s requests and stored in accordance with applicable regulations and, in any case, only for the time required by the purpose for which they have been provided;
- the legitimate interest of the Data Controller (art. 6 letter f of the GDPR) in the event that user’s personal data are collected (i) for the purpose of preventing and repressing fraud/abuse/fraudulent activities carried out through the Website or; (ii) for the assessment, exercise or defence of a right of the Data Controller in court (personal data will be stored for the entire duration of the complaint and/or proceeding, until the exhaustion of the terms of enforceability of judicial protections and/or appeal actions).
Specific information notices will be displayed on the Website, where applicable, to provide certain services or for the participation to specific initiatives published by the Company on the Website.
4. METHOD OF THE DATA PROCESSING AND DATA SECURITY
The user’s personal data will be processed with IT, electronic and/or telematic systems, according to organizational methods which respect the principles of minimisation, necessity, and proportionality, avoiding the processing of personal data if the operations can be carried out by anonymous data or through any other mode. The processing of personal data will only be carried out by personnel of the Data Controller specifically authorized in accordance with the GDPR. The Data Controller has adopted appropriate security measures to prevent unauthorized access, disclosure, modification and/or destruction of personal data in accordance with art. 32 of the GDPR.
5. COMMUNICATION AND DISSEMINATION OF PERSONAL DATA
For the performance of activities necessary to respond to user requests, personal data may be disclosed to third parties, duly appointed as data processors in accordance with the provisions of art. 28 of the GDPR. The user's personal data will not, however, be subject to dissemination.
The transfer of data to non-EU countries is not envisaged.
Personal Data will not be publicly disclosed. Should the transfer be necessary to respond to the request received by the user or through the dedicated form on the Website, it will be carried out in compliance with articles no. 44 and subsequent of the GDPR.
6. THE RIGHTS OF THE DATA SUBJECT
We inform you that, pursuant to the GDPR, as a Data Subject, in addition to the right of lodging a complaint with a supervisory authority, you also have the rights listed below that you can exercise by sending a specific written request to the Data Controller:
- Art. 15 - Right of access: right to obtain confirmation whether or not your personal data are being processed by Data Controller and, if so, to obtain access to them;
- Art. 16 - Right to rectification: right to obtain the rectification of inaccurate Personal Data without unjustified delay;
- Art. 17 - Right to erasure (right to be forgotten): right to obtain the erasure of your Personal Data, without unjustified delay, in the cases provided for by the applicable law;
- Art. 18 - Right to restriction of processing: right to obtain a restriction of processing when one of the cases provided for by the applicable legislation occurs;
- Art. 19 - Obligation to notify the event of rectification or cancellation of Personal Data or restrictions of processing: the Data Controller informs each of the recipients to whom the Personal Data have been transmitted of any corrections or cancellations or restrictions of processing carried out in accordance with the Articles 16, 17 (paragraph 1) and 18, unless this requires impossible or disproportionate effort. The Data Controller communicates these recipients to the Data Subject party if the Data Subject requests it;
- Art. 20 - Right to data portability: right to receive your Personal Data in a structured, commonly used and automatically readable format and has the right to transmit such data to another data controller without hindrance from of the Data Controller to whom it has been provided if: a) the processing is based on consent or on a contract of which the Data Subject is a party (pursuant to the GDPR); and b) the processing is carried out by automated means;
- Art. 21 - Right to object: right to object at any time, for reasons related to your particular situation, to the processing of personal data concerning you pursuant to article 6, paragraph 1, letters e) or f) of the GDPR, including profiling on the basis of these provisions;
- Art. 22 - Right not to be subjected to an automated decision-making process, including profiling: right not to be subjected to a decision based solely on automated processing, including profiling, which produces legal effects concerning the Data Subject or which affects similar significantly on your person.
To exercise the rights provided by the articles no. 15 and ss. of the 2016/679 European Regulation, you shall write an e-mail to privacy@gualaclosures.com or by sending a letter to the Company's headquarters located in via Rana 10/12, fraz. Spinetta Marengo, Alessandria (AL) – 15122, to the attention of the Data Controller. If the Data Subject considers that the processing of personal data relating to him or her as performed via Website infringes the GDPR, he or she has the right to lodge a complaint with the Autorità Garante per la protezione dei dati personali pursuant to art. 77 of the GDPR, or else to bring a judicial proceeding pursuant to art. 79 of the GDPR.