Privacy Policy

This policy is provided, in accordance with Art. 13 of Legislative Decree no 196/2003 (Personal Data Protection Code) and Art. 13 of Regulation (EU) 2016/679 (European Regulation on the protection of natural persons with regard to the processing of personal data (“GDPR”), to those who interact with the services available online on the Site. This policy aims to give you information on how we look after your personal data and tell you about your privacy rights as an individual under the GDPR. We inform you that the processing of your personal data will respect the principles of fairness, legality, trasparency and protection of your privacy and rights. This policy is applicable exclusively for the site www.gicomsrl.com (“Site”), and not for any other site that a user might connect to via hyperlink, which are in fact beyond the control of GICOM SRL.

DATA CONTROLLER

The Data Controller is GICOM SRL (“GICOM SRL.” or “Data Controller”), with registered office in Via Sardorella 45R B/C, 16162 Genova Bolzaneto. (GE), Italy. Tax ID and VAT number 02144410996, phone +39 0108062168, e-mail gicom@gicomsrl.com, certified email gicomsrl@legalmail.it.

TYPE OF PERSONAL DATA COLLECTED

Navigation Data

The IT systems and software procedures utilized to run this Site acquire some user-derived personal data as part of their normal functioning; the transmission of such data is implicit in internet communication protocols. These data are not collected to be associated with identified data subjects, but, by their very nature, they might make users identifiable after being processed and matched with data held by third parties. This data category includes IP addresses or domain names of the computers used to connect to the website, URI (Uniform Resource Identifier) addresses of the requested resources, the time of such requests, the method used to submit the request to the server, the size of the returned file, the numerical code of the server response status (completed, error, etc.) and other parameters related to the user’s operating system and IT environment.

Data Voluntarily Submitted by the User

The user’s personal data collected through the online form on the Site are: first name, surname, email address, country of origin.

THE PURPOSES OF PERSONAL DATA PROCESSING

GICOM SRL. will process your personal data:
1. to respond to your requests for information submitted by Site using the enquiry form;
2. to provide technical assistance;
3. to comply with statutory, regulatory requirements (for both Italian and EU legislation)
4. Once they are anonymized, to collect anonymous statistical data on use of the website, and to monitor its proper functioning;
5. To send you exclusively by e-mail newsletter of an informative/advertising nature commercial information with respect to its own marketing campaigns, and invitations to events organized by GICOM SRL.
Please note that for the purposes listed under 1), 2) and 3), supra, consent is not required for GICOM SRL to process your personal data, as the processing is made pursuant to requests made by you, or in compliance with the law. The purpose listed under point 4), supra, does not involve personal data processing, whereas your consent is required to process data with regard to point 5).

OPTIONAL AND REQUIRED DATA SUBMISSION

It is mandatory to provide your data for the purposes referred to in points 1), 2) and 3) above. Their processing is required so we can respond to requests for information, provide technical assistance and comply with legal obligations. Any refusal to provide such consent will make it impossible for GICOM SRL. to respond. The provision of data for the purposes referred to in point 5) above is optional; consequently, without your express consent, we will not process the data for the advertising and marketing purposes indicated therein.

DATA PROCESSING METHODS AND SECURITY MEASURES

Data will mainly be processed using electronic or, in any case, automated (manual, IT, and/or online) tools, using methods and resources that assure the security and privacy of the data. Moreover, all technical, IT, organizational, and security-protocol measures will be taken to ensure appropriate data protection as required by law. Only Data Processors appointed by the Data Controller or by any Data Protection Officers may access the data. Data subject to processing shall be relevant, complete, and limited in scope to the purposes for which they were collected or thereafter processed and will only be stored in a format that allows the data subject to be identified as long as necessary for the purposes for which they were collected, in compliance with applicable law. The Controller states it does not use automated processes to profile the data subject.

RECIPIENTS OF PERSONAL DATA

Personal data shall be processed onsite at GICOM SRL’s premises, and may be disclosed to its employees and/or contractors, as well as to the following entities:
a) Third-party companies in the same corporate group as GICOM SRL. in order to respond to requests you have submitted using the online form;
b) Third-party companies, in order to provide the technical assistance requested;
c) Any government authority with access to the data pursuant to any court or administrative order;
d) Entities who provide services for the management of the IT system, and the telecommunications network (including email).
e) marketing companies.
All the above Third party will be nominated by GICOM SRL as Data Processors. The updated list of Data Processors will be made available upon request to the Data Controller to be sent by e-mail to the following address: privacy@ gicomsrl.com.

PERIOD OF DATA STORAGE

The Controller retains your personal data for as long as is necessary for the purposes described in this policy. When used for marketing purposes referred to in point 5) above, data will be kept by GICOM SRL for a period equal to twenty-four months from the date of registration in its database. In any case, once the maximum data retention period has elapsed they will be automatically deleted or made anonymous.

INTERNATIONAL TRANSFER OF PERSONAL DATA

Your personal information will be stored at GICOM SRL’s facilities in Genova Bolzaneto (Italy). Your data will not be transferred by GICOM SRL to third countries outside the European Economic Area (“EEA”).

DATA SUBJECT’S RIGHTS

Pursuant to Italian Legislative Decree no. 196 of 30 June 2003 and Regulation (EU) 2016/679, you may exercise your rights as follows: – Pursuant to Section 15, 16, 17, 18, 19, 20 and 21 of the EU Regulation and in accordance with Art. 7 of Italian Legislative Decree n. 196, 30 June 2003, to ask the Controller to access your personal data, correct or delete them or restrict the processing of your personal data or to oppose to processing of the data, in addition to the right to data portability.
Data that the Controller is required to store by law cannot be erased.
– To withdraw your consent to processing of your data for the purposes referred to in point 5) above at any time, pursuant to Art. 7 of the EU Regulation, without thereby affecting the legality of the processing based on your consent before the revocation.
-to lodge a complaint with the Garante Privacy (The Italian Data Protection Authority), following the procedure and instructions available on the official website of the Authority on www.garanteprivacy.it, should you believe that Controller’s processing of your personal data breaches your privacy rights.
The exercise of the preceding rights is not subject to any form constraint and is free.
If you wish to exercise any of the rights set out above, please contact the Data Controller
by e-mail sent to privacy@gicomsrl.com or by post GICOM SRL, Via Sardorella 45R B/C, 16162 Genova Bolzaneto. (GE), Italy.
The present privacy policy may be subject to change to comply with any intervening changes in the law, or any updates to GICOM SRL’s data-processing policies. Each updated version of the present Privacy Policy shall be included on the Site.