Privacy policy

DATA CONTROLLER

Controller

G.T.S. GLOBAL TRADE SOLUTION S.R.L.

Address

Via Zoe Fontana 220 - 00131 Roma (RM)

VAT / Tax Code

17237271006 / 17237271006

Contacts

Legal Representative

Angeletti Fabio

Privacy Contact

Angeletti Fabio ([email protected])

Data Protection Officer

Not present

Co-Controllers

• No co-controller present

If you would like to request further information on the processing of your personal data or exercise your rights, you can contact the Privacy Contact listed above in writing.

CATEGORIES OF DATA SUBJECTS

List of data subjects categories

Clients or Users, Potential clients, Consumers, Freelancers, Shareholders, members, and subscribers, Merchants, Entrepreneurs, Suppliers

PROCESSING CARRIED OUT

Commercial activities with customer loyalty

Description

Activities related to the processing of personal data for the production, distribution, and sale of goods or services and customer loyalty through enrollment in a loyalty program.

ORIGIN, PURPOSES, LEGAL BASIS AND NATURE OF THE PROCESSED DATA

Origin

Data collected from the data subject.

Purposes

1. Customer management

2. Compliance with tax and accounting obligations - Acquisition of data for printing and sending invoices both in paper and digital form.

3. Marketing (market analysis and surveys) - Consent not required because communications for direct sales of products/services or for customer satisfaction analysis or market surveys use the email coordinates collected from the data subject during the sale of a product or service similar to those of the sale, and no explicit refusal was made by the data subject to such use, initially or in subsequent communications. Each communication provides information on the possibility of opting out of the treatment (opt-out).

4. Advertising

5. Promotional activities - Consent obtained from the data subject at the time of collecting personal data through acceptance included in the policy. In case of no consent, profiling for promotional purposes will not proceed.

6. Customer satisfaction survey

7. Information to customers about new services/products

8. Sending of informational and/or advertising material by phone or internet - Consent received from the data subject at the time of collecting personal data through acceptance included in the policy. In case of no consent, the sending of informational and/or advertising material will not proceed.

9. Telecommunication for information

10. Providing the service

Legal basis

For purposes 1, 4, 6, 7, 9, 10: The processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures taken at the request of the data subject

For purpose 2: The processing is necessary to comply with a legal obligation to which the data controller is subject

For purpose 3: The processing is necessary for the pursuit of the legitimate interest of the data controller or a third party

For purposes 5, 8: Consent of the Data Subject

Personal data processed

Tax code and other personal identification numbers, Contact phone, Bank details, Date of birth, Accounting, fiscal, and financial data, Contact and communication data, Behavioral data, User profiles, consumers, taxpayers, etc., Identification document, Residential address, Email address, Name, address or other identifying personal elements, Gender m/f

"Special" data (sensitive data) are those defined by Articles 9 and 10 of Regulation 2016/679/EU ("GDPR"). Such data are processed in compliance with the provisions of the GDPR as well as the General Authorizations issued by the Italian Data Protection Authority.

Special data processed

-

Legal basis under Article 9

RECIPIENTS OR CATEGORIES OF RECIPIENTS OF PERSONAL DATA

Categories of recipients

The communication of your personal data is envisaged, based on the legal grounds provided by Article 6 of Regulation 2016/679/EU, to the following third parties:

Consultants and freelancers, also in association, Companies and businesses, Authorized subjects

These entities, organizations, companies, and professionals act as Data Processors appointed by G.T.S. GLOBAL TRADE SOLUTION S.R.L. or are themselves Controllers of personal data transmitted to them.

Your personal data, or personal data of third parties in your ownership, may also be communicated to external companies, selected from time to time, to whom G.T.S. GLOBAL TRADE SOLUTION S.R.L. assigns the performance of obligations arising from the received assignment, to which only the data necessary for the activities requested will be transmitted.

TRANSFER TO FOREIGN COUNTRIES

Transfers to foreign countries (non-EU) or to international organizations

• No transfer to foreign countries or international organizations

The transfer abroad of your personal data may occur when it is necessary for the management of the assignment received. For the processing of information and data that will be communicated to these subjects, equivalent levels of protection will be required for the processing of personal data of employees.

MODALITIES, LOGICS OF PROCESSING AND CONSERVATION TIMES

Duration of processing

Data for loyalty purposes in the strict sense, necessary to enable enrollment in the loyalty program and for the management of the loyalty card, will be processed and stored until the administrative duration of the respective program or until cancellation and/or withdrawal by the participant.

In case of possible withdrawal, disqualification due to non-use within a specific time frame, expiration, or return of the card (as provided by the separate Loyalty Program Regulations), the retention period of personal data for exclusive administrative purposes (and not for profiling or marketing purposes) will not exceed three months.

Data for profiling and/or marketing purposes (only if the participant in the loyalty program and/or the cardholder has given separate, specific, optional, and informed consent) will be stored for a period not exceeding twelve and twenty-four months from their registration.

Data will be processed throughout the contractual relationship and even subsequently, to fulfill all legal obligations and for future commercial purposes.

NATURE OF THE PROVISION

The processing of personal data will be carried out for the following purposes:

Purposes that do not require consent

- Customer management

- Compliance with tax and accounting obligations - Acquisition of data for printing and sending invoices both in paper and digital form.

- Marketing (market analysis and surveys) - Consent not required because communications for direct sales of products/services or for customer satisfaction analysis or market surveys use the email coordinates collected from the data subject during the sale of a product or service similar to those of the sale, and no explicit refusal was made by the data subject to such use, initially or in subsequent communications. Each communication provides information on the possibility of opting out of the treatment (opt-out).

- Advertising

- Customer satisfaction survey

- Information to customers about new services/products

- Telecommunication for information

- Providing the service

Purposes that require consent

- Promotional activities - Consent obtained from the data subject at the time of collecting personal data through acceptance included in the policy. In case of no consent, profiling for promotional purposes will not proceed.

- Sending of informational and/or advertising material by phone or internet - Consent received from the data subject at the time of collecting personal data through acceptance included in the policy. In case of no consent, the sending of informational and/or advertising material will not proceed.

Only with your explicit consent given at the end of this privacy policy, data for purposes that require consent will be processed. Providing data is optional and will not affect the contractual relationship with the Data Controller.

For data collected and used for tasks related to the contractual relationship and compliance with the legal obligations indicated, consent is not required.

RIGHTS OF DATA SUBJECTS

(Articles 15 to 22 of the GDPR)

Right of access

The data subject has the right, as per Articles 15 to 22 of the GDPR, to request access to their personal data from the Data Controller.

Right of rectification

The data subject has the right, as per Articles 15 to 22 of the GDPR, to request rectification of their personal data from the Data Controller.

Right of deletion

The data subject has the right, as per Articles 15 to 22 of the GDPR, to request deletion of their personal data from the Data Controller.

Right of limitation

The data subject has the right, as per Articles 15 to 22 of the GDPR, to request limitation of their data from the Data Controller.

Right of opposition

The data subject has the right, as per Articles 15 to 22 of the GDPR, to oppose the processing of their personal data.

Right of portability

The data subject has the right, as per Articles 15 to 22 of the GDPR, to exercise their right to data portability.

Right of revocation

The data subject has the right, as per Articles 15 to 22 of the GDPR, to exercise their right to revoke consent.

Right to complaint

The data subject has the right, as per Article 77 of the GDPR, to file a complaint with the supervisory authority.

AUTOMATED PROCESS

Is there an automated process?

YES

Automated processes or profiling methods

Despite the data subject's consent, profiling will not proceed for the purposes of revealing health status or sexual life, which is prohibited. The processing methods will always be relevant and not excessive with respect to the types of goods marketed or services rendered.

Profiling activities may involve both "individual" and "aggregated" personal data derived from detailed individual data. These processes may include various types of personal information, including contractual data and data related to purchases, consumption habits, and spending levels, from which further information about the data subject can be inferred.

Legal basis

Explicit consent of the data subject