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Information on processing of personal data
pursuant to Art. 13 EU Regulation 679/2016
Gabel Industria Tessile s.p.a. guarantees its users that the processing of their personal data will be reserved for uses strictly connected and related to the provision of its services, the facilitation of site management and the processing of orders. The data voluntarily provided by customers will in no case be communicated, diffused or transferred to third parties without your express consent.
Pursuant to art. 13 of EU Regulation 679/2016 (hereinafter also referred to only as "EU Reg. 679/2016") on the protection of persons regarding the processing of personal data, we hereby set out the methods and principles underlying the processing of personal data adopted by GABEL Industria Tessile s.p.a..
1. Data Controller
The data controller of personal information is GABEL Industria tessile s.p.a., with head office in Rovellasca via XX Settembre 35, CF and VAT no. 00185790185, in the person of its legal representative pro tempore (telephone: 02964771 - email: firstname.lastname@example.org).
The list of data processors and any authorised persons is kept at the data controller's head office and made available upon request by the data subject.
2. Personal data subject to processing
Gabel Industria Tessile s.p.a. may collect the following categories of personal data for the purposes described in this information notice:
a) Browsing data: the IT systems and computer programmes used to operate the www.somma1867.com website of GABEL Industria Tessile s.p.a. collect certain personal data, listed below, the transmission of which is implicit in the use of normal Internet communication protocols
- IP addresses or domain of the computers/devices used by users;
- the URI (Uniform Resource Identifier) addresses of the resources requested;
- time of the request;
- method used to submit the request to the server;
- the size of the file obtained in response and the numerical code regarding the status of the response returned by the server - successful, error, etc;
- the browser being used and other parameters relating to the user's operating system and computer environment;
- as well as data and information about the way browsing the site is carried out, such as information relating to completed or partially completed purchases (e.g. product categories visited, products placed in the shopping cart, purchase not completed, etc.). Although this information is not collected in order to be associated with identified data subjects, by its nature it could, through processing and association with data held by third parties, allow users to be identified.
b) Data provided voluntarily by the user: as regards use and consultation of the www.somma1867.com website, please note that no personal data is required from the user. However, any contact with GABEL Industria Tessile s.p.a., through the customer care service, or the optional, express and voluntary sending of e-mail or ordinary correspondence to the GABEL Industria Tessile s.p.a. addresses indicated on the web site, entails the subsequent acquisition of the sender's address, including e-mail address, or relative telephone number, necessary for replying to requests, as well as any other personal data included in the relative communications. This data will be used solely for the purpose of responding to the user's request and may be disclosed to third parties only if necessary for this purpose. This category of data therefore includes the personal data, listed below, spontaneously provided by the data subject to the Data Controller when creating a customer account, completing a purchase on the web site (with or without creating an account), participating in the fidelity programme, establishing business contacts, visiting GABEL Industria Tessile s.p.a. offices, meetings, events, trade fairs, or provided by e-mail, post or other communication tools, and specifically:
- personal and identification data provided when creating an account on the GABEL Industria Tessile s.p.a. website/application, such as first name, last name, email address;
- personal, identifying and contact data provided when completing a purchase on the GABEL Industria Tessile s.p.a. website/application or when making a return or refund request, such as email address, first name, last name, billing and delivery address, telephone number, billing and payment data, company and VAT number;
- personal, identification, demographic and contact data provided in connection with participation in the GABEL Industria Tessile s.p.a. fidelity programme, such as: name, surname, billing and delivery address, date of birth, gender, presence of children and children's age group, email address, telephone number
- personal, identification, demographic and contact data provided for the purpose of sending commercial communications, such as: first name, last name, billing and delivery address, date of birth, gender, presence of children and children's age range, email address, telephone number;
- personal and contact data provided when contacting customer service, also for the purposes of issues relating to orders placed, such as name, surname, date of birth, any Gabel fidelity card number or customer number, address telephone number, email address, any further data provided in order to allow GABEL Industria Tessile s.p.a. to process your request
- personal data provided for the purpose of requesting the dispatch of informative material or other communications, such as name, surname, e-mail address, telephone number and any other data communicated in order to allow GABEL Industria Tessile s.p.a. to process your request;
- preferences and interests that you have chosen to disclose (including, by way of example, preferences regarding our products)
- information that you have disclosed or published in a public place, on GABEL Industria Tessile s.p.a.'s social pages or websites, such as ratings given to a product or product reviews
- information relating to purchases made online (these include the products purchased and their price)
- information contained in the curriculum vitae sent spontaneously by the candidate or in response to an open application, such as first name, surname, residence, fiscal code, educational qualifications, e-mail and telephone numbers.
3. Purposes of the processing
More specifically, your personal data are processed for the following purposes
- as regards browsing data: these data are not subject to automated processing (profiling) and are used solely for the purpose of obtaining statistical information not associated with any user identification data on the use of the site and to check its correct operation and are deleted immediately after processing. The data could also be used to ascertain responsibility in the event of hypothetical computer crimes to the detriment of the Site;
- as regards the data provided when creating an account on the GABEL Industria Tessile s.p.a. web site/application: management of registration on the GABEL Industria Tessile s.p.a. web site/application
- as regards data provided during the conclusion of a contract with GABEL Industria Tessile s.p.a.: fulfilment of pre-contractual and contractual obligations relating to the conclusion, termination, of the existing contract performed on the GABEL Industria Tessile s.p.a. web site/application with or without the creation of a customer account, fulfilment of payment management and related invoicing obligations, fulfilment of orders and product delivery
- with regard to data provided in connection with participation in the GABEL Industria Tessile s.p.a. fidelity programme: management of the issue of the Gabel fidelity card, use of the relative services, collection of points as well as special reserved initiatives; statistical and market research purposes; marketing, i.e. sending of promotional commercial communications and/or advertising or informative material about discounts, offers, or events of GABEL Industria Tessile s.p.a. or third parties by means of automated contact methods (via e-mail and sms) or by means of promotional telephone calls; profiling purposes in order to improve the commercial offer and the services proposed, to send information requests or to carry out surveys to determine the degree of satisfaction with the quality of the services offered;
- with regard to the data provided for the purpose of forwarding commercial communications: marketing, i.e. sending promotional commercial communications and/or advertising or informative material (discounts, offers, or events) from GABEL Industria Tessile s.p.a. or third parties by means of automated contact methods (via e-mail and sms) or by means of promotional telephone calls, subject to your consent. We would like to inform you that as a customer or supplier, we may send you commercial communications relating to products and services of the Controller similar to those you have already used, unless you disagree (art. 130 c. 4 Privacy Code). In any case, we inform you that you may object to any future sending of such communications by sending a request to email@example.com;
- compliance with the obligations provided for by law, regulations, Community legislation or an order from the Authority (such as anti-money laundering)
- exercise of the Controller's rights, in judicial, extrajudicial or administrative proceedings;
- replying to requests for information received through the GABEL Industria Tessile s.p.a. web site, including those received through the customer service, as well as sending information material or other communications, including those relating to information on changes to the site, updates to services, and requests for feedback on the terms of the web service offered;
- preventing counterfeiting and combating illegal resale channels of Gabel Industria Tessile s.p.a.'s products
- for legal, administrative or auditing purposes;
- understanding your interests, expectations and how you use our products. We may use that information to improve our websites, apps, and products/services. We use your information to personalise your experience and tailor our marketing activities to your needs and interests, as we believe it is also in our legitimate interest to serve you as well as possible and to respond to your needs;
- sending you a CV and submitting your application either spontaneously or in response to an open position.
4. Legal basis
Pursuant to Article 6 of EU Reg. 679/2016, the conditions of lawfulness (legal basis) for the processing of your personal data processed by GABEL Industria Tessile s.p.a. are as follows:
- for processing relating to browsing data: the need to execute the contract or pre-contractual measures, in compliance with Article 6(1)(b) EU Reg. 679/2016 and the legitimate interest of the data controller in accordance with Article 6(1)(b) EU Reg. 679/2016;
- for the processing operations related to the creation of an account on the website/application of GABEL Industria Tessile s.p.a.: necessity of the performance of the contract, in compliance with Article 6(1)(b), Reg. UE 679/2016;
- for processing relating to e-commerce activities and the conclusion of a contract with GABEL Industria Tessile s.p.a.: necessity of performance of the contract, in compliance with Article 6(1)(b) of EU Reg. 679/2016;
- for processing relating to participation in the fidelity programme: need to execute the contract, in compliance with article 6, (1)(b), Reg. UE 679/2016 as regards the issue of the fidelity card; your consent, in compliance with article 6, (1)(a), Reg. UE 679/2016 as regards the purposes of promotional communications and profiling
- for the fulfilment of the activity of responding to requests for information, for profiling and marketing purposes: your consent, in compliance with Article 6(1)(a) and Art. 7) EU Reg. 679/2016;
- for the processing of personal data contained in CVs: performance of activities necessary for the execution of pre-contractual measures taken at your request in compliance with Article 6(1)(b) EU Reg. 679/2016.
The provision of data for the purposes of concluding a contract is a necessary requirement for the conclusion and execution of the contract. In the event of refusal to provide the data, the purchase order cannot be processed, the contract cannot be executed by GABEL Industria Tessile s.p.a., the products cannot be delivered and the related payments cannot be managed.
On the contrary, the provision of data for further purposes is optional. You may therefore decide not to provide any data or to deny the possibility to process data already provided, in which case you will not be able to: create a customer account, take advantage of GABEL Industria Tessile s.p.a.'s fidelity programmes, receive newsletters, be informed about promotional communications from GABEL Industria Tessile s.p.a. or third party companies, and receive commercial communications and/or advertising content that may be of interest to you. In such cases, you will still be entitled to e-commerce services.
Consent to processing for the purpose of joining the loyalty programme does not also cover the different and further processing of direct marketing, and in order to proceed for this purpose you need to acquire a further, documented, separately expressed and optional consent. At the same time, any failure to provide data relating to direct marketing and profiling activities does not preclude the activation of the Gabel fidelity card.
5. Methods of personal data processing
In relation to the purposes described above, personal data are processed by manual, computerised and telematic means, in any case, in such a way as to guarantee the security and confidentiality of the data. Data may be collected, recorded, stored, organised, processed, profiled for organisational purposes, selected, extracted, compared, interconnected, communicated, blocked, deleted, destroyed, including the combination of two or more of the above activities.
6. Period of retention of personal data
Your personal data will be stored as follows
- browsing data: for the time strictly necessary for processing and will then be deleted immediately;
- personal, contact and payment data: for the period of time necessary to execute the contract or to process the submitted request and, subsequently, for a period not exceeding the statute of limitations provided for by the applicable legislation (in particular, ten years for the retention period of contractual and fiscal documentation in compliance with the legal provisions provided for administrative and fiscal obligations as well as for the retention of business correspondence) in order to possibly assert or defend a right in court against you or against a third party
- account creation data: for the duration of your registration on the GABEL Industria Tessile s.p.a. website/application and thereafter for a period not exceeding the limitation period laid down by applicable law, in order to assert or defend a legal claim against you or a third party;
- data relating to participation in the fidelity programme (management of fidelity card issuance and use of related services): for as long as you are a participant in the fidelity programme and thereafter for a period not exceeding the period of limitation provided for by the applicable legislation in order to assert or defend a legal claim against you or against a third party;
- data relating to participation in the fidelity programme (sending of promotional communications, profiling): until you revoke your consent to receive commercial communications from GABEL Industria Tessile s.p.a. or you revoke your consent to preference profiling activities, or you request the deletion of your data, except for the exceptional need to keep your data in order to defend GABEL Industria Tessile s.p.a.'s rights in relation to disputes pending at the time of your request, or at the request of public authorities. It should be noted that, regardless of your revocation of consent or your possible request for deletion: data relating to purchase history processed by GABEL Industria Tessile s.p.a. for marketing purposes (sending commercial communications) will be deleted 4 years after their registration; data collected and processed by GABEL Industria Tessile s.p.a. for profiling purposes will be transformed into anonymous form 12 months after their registration;
- data for marketing purposes: no later than 4 years from the collection of the data or from the last update of the relative data; if the data is not updated within the aforementioned period, it will be deleted from our archives. Subsequently, the data will be retained for a period not exceeding the limitation period provided for by the applicable legislation in order to possibly assert or defend a legal claim against you or against a third party;
- data relating to profiling activities: for 12 months after their recording and thereafter for a period not exceeding the limitation period provided for by the applicable legislation in order to assert or defend a legal claim against you or a third party. After 12 months have elapsed, such data will be anonymised;
- with regard to the personal data contained in CVs: for a period of not more than 45 days from the sending of the same, unless you have updated the same. In any case, GABEL Industria Tessile s.p.a. will provide for the deletion of the data once the position or the selection phase has been completed;
- in any case, the data will be stored for the entire duration of any extrajudicial and/or judicial proceedings, until the time limit for judicial protection and/or appeal actions has expired. Once the aforementioned retention periods have expired, the data will be deleted.
7. Recipients of personal data
Your personal data may be communicated to:
- authorised and responsible individuals pursuant to art. 28 EU Reg. 679/2016;
- specialised companies that provide processing or instrumental services (e.g. consumer services, IT services for the operation of the site) on behalf of GABEL Industria Tessile s.p.a., their employees and collaborators, as authorised or responsible persons
- professionals or service companies for company administration and management who work on behalf of GABEL Industria Tessile S.p.a;
- online payment service companies;
- transport companies for goods shipment;
- financial administrations, public bodies, judicial authorities and law enforcement agencies;
- third parties exclusively for accounting, tax, legal or insurance purposes or in the event of police checks or if required by law.
It should be noted, in particular, that such data will not be disseminated and will be processed by persons duly appointed for the performance of such tasks, constantly identified and/or appointed, duly instructed and made aware of the constraints imposed by law, as well as through the use of security measures to ensure the protection of its confidentiality and to avoid the risks of loss or destruction, unauthorised access, unauthorised processing or processing that does not comply with the purposes referred to above.
8. Possibility of transfer of personal data to third countries
Your personal data will not be transferred to third countries outside the European Union.
9. Rights of the data subject and complaint procedures
Please note that, with reference to the personal data provided, you have the following rights pursuant to Articles 15 to 22 of EU Reg. 679/2016, (all compatible with the purposes of the processing itself):
a) to obtain the cessation of processing in cases where your personal data are treated for direct marketing purposes, including in relation to services identical to those already provided by GABEL Industria Tessile s.p.a., or are processed for the legitimate interest of GABEL Industria Tessile s.p.a. and you contest the existence of this interest (so-called right to object);
b) to obtain information in relation to the purposes for which the personal data are processed, the period of processing and the persons to whom the data are communicated (so-called right of access)
c) obtain the rectification or integration of inaccurate personal data concerning you (so-called right of rectification);
d) obtain the deletion of personal data concerning you in the following cases: (i) the data is no longer necessary for the purposes for which it was collected; (ii) you have withdrawn your consent to the processing of the data where it is processed on the basis of your consent; (iii) you have objected to the processing of personal data concerning you where it is processed for our legitimate interest; or (iv) the processing of your personal data does not comply with the law.
However, we point out that the storage of your personal data by GABEL Industria Tessile s.p.a. is lawful if it is necessary to allow you to fulfil a legal obligation or in order to establish, exercise or defend a right in court (so-called right of erasure);
e) obtain that personal data concerning you are only stored without any other use being made of them in the following cases (i) you contest the accuracy of the personal data, for the period necessary to allow us to verify the accuracy of such personal data; (ii) the processing is unlawful but you nevertheless object to the deletion of the personal data by us; (iii) the personal data are necessary for the establishment, exercise or defence of a legal claim; (iv) you objected to the processing and are awaiting verification as to whether our legitimate reasons for processing outweigh yours (so-called right of restriction);
f) receive in a commonly used, machine-readable and interoperable format the personal data concerning you, if they are processed pursuant to a contract or on the basis of your consent (so called right of portability).
To exercise these rights, you may send a request by contacting GABEL Industria Tessile s.p.a. at the following e-mail address: firstname.lastname@example.org. When contacting the Data Controller, you should make sure to include your name, email address, postal address and/or telephone number(s), as well as a copy of a valid ID document, in order to ensure that the Data Controller can correctly handle your request. GABEL Industria Tessile s.p.a. is obliged to provide a reply within one month from the request; this term may be extended up to three months in case of particular complexity of the request.