Privacy policy

Information for potential customers pursuant to Regulation (EU) 2016/679 GDPR

Dear User:
Gemavip S.r.l., the Data Controller, wishes to provide you with a description of the characteristics of the processing of your personal data by us. The processing will take place in compliance with Regulation (EU) 2016/679 General Data Protection Regulation and Legislative Decree [Italian] no. 196/2003 Personal Data Protection Code.
We would like to remind you that personal data is “any information relating to an identified or identifiable natural person”; processing is “any operation or set of operations, performed with or without the aid of automated processes and applied to personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication through transmission, dissemination or otherwise availability, comparison or interconnection, limitation, erasure or destruction”.
 

  1. Identity and Contact Details of the Data Controller

    2. The Data Controller is Gemavip S.r.l., with registered office in Via Sernagiotto n. 7/7A, 09067 – Elmas (CA), VAT ID. 03853410920, Ph. +39 0702506058, Email info@gemavip.com, Certified Email gemavipsrl@legalmail.it.

  2. Source and Nature of Personal Data

    3. This information is drawn up because you have expressed your interest in receiving promotional offers on our products, upon your request to be contacted by our Company or by individuals appointed as Data Processors, for direct marketing purposes via telephone by an operator or text message, or by personnel in charge of promoting our services, as further specified in paragraph c) below.
    You will be contacted as soon as possible as you have provided your personal data (i.e. personal and contact details) now included in the contact lists used by the Company or by one of the external suppliers to whom we entrust our advertising and promotional campaigns. You may also be contacted:

    • as your number is included in the lists of contractors available to the public and so far, you have not exercised the right to object to receiving advertising or direct sales material; or
    • based on the consent you provided directly to the Company (e.g. by using the contact form on our website or presented to you by the staff responsible for promoting our services); or
    • based on an extended consent to the receipt of promotional communications from third parties given by you to a supplier external to our Company

  3. Purpose and Legal Basis of the Processing of Personal Data

    4. Your personal data will be processed in compliance with the law and exclusively for the following purposes:

    1. Legal obligations: fulfillment of legal, regulatory and community legislation obligations relating to pre-contractual and contractual relationship (e.g. regarding consumer protection, and so on);
    2. Marketing: sending commercial and promotional communication relating to promotions, offers and products of the Company and participation in market research. This activity may be carried out using automated means (such as newsletters, emails, telephone contact without the intervention of an operator, text messages, WhatsApp, instant messages, communications and posts on social networks, and so on) and non-automated means (such as paperbased mail and/or calls from an operator).

    The processing of your personal data for the purposes under a) is necessary for the execution of pre-contractual or contractual measures, such as credit worthiness.
    The processing of your personal data for the purposes under b) is optional and occurs on the basis of your specific consent given directly to the Company or to external suppliers. You may decide at any time, even subsequently, to revoke your consent by sending a specific communication to the contacts details below.

  4. Recipients of your Personal Data

    5. Within the scope of the purposes indicated above, your personal data may be disclosed to third parties such as: Authorities and Public Bodies, Supervisory and Control Bodies; professional advisors regarding taxation, legal or accounting matters and subjects who provide technical and organizational services relating to the assistance and management of the Company’s customers. You may at any time request the details of the service providers appointed by the Company as Data Processors pursuant to art. 28 of the GDPR.
    Your personal data will be processed by personnel in charge and authorized by the Company to process this information pursuant to art. 29 of the GDPR.

  5. Transfers to a Third Country Outside EU

    6. For the purposes mentioned above, your personal data will not be transferred to countries outside the European Union.

  6. Methods of Personal Data Processing

    7. In relation to the above-mentioned purposes, your personal data processing will take place with the support of paper, computer or digital means, in compliance with current legislation, in order to guarantee their security and confidentiality and prevent their unauthorized disclosure or use, alteration or destruction.
    Your personal data will also be processed in compliance with the provisions of art. 130 of the [Italian] Code by the Provision of the Guarantor no. 330 of 04.07.2013 “Guidelines on promotional activities and the fight against spam” and by the Provision of the Guarantor no. 16 of 19.01.2011 “Requirements for the processing of personal data for marketing purposes, through telephone with and operator, following the establishment of the public register of objections”.

  7. Storage Period of Time of Personal Data

    8. In the context of the purposes indicated above, your personal data will be retained for the time necessary to fulfill the contract and the legal obligations, or in the event that you have not terminated a contract with the Company for direct marketing purposes only.
    In the first case, your personal data will be retained for a further 10 years from the termination of the contractual relationship, or in its absence for a period not exceeding 2 years from your expression of interest, without prejudice to revocation of consent or your opposition to processing for direct marketing purposes.

  8. Rights Pursuant art. 15 et seq. of the Regulation

    9. By sending a communication to the email address privacy@gemavip.com you may exercise the rights referred to in articles 15 to 22 of the Regulation, including, in summary, those of:

    • obtain confirmation as to whether or not your personal data is being processed;
    • obtain access to your personal data and the information referred to in art. 15 of the Regulation;
    • rectification of inaccurate personal data, the erasure, the limitation of the processing of your personal data;
    • receive your personal data in a structured, commonly used and machine-readable format;
    • withdraw your consent to the processing provided at any time and oppose our direct marketing activities. You can find the complete list of your rights at www.garanteprivacy.it.

  9. Complaint with the Data Protection Supervisor

    10. We remind you that, if you believe that the processing carried out by us violates the provisions of the Regulation, you can always lodge a complaint with the Authority for the protection of personal data (www.garanteprivacy.it), or to the Authority of the country in which you habitually reside, work or the place where the alleged violation occurred

  10. Data Protection Officer (DPO)

    11. The Data Protection Officer designated by the Company pursuant to art. 37 of the Regulation can be contacted at the following email address dpo@gemavip.com.