Privacy Policy

Information on the processing of personal data. Effective from 25/07/2024

INTRODUCTION – This policy takes into account the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) and the Privacy Code (Legislative Decree 30 June 2003 No. 196). This document has also been drafted based on the Guidelines of the Italian Data Protection Authority (especially the Guidelines for combating spam issued by the Data Protection Authority on 4 July 2013).

Data Controller: Simone Negri

The website to which this privacy policy refers is www.globalsolutioncar.com (Website).

The Data Controller has not appointed a DPO (Data Protection Officer). Therefore, you can send any request for information directly to the Data Controller.

GENERAL INFORMATION

This document describes how the Data Controller processes your data provided on the Website. The primary processing of your data is described below. In particular, the legal basis for the processing is explained, whether the provision of data is mandatory, and the consequences of failure to provide personal data. To better describe your rights, where necessary, we have specified if and when certain personal data processing is not carried out. On the Website, you can enter the personal data of third parties. In this case, you guarantee that you have obtained consent from these individuals to enter their data. Therefore, you agree to indemnify and hold the Data Controller harmless from any liability.

Registration on the Website – The Website does not offer the possibility of registration. Therefore, the Data Controller does not process your data for this purpose.

Purchases on the Website – It is not possible to make purchases on the Website. Therefore, your data will not be processed for this purpose. The Data Controller does not process user data to send “reminder” emails for the purchase of products and/or services of the Data Controller itself.

Responding to Your Requests – Your data will be processed to respond to your requests for information. The provision of data is optional, but your refusal will make it impossible for the Data Controller to answer your questions. The legal basis for the processing is the legitimate interest of the Data Controller in following up on user requests. This legitimate interest is equivalent to the user’s interest in receiving a response to communications sent to the Data Controller.

General Marketing – The Data Controller will not send you advertising material and/or newsletters relating to its products or those of third parties.

Profiling – The Data Controller does not carry out “profiling” with your data. Therefore, it will not send you advertising material and/or newsletters relating to its products or those of third parties that are of specific interest to you.

Data Transfer – The Data Controller does not transfer your data to third parties.

Geolocation – The Website does not implement tools for geolocating the user’s IP address.

Curriculum Vitae – It is not possible to send curriculum vitae through the Website. Therefore, your data will not be processed for these purposes.

Appointment Booking – There are no third-party systems active on the Website for booking appointments with the Data Controller. Therefore, your data will not be processed for this purpose. In any case, you can always contact the Data Controller at the contact details indicated in the introduction.

Photographs and Videos – The Data Controller does not request the publication of photographs and/or videos depicting you. Therefore, your data will not be processed for these purposes.15

Web scraping – The use of any automated process or system to access, acquire, copy, or monitor any part of our website, including but not limited to web scraping, crawling, or spidering techniques, is expressly prohibited. The Data Controller reserves the right to take all necessary measures, including legal action, to prevent and prosecute any unauthorized scraping activity. By using the Website, the user or any third party agrees not to: (i) use automated systems, such as bots, scrapers, or spiders, to access or interact with the Website; (ii) collect content, data, or other information present on the Website without explicit written authorization; (iii) distribute, display, publish, or otherwise use the content acquired through scraping techniques without consent. Any violation of this clause will be considered a substantial breach of the Website’s terms of use and will result in the adoption of appropriate measures, including the possible suspension of access to the website and the initiation of legal actions to protect the interests of the Data Controller.

Communication of Personal Data – In the course of its ordinary business, the Data Controller may communicate your data to certain categories of subjects. In Article 2, you can find the list of subjects to whom the Data Controller communicates your data. To facilitate the protection of your rights, Article 2 may specify in some cases when your data is not communicated to third parties.

The “communication” of personal data to third parties is different from “transfer” (governed in the preceding point). In fact, in communication, the third party to whom the data is transmitted can only use it for the specific purposes described in the relationship with the Data Controller. In the transfer, however, the third party becomes an independent Data Controller of the personal data. Furthermore, your consent is always required to transfer your data to third parties.

Without prejudice to the foregoing, it is understood that the Data Controller may still use your data to correctly fulfill the obligations provided for by current laws.

SPECIFIC PRIVACY INFORMATION

Art. 1 Processing Methods

1.1 The processing of your data will mainly be carried out with the aid of electronic22 or otherwise automated means, according to methods and with tools suitable for guaranteeing the security and confidentiality of personal data.

1.2 The information acquired and the methods of processing will be relevant and not excessive with respect24 to the type of services rendered. Your data will also be managed and protected in secure IT environments suitable for the circumstances.

1.3 “Special categories of personal data” are not processed through the Website. Special categories of personal data are those that may reveal racial or ethnic origin; religious, philosophical or other beliefs; political opinions; membership of parties, trade unions, associations or organizations of a religious, philosophical, political or trade union nature; health status or sex life.

1.4 Judicial data is not processed through the Website.

Art. 2 Communication of Personal Data

The Data Controller may communicate your data to specific categories of subjects. Below are indicated the subjects to whom the Data Controller reserves the right to communicate your data:

  • The Data Controller may communicate your data to all those subjects (including Public Authorities) who have access to personal data by regulatory or administrative provisions.
  • Your personal data may also be communicated to all those public and/or private subjects, natural and/or legal persons (legal, administrative and tax consultancy firms, Judicial Offices, Chambers of Commerce, Labor Offices, etc.), if the communication is necessary or functional for the correct fulfillment of obligations arising from the law.
  • In its ordinary activity of managing the Website, the Data Controller may use companies, consultants or professionals in charge of the installation, maintenance, updating and, in general, the management of the hardware and software of the Data Controller or used by the latter for the provision of its services. Therefore, only regarding these purposes may your data also be processed by these subjects.
  • The Data Controller does not use CRM platforms (companies that specifically carry out the activity of sending automated communications to users). Therefore, your data is not communicated to these companies.

The Data Controller reserves the right to modify the above list based on its ordinary operations. Therefore, you are invited to regularly access this policy to check to which subjects the Data Controller communicates your data.

Art. 3 Retention of Personal Data

3.1 This article describes how long the Data Controller reserves the right to retain your data.

  • For marketing purposes, personal data will be kept until the possible withdrawal of consent. For inactive users, personal data will be deleted one year after the sending of the last email possibly viewed.

3.2 Without prejudice to Article 3.1, the Data Controller may retain your data for the time required by specific regulations, as amended37 from time to time.

Art. 4 Transfer of Personal Data

4.1 The Data Controller is based in a country that has an adequate level of security from a regulatory point of view. If the transfer of your data takes place to a non-EU country for which the European Commission has expressed an adequacy judgment, the transfer is, in any case, considered secure from a regulatory point of view. This Article 4.1 indicates from time to time the countries to which your data may be transferred and where the European Commission has expressed an adequacy judgment.

Therefore, the user is invited to regularly access this article to verify if the transfer of their data takes place in a country with these characteristics.

4.2 Without prejudice to Article 4.1, your data may also be transferred to non-EU countries for which the European Commission has not expressed an adequacy judgment. You are therefore invited to regularly view this Article 4.2 to ascertain in which of these countries your data is possibly transferred.

4.3 In this article, the Data Controller indicates the countries in which it specifically directs its activities. This circumstance may imply the application of the regulations of the reference country, together with those governing the relationship with the user based on what is indicated in the Introduction.

At the user’s request, the Data Controller will apply to the processing of personal data the possibly more favorable regulations provided for by the user’s national legislation.

Art. 5. Rights of the Data Subject

The Data Controller informs you that you have the right to:

  • request from the Data Controller access to your data and the rectification or erasure thereof or the restriction of processing concerning you or to object to their processing, as well as the right to data portability;
  • withdraw consent at any time without prejudice to the lawfulness of processing based on consent before its withdrawal;
  • lodge a complaint with a supervisory authority.

The aforementioned rights may be exercised by requesting, without formalities, the contact details indicated in the Introduction.

Art. 6. Amendments and Miscellaneous

The Data Controller reserves the right to make changes to this policy at any time, giving appropriate publicity to users of the Website and in any case guaranteeing adequate and similar protection of personal data. In order to view any changes, you are invited to consult this policy regularly.. In the event of substantial changes to this privacy policy, the Data Controller may also notify you by email.