This privacy policy (hereinafter, "Privacy Policy") relates to the website www.galletti.it, including the areas dedicated to and reserved for registered users (hereinafter, the "Website"), and outlines the activities and methods of processing personal data carried out by Galletti S.p.A. (hereinafter, "Galletti") through the Website, which is owned and registered by Galletti S.p.A.
Galletti recognises the importance of its users' privacy and is committed to respecting it. Galletti processes users' personal data ("Personal Data") when they visit the Website and use the available services and features. This Privacy Policy has been drawn up in accordance with the General Data Protection Regulation No. 679/2016 ("GDPR"). The Privacy Policy specifies who the data controller is and who is responsible for controlling and managing the Personal Data collected and processed via the Website. It also specifies what personal information is collected, for what purposes and by what means the Personal Data is processed, the scope of disclosure to third parties and any transfer abroad, the security measures adopted to protect and safeguard such data and the procedures by which users can verify the processing of data concerning them and exercise the rights recognised by the Privacy Regulations.
This Privacy Policy applies solely to this Website and to the activities carried out and services provided by Galletti and its data processors. It does not apply to other websites that users may access via links, nor to the activities of third parties. If you visit other websites, we recommend consulting their respective privacy policies.
1. TYPES OF DATA PROCESSED
1.1 Browsing data
Visiting and browsing the Website does not generally involve the collection or processing of users' Personal Data. The processing of Personal Data of users who visit and browse the Website is limited to what is known as browsing data. The transmission of this data is necessary for operating the Website's IT systems and programmes, but, by its very nature, it could allow users to be identified if combined with other data. This category includes, for example, the IP (Internet Protocol) addresses and domain names of the computers used to visit the Website, as well as other parameters relating to the operating systems used by users to connect to the Website. Browsing data is collected automatically and cannot be avoided. Such data may be used solely to compile statistical information on Website usage and to verify that the Website is functioning correctly. Where expressly required, such data may be used by public authorities to determine liability for cybercrimes committed against the Website and/or third parties, in accordance with the competent authorities' procedures. In all other cases, the browsing data described above is stored only temporarily, in accordance with applicable legislation.
1.2 Data provided voluntarily by individual users
Galletti also collects and processes Personal Data provided voluntarily by individual users. This consists of data collected when e-mails are sent, when users interact with the Website's features, when services offered by the Website are requested, when CVs are submitted, and when other specific forms are completed in order to access restricted sections of the Website. The Personal Data collected and processed by Galletti includes name, gender, place and date of birth, nationality, and contact details such as addresses, telephone numbers, and e-mail addresses, as well as any other information contained in CVs.
2. METHODS AND PURPOSES OF DATA PROCESSING
Data will be processed both manually and electronically for the following purposes: to respond to and manage users’ requests for information and/or materials, as well as their queries, communications and feedback; to provide services requested via the Website, including registration and subsequent updates, by sending price-sensitive notices, presentations, interim reports and annual reports, and to manage initiatives organised through the Website; and to carry out recruitment and staff selection activities.
In addition to the purposes related to operating the Website, Galletti may use the Personal Data collected for the purposes of, or in connection with, the following services:
Payment details
Fraud prevention management
Website registration management
Newsletter and mailing list management
Product purchase management
Customer support and product service
Customer feedback
Creation of individual profiles
Contacting the user
Interaction with social networks and external platforms
Statistics
Marketing and commercial purposes
Cookie Policy
Legal basis for processing
Galletti will process the User’s Personal Data if any of the following conditions apply:
- the User has given consent for one or more specific purposes;
- the processing is necessary for the performance of a contract with the User and/or for the implementation of pre-contractual measures;
- the processing is necessary to comply with a legal obligation to which the Data Controller is subject;
- the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;
- the processing is necessary for the purposes of the legitimate interests of the Data Controller or of a third party.
However, you can always ask the Data Controller to clarify the specific legal basis for each processing operation.
Retention period
Personal Data will be retained for a period no longer than is necessary to fulfil the purposes for which it was collected, and in any case for no longer than ten years.
Personal Data submitted for recruitment purposes will be retained for a period not exceeding 18 months.
The Personal Data will be deleted at the end of the retention period. Consequently, the rights of access, erasure, rectification and data portability will no longer be exercisable upon expiry of this period.
3. NATURE OF THE PROVISION OF DATA
Providing Personal Data for the purposes referred to in point 2 above is necessary for Galletti to be able to respond to information requests and to provide the services requested via the Website, including registration. If Personal Data is not provided for the purposes referred to in point 2, Galletti will not be able to respond to requests for information or provide the services requested via the Website.
4. DISCLOSURE OF DATA
Personal Data may be accessed by the Data Processor indicated below and by other parties acting as external Data Processors appointed by Galletti. In their capacity as data processors, Galletti staff involved in providing the services and features offered by Galletti from time to time may also access Personal Data, in accordance with the principle of necessity and for the purposes set out in point 2 ("Methods and purposes of data processing"), as may the parent company Galletti S.p.A., its subsidiary Cetra S.r.l., and the subsidiaries and affiliated companies of HiRef S.p.A. (Eneren S.r.l., HiDew S.r.l., Tecno Refrigeration S.r.l. and Jonix S.r.l.).
Personal Data may be disclosed to bodies, authorities and public institutions, as well as to other legitimate recipients, in compliance with laws and regulations, and as required by law. It may be made available to professionals and self-employed collaborators, whether organised as a group or otherwise, as well as to third-party suppliers of the professional and technical services necessary for the processing purposes set out in point 2 above, who assist Galletti with legal, tax, social security, accounting and/or organisational matters. These parties will act as Data Processors or Persons in Charge of Data Processing, as appropriate, provided that they adopt security and protection criteria for Personal Data in line with current legislation.
Personal Data may also be disclosed to third parties in the event of extraordinary operations carried out by Galletti, such as mergers, acquisitions or business transfers. These parties will only be given the information necessary for them to carry out their respective functions. These third parties undertake to use the information received solely for the above specified processing purposes, to keep it confidential and secure, and to comply with applicable Personal Data protection legislation and any instructions issued by Galletti.
Personal Data may be transferred outside the country, including to entities based in countries outside the European Union (i.e. companies that form part of the sales and distribution network, including those outside the EU), where an adequate level of protection under Privacy Regulations may not be guaranteed. In such cases, Galletti will transfer Personal Data to third countries only after implementing the measures set out in Articles 44 et seq. of the GDPR, in order to ensure the lawfulness of the transfer and guarantee an adequate level of protection for the Personal Data transferred.
Personal Data will not be disseminated under any circumstances.
5. AUTOMATIC DATA COLLECTION MECHANISMS – COOKIES
The Website uses cookies and other technologies to read and/or store information on users' devices. For a detailed description of these technologies, please refer to the Cookie Policy, which is reproduced in full at http://www.galletti.com/contatti/cookies.
6. RIGHTS OF THE DATA SUBJECT
Users may exercise the rights set out in Articles 15-22 of the GDPR at any time. These rights include the right to obtain confirmation as to whether Personal Data concerning them exists; to verify its content, origin and accuracy; and to request that it be completed, updated, rectified, erased, anonymised or transferred. Users may object to the processing of their personal data in whole or in part, or request that it be restricted, on legitimate grounds.
For any questions or requests relating to the processing of their personal data, or to exercise their rights under the GDPR, users can contact Galletti via the following e-mail address: privacy@galletti.it
7. UPDATES AND CHANGES TO THE PRIVACY POLICY
The Privacy Policy may be changed or updated from time to time. The version currently in force is the one published on the Website. Any changes to the Privacy Policy will be communicated via publication on the Website. Please check the Privacy Policy periodically to stay informed about any changes.
8. DATA CONTROLLER
The Data Controller is Galletti S.p.A., whose registered office is located at Via Luciano Romagnoli 12, 40010 Bentivoglio (BO). The company can be contacted at the following e-mail address: privacy@galletti.it and telephone number: +39 051.8908111.
9. DATA PROTECTION OFFICER
The Data Protection Officer (DPO) is Mr. Giorgio Sbaraglia. He was appointed by the Data Controller in accordance with Articles 37 et seq. of Regulation (EU) 2016/679 (GDPR).
You can contact the Data Protection Officer (DPO) at the following e-mail address: dpo@galletti.it