Privacy policy

Privacy notice in accordance with articles no. 13 and 14 of the data protection regulation (eu) 2016/679 – General Data Protection Regulation (GDPR)

1. DATA CONTROLLER

Guala Closures S.p.A., with registered office in via Rana 10/12, fraz. Spinetta Marengo, Alessandria (AL) – 15122, VAT no. 10038620968, e-mail privacy@gualaclosures.com, in the person of the legal representative pro-tempore.

2. TYPE OF DATA

Personal data means any information concerning an identified or identifiable natural person (data subject), in particular by reference to an identifier such as first name, surname, contact details, identity documents, location data, image, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic identity of that natural person, including educational attainment and professional experience – cf. Art. 4, para. 1, n. 1 GDPR.

Navigation data: the computer systems and software procedures used to operate this site acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.
This category of data includes the IP addresses or domain names of the computers and terminals used by users, the URI/URL (Uniform Resource Identifier/Locator) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, successful,  error, etc.) and other parameters related to the user's operating system and computer environment.

Data communicated voluntarily: the optional, explicit and voluntary sending of messages to the contact addresses indicated on this site and/or the compilation of data collection forms involves the subsequent acquisition of the sender's address, necessary to respond to requests, as well as any other personal data entered.

3. SPECIFIC DISCLOSURES

Specific information may be present on the pages of the Site in relation to particular services or data processing provided.

Cookies and other tracking systems. What are they? What are they for?

For cookies and other tracking systems, see the cookies policy in the footer of the site and at the following link.

4. PURPOSE OF THE PROCESSING, LEGAL BASIS, DATA RETENTION PERIOD, NATURE OF THE PROVISION

PURPOSE OF THE PROCESSING

Art. 13, par. 1, lett. c) of GDPR.

LEGAL BASIS

Art. 13, par. 1, lett. c) of GDPR.

RETENTION PERIOD

Art. 13, par. 2, lett. a) and c) of GDPR.

NATURE OF THE PROVISION

Art. 13, par. 2, Lett. a) and c) of GDPR.

(A)

Website navigation.

The data necessary for the use of web services are also processed for the purpose of:

  • obtain statistical information on the use of the services (most visited pages, number of visitors per time slot or day, geographical areas of origin, etc.);
  • check the correct functioning of the services offered.

Legitimate Interest.

The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, provided that the interests or fundamental rights and freedoms of the data subject which require the protection of personal data do not prevail, taking into account the reasonable expectations entertained by the data subject and the activities strictly necessary for the operation of the site and for navigation itself.

Art. 6, para. 1, lett. f) and C47 of GDPR

The browsing data will be stored for the duration of the browsing session.

Necessary.

The provision of data is necessary for browsing the website.
 (B)

Use of cookies and equivalent technologies.

See the cookies policy in the footer of the site.

Consent.

For necessary non-technical cookies and comparable technologies, the processing is based on consent to the processing of personal data.
Consent is given through the banner and the cookie policy of the site.

Art. 6 para. 1 lett. a) and C42, C43 of GDPR.

See the cookies policy in the footer of the site.

See the cookies policy in the footer of the site.

(C) Management of any contact and/or information requests through a dedicated form.

Pre-contractual measures.

The processing is necessary for the execution of pre-contractual measures adopted at the request of the data subject (C44).

Art. 6, para. 1, lett. b) of GDPR
1 year from the request.

Necessary.

The provision of data is necessary. Failure to provide data will make it impossible to follow up on the requests of the interested party.
(D)

Direct marketing for sending commercial and promotional information, invitations to events, newsletters, and market research, also with reference to promotional information from companies of the Data Controller's Group through automated marketing methods such as e-mail.

Consent.

For direct marketing purposes, the processing is based on consent to the processing of personal data.
Consent is given through the appropriate flag in the form for sending communications to the Data Controller both on the corporate website and on the landing pages specifically created for the individual marketing initiatives managed by the Data Controller.

Art. 6 para. 1 lett. a) and C42, C43 of GDPR.

Until consent is withdrawn.

You can revoke your consent at any time by writing to privacy@gualaclosures.com

The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Art. 7 para. 3 and C42, C43 of GDPR.

Optional.

The provision of data is optional. Failure to provide data will make it impossible to receive marketing communications from the Data Controller.
(E) Profiling of the data subject that is not fully automated aimed at creating homogeneous groups of subjects with specific interests and receiving communications and dedicated marketing initiatives (so-called “Targeted profiling marketing”).

Consent.

For profiling purposes aimed at targeted marketing, the processing is based on consent to the processing of personal data.

Consent is given through the appropriate flag in the form for sending communications to the Data Controller both on the corporate website and on the landing pages specifically created for the individual marketing initiatives managed by the Data Controller.

Until consent is withdrawn.

You can revoke your consent at any time by writing to privacy@gualaclosures.com

The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Art. 7 para. 3 and C42, C43 of GDPR.

Optional.

The provision of data is optional. Failure to provide the data will make it impossible for the Data Controller to use the data collected on the data subject to include him or her in homogeneous groups of interest aimed at receiving targeted marketing communications from the Data Controller.
 (F) Data subject rights management pursuant to Article 15 et seq. of the GDPR.

Legal obligation to which the Data Controller is subject.

Art. 6 lett. c) of GDPR
5 years from the closure of the request, except for litigation.

Necessary.

The provision of personal data is mandatory, as it is essential to be able to execute legal obligations.

5. RECIPIENTS OR CATEGORIES OF RECIPIENTS OF THE DATA

Personal data will not be disseminated and will also be communicated to recipients who will process them as independent data controllers or data processors (art. 28 GDPR) or to natural persons (art. 29 GDPR) acting under the authority of the Data Controller, or other data controllers and processors, on the basis of specific instructions provided regarding the purposes and methods of processing.

The data may be communicated to recipients belonging to the following categories:

  • entities that provide services for the management of the information system used by Guala Closures S.p.A. and the telecommunications networks;
  • freelancers, firms or companies in the context of assistance and consultancy relationships;
  • platform operators for the services listed above (e.g. site hosting);
  • competent authorities for the fulfilment of legal obligations and/or provisions of public bodies, upon request.

The complete list of Data Processors identified pursuant to article 28 of the GDPR is available by contacting the Data Controller at privacy@gualaclosures.com.

6. DATA TRANSFER TO THIRD COUNTRIES

Personal data processed for the purposes set out in this policy will not be transferred to countries located outside the European Economic Area. Should this occur, the Data Controller will notify it and comply with the criteria (transfer mechanisms) provided for by art. 45 et seq. GDPR.

7. AUTOMATED PROCESS

Personal data will be subjected to traditional, electronic and automated manual processing. Please note that fully automated decision-making processes are not carried out.

8. RIGHTS OF DATA SUBJECTS

The data subject may assert the rights as expressed by articles 15 et seq. GDPR, by contacting the Data Controller at the address privacy@gualaclosures.com.

The interested party has the right, at any time, to request access to his or her personal data (art.15), rectification (art.16), erasure (art.17), limitation of processing (art.18). The Data Controller notifies (art. 19) to each of the recipients to whom the personal data have been transmitted any rectifications or deletions or limitations of processing carried out. The Data Controller shall notify the data subject of these recipients if the data subject so requests.

With reference to the purposes referred to in points B), C), D), and E) of this policy, the data subject has the right to the portability of his or her data (art. 20) and, in this case, they will be provided in a structured, commonly used and readable format by an automatic device. The data subject has the right to object, in the cases provided for (art. 21), at any time, to the processing of data based on legitimate interest and to the processing of personal data for marketing purposes (see the purposes referred to in letters D) and E) of this policy), by writing to privacy@gualaclosures.com.

In the event that the data subject considers that the processing of personal data carried out by the Data Controller is in violation of the provisions of Regulation (EU) 2016/679, the data subject has the right to lodge a complaint with the supervisory authority, in particular in the Member State where he or she habitually resides or works, or in the place where the alleged violation of the regulation occurred (Privacy Guarantor https://www.garanteprivacy.it/),  or to bring the appropriate courts.

9. POLICY CHANGES

The Data Controller reserves the right to modify, add or remove any part of this Privacy Policy.

Updated: October 10, 2024

The Data Controller

GUALA CLOSURES S.p.A.