Privacy Policy

Information on the processing of personal data

pursuant to Art. 13 GDPR

All processing operations of your personal data are carried out in compliance with applicable data protection legislation, including Regulation (EU) 2016/679 (“GDPR”) and Legislative Decree No. 196 of 30 June 2003, as amended by Legislative Decree No. 101 of 10 August 2018 (“Privacy Code”).

With this privacy policy (“Privacy Policy”), we wish to provide you with information on the processing operations of your personal data collected through our website gltsafeandsound.nohup.co.uk (“Site”).

Please note that you will be able to use the services made available on our Site (“Services”) only after having read and accepted the “Terms and Conditions of the Site” (“Terms and Conditions”).

WHO IS THE DATA CONTROLLER OF YOUR PERSONAL DATA?

The data controller of your personal data is Global Thinking Foundation (“GLT”), VAT No. 09578750961, located in Milan (20155), via Aosta 21.

You may contact GLT with any questions or comments you may have regarding this Privacy Policy by writing to the e-mail address segreteria@gltfoundation.com.

WHAT CATEGORIES OF DATA DO WE PROCESS?

In order to achieve the purposes indicated in the following section, we process the following categories of data:

1) Browsing data

Through the Site we collect certain personal data relating to your navigation. This category includes

– IP addresses of the computers and devices used to access the Site and to use the Services;

– information relating to the device used to visit or access the Site (such as, for example, the model, operating system and browser used, etc.).

2) Site usage data

We collect data relating to your interactions with the Site, such as information about the products you have viewed and/or the Services you have selected, search history, etc.

3) Data provided voluntarily by you

We may collect the following information, directly provided by you (e.g. via the online registration form for sending our newsletter or requesting information or assistance)

– first name, last name, e-mail address;

– information provided in the context of a request for assistance or clarification (reason for contact, etc.);

– information provided as part of participation in the quiz on the Site.

4) Data collected through cookies and other tracking tools

In the event that you expressly consent to the installation and use of analytical and profiling cookies, we will collect data through the use of cookies, web beacons and other technologies. For more information please see our cookie policy.

FOR WHAT PURPOSES AND ON WHAT BASIS DO WE PROCESS YOUR PERSONAL DATA?

We process your personal data for the following purposes:

(A) to provide you with the requested Services and, therefore, for purposes strictly connected with and instrumental to the establishment and management of customer relations (Art. 6, para. 1, letter b GDPR).

The processing of your personal data is necessary to execute the contract we have concluded with you or the pre-contractual measures taken at your request. In particular, we process your personal data in order to:

– allow you to browse and use the Site;

– verify your identity

– allow you to benefit, in accordance with the General Conditions, from the Services requested;

– provide you with assistance and/or follow up on your possible requests through our custo-mer service (through remote communication tools, such as email, chat, etc.) in relation to the Services.

Processing for the purposes set out in this section does not require your consent as it is necessary to enable us to provide the Services and, therefore, if you do not wish to provide us with your personal data for this purpose, we will not be able to provide you with any Services.

The data processed for this purpose belong to the following categories: navigation data and data provided voluntarily by you.

(B) in order to comply with legal obligations to which GLT is subject and, therefore, for purposes arising from legal obligations, regulations, EU legislation, provisions issued by authorities empowered to do so by law or by supervisory and control bodies (Art. 6, para. 1, letter c GDPR).

We also process your personal data to:

– to enable us to act in accordance with applicable legal and/or regulatory obligations;

– to assert and defend the rights of GLT;

– to handle and respond to requests from competent authorities (administrative, tax and judicial).

The data processed for this purpose belong to the following categories: navigation data, data related to the use of the Site and data provided voluntarily by the user.

(C) to pursue the legitimate interests of GLT (Art. 6, para. 1 lit. f GDPR)

We also process your personal data for:

– purposes of product and/or service improvement, internal management control, to enforce and defend the rights of GLT;

– to complete a sale of assets, business, or business unit as well as a potential merger or corporate and/or financial transaction, in which case we will disclose and transfer the data to the third party(ies) involved in the transaction

– maintaining and improving the security of the Site, our network, and our information system.

Such processing is carried out based on our legitimate interest and therefore does not require your specific consent. You may, however, object to the processing at any time by sending a written communication to segreteria@gltfoundation.com.

The data processed for this purpose belong to the following categories: navigation data, data related to the use of the Site and data provided voluntarily by you.

(D) Subject to your express and specific consent with reference to each of the following purposes (Art. 6(1)(a) GDPR), we may process your personal data to:

– send you (by means of remote communication tools) our newsletter, which may also include updates about initiatives and/or projects promoted by GLT from time to time

– allow you to take part in the quiz described in the following link https://gltsafeandsound.com/en/quiz/ , as well as for GLT to perform statistical analysis of the data collected in this way.

Such processing of your data is not mandatory and your prior consent is required. You may revoke your consent at any time by sending a written notice to segreteria@gltfoundation.com  or by clicking on the unsubscribe link in each email newsletter.

The data processed for this purpose belong to the following categories: navigation data, data relating to the use of the Site, data provided voluntarily by the user and data collected through the use of cookies and other tracking tools.

TO WHOM MAY WE COMMUNICATE YOUR DATA?
Your data may be communicated to the following categories of subjects

– parent and/or associated companies of and/or controlled by GLT;

– suppliers, business partners and all those who are part of our network or who offer us services of various kinds whose provision requires the processing of personal data. In particular, we use third party providers to provide you with our newsletter service (specifically, the MailChimp platform), to optimize our Services, and to operate and maintain the Site;

– professionals or professional firms assisting GLT in connection with legal, administrative and/or tax matters, including litigation;

– counterparties in connection with corporate transactions or the sale of a company or business unit or individual business assets and entities resulting from a merger or any other form of transformation involving GLT

– public safety and judicial authorities, individuals, entities, or other authorities to whom we are required to disclose your information by law or by order of such authorities.

TO WHOM DO WE TRANSFER YOUR DATA ABROAD?

Your personal data may be transferred freely within the territory of the European Economic Area (EEA).

If, for the purposes set out in this Privacy Policy, it is necessary to transfer your data outside the EEA and to countries or territories that are not the subject of a European Commission adequacy decision under Art. 45 GDPR, GLT will (i) carry out such transfer on the basis of the conditions set out in Articles 46 or 47 GDPR (adequate safeguards or binding corporate rules) and/or the exemptions set out in Article 49 GDPR, and (ii) take the technical, organizational and/or contractual measures necessary to ensure a level of protection of your personal data comparable to the level of protection provided by the applicable legislation in the EEA.

HOW LONG DO WE KEEP YOUR DATA?

Your information will be retained for no longer than is necessary for the purposes for which it was collected, without prejudice to the exercise of your rights set forth in the section below.

GLT may retain certain information even after the termination of your relationship with GLT in connection with the provision of the Services, as long as necessary to fulfill specific contractual or legal obligations, as well as for administrative, tax and/or social security purposes, for the period of time required by applicable laws and regulations, and as long as necessary to bring legal claims.

Notwithstanding the foregoing, data processed for the purpose of sending the newsletter based on consent will be kept for a period of 24 months from the date on which consent was given or renewed.

WHAT ARE YOUR RIGHTS?

You have the right to exercise, at any time, the rights recognized by Articles 15-21 GDPR, as briefly summarized below:

– Right of access: you may request information from us regarding our processing of your data or confirmation that GLT processes your personal data. In this case, you can ask us to provide you with a copy of your data and check what data we hold about you.

– Right of rectification: you have the right to ask us to rectify your personal data if it is incorrect, including the right to request the integration of incomplete personal data.

– Right to erasure: you have the right to request us to erase the data (or any part of it) you have provided to us, including data that does not need to be kept in relation to the purposes for which the data was collected or otherwise processed.

– Right of restriction: you may ask us to restrict the processing of your personal data if we are legally entitled to do so.

– Right to object: you may object to the processing of your data, subject to the existence of an overriding legitimate reason to continue such processing.

– Right to portability: you may obtain from GLT, in a structured, commonly used and machine-readable format, the personal data you have communicated to us for the purpose of transmitting them to another party. This right applies when GLT processes such data through automated means, based on your consent or for purposes of providing the Services.

– Withdrawal of consent: if the processing is based on your consent, you may withdraw your consent at any time, provided that the lawfulness of the processing carried out prior to the withdrawal of your consent is not affected.

– Right to lodge a complaint with the Guarantor: without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with the Guarantor Authority for the protection of personal data if you believe that the processing carried out by GLT violates the applicable data protection law.

You may exercise your rights at any time and free of charge by sending a written notice to segreteria@gltfoundation.com.

Pursuant to Article 2-terdecies of the Privacy Code, the rights listed above may be exercised, in the event of your death, by the person who has an interest in you, or is acting on your behalf (as your representative, or for family reasons worthy of protection). You may prohibit the exercise of all or any of these rights by your successors in title by sending us a written declaration.

UPDATES TO THIS PRIVACY POLICY

We will periodically update this Privacy Policy to comply with applicable data protection legislation and/or to adapt to the adoption of new internal systems or procedures, or for any other reason that may be appropriate.

Any such changes will be promptly posted on the Site and we will notify you through our communication tools. The changes will be binding as soon as they are announced. If you do not wish to acknowledge or accept the changes to this Privacy Policy, you may exercise any of the above rights.

Please consult this page periodically. Version updated as of 18/11/2022.