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PRIVACY POLICY

 

Gilmar Divisione Industria S.p.A. (hereinafter referred to as “Gilmar”) respects your privacy and is committed to processing your personal data with the utmost care and in full compliance with the relevant provisions governing the protection of personal data, including Regulation (EU) 2016/679 (General Data Protection Regulation or “GDPR”) and Legislative Decree no. 196/2003, also updated pursuant to Legislative Decree no. 101/2018.

 

This Privacy Policy therefore aims to inform you, with the utmost transparency, about the processing of personal data carried out by Gilmar on the www.iceplay.com website (hereinafter referred to as the “Website”).

The information included in this Privacy Policy does not relate to other websites, web pages or online services accessible from the Website, such as through redirects to resources outside the www.iceplay.com domain, e.g., to access the “Work with us” section within www.gilmar.it. Before providing any personal data through said form, we therefore invite you to read the privacy policy available on www.gilmar.it.

 

For us, it is important to provide clear and complete information on how we collect, use and store your personal data in the context of your interaction with the Website. For this very reason, we encourage you to carefully read this Privacy Policy before sending Gilmar any information and/or personal data of any type.

 

Personal data refers to any information that makes it possible to identify a person, also indirectly (e.g., by combining said data with other information). By way of example, your email address, first and last name, etc. are considered to be personal data.

 

If you are under 18 years old, please do not provide us with any personal data. In the event that we determine that personal data belonging to a minor have been communicated to Gilmar, such data shall be deleted.

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DATA CONTROLLER

 

The Data Controller for the processing of personal data that you may provide to us is Gilmar Divisione Industria S.p.A., with registered office in San Giovanni in Marignano (RN), Italy, in Via Malpasso no. 723-725, reachable by phone or email at:

Tel: +39 0541 959111

Email address: privacy@gilmar.it

 

 

DATA PROTECTION OFFICER

 

Pursuant to art. 37 of the Regulation (EU) 2016/679, Gilmar Divisione Industria S.p.A. has voluntarily designated a Data Protection Officer (“DPO”), which can be contacted at Gilmar Divisione Industria S.p.A., Via Malpasso no. 723-725, 47842 San Giovanni in Marignano (RN), Italy, or by sending an e-mail to dpo@gilmar.it.

 

 

TYPES OF PERSONAL DATA PROCESSED

 

When you browse, interact with the Website or make purchases on the Website, Gilmar processes the following types of personal data:

  1. data that you provide to Gilmar when you fill out the “Contact Us” form available on the Website, such as your name, email address, the country where you are located, the information you wish to provide to us by filling out the “Subject” and “Message” fields found on the same form and, possibly, your telephone number and your order number;

  2. browsing data which, although constituting information that is not collected in order to be associated with identified users, could, by their very nature, make it possible to identify the site users if processed and associated with data held by third parties.

This category of data includes data collected automatically while browsing the Website and necessary for the functioning of the same, such as IP addresses, domain names of computers used to connect to the site, addresses in URI (Uniform Resource Identifier) notation of requested resources, the time the request is made, the method used to submit the request to the server, the file size obtained in response, the numerical code indicating the response status from the server (successful, error, etc.) and other parameters related to the user's operating system and computer environment.

 

 

PURPOSE AND COMPULSORY OR OPTIONAL NATURE OF THE DATA PROCESSING

 

Gilmar processes your personal data for the following purposes:

  1. to provide a reply to your requests for information and/or assistance made using the “Contact Us” form available on the Website;

  2. to comply with applicable legal obligations (if any) and to protect its rights;

  3. to allow you to browse the Website and for computer security purposes.

The provision of your personal data for the aforementioned purposes is not mandatory. However, your refusal to provide such data makes it impossible for Gilmar to respond to your requests.

 

LEGAL BASIS OF THE DATA PROCESSING

 

Gilmar processes your personal data based on the following conditions of legitimacy:

  1. to enforce the sales contract between you and Gilmar, or with the intention of establishing an eventual business relationship with you (and therefore as relating to the implementation of pre-contractual measures), pursuant to Article 6, letter b) of the GDPR.

The data processing activities legitimised by this legal basis concern the activity of providing answers to your possible requests for information about your purchases, the provision of after-sales services, the handling of requests for exchanges and/or returns and to process refunds;

 

  1. to perform a legal obligation to which it is subject, pursuant to Article 6, letter c) of the GDPR.

The data processing activities legitimised by this legal basis concern the receipt of your privacy-related requests and the reply to said requests;

  1. to pursue Gilmar’s legitimate interests, in accordance with Article 6, letter f) of the GDPR, as in promoting and operating its business, also through the Website, acknowledging and replying to comments on the Website as well as requests for general information, defending its rights and implementing computer security systems.

The data processing activities legitimised by this legal basis concern the collection of personal data to the extent that it is necessary to receive your comments on the Website and your requests for general information, replying to said comments on the Website and to said requests for general information and to allow browsing of the Website.

 

 

SUBJECTS WHO HAVE ACCESS TO YOUR PERSONAL DATA

 

Gilmar limits access to personal data as much as possible, making such data available to its staff, duly authorised to access the data in order to carry out their professional duties.

Gilmar’s staff shall process the personal data within the limits and in compliance with the provisions entrusted to it by the same.

 

Your personal data may also be shared with companies affiliated with Gilmar and disclosed to independent subjects on which the latter relies to carry out its normal business activities.

 

These subjects shall process your personal data in a capacity of Data Processors, according to the instructions provided by Gilmar, as well as in a capacity of independent Data Controllers.

Gilmar provides to said subjects only the data strictly necessary to perform the agreed-upon services.

The suppliers of such services fall into the following categories:

  • companies, consultants and service providers (also IT service providers);

  • companies and professionals that provide legal, tax, accounting and administrative consultancy services;

  • financial administration;

  • communication agencies.

Gilmar may also disclose your personal data to its legal representatives and/or consultants to enforce its general conditions of sale and/or legal regulations, to fulfil the requests of judicial and administrative authorities and/or to protect its rights in judicial, arbitration or similar legal proceedings, as well as for other reasons related to the protection of the rights and freedoms of others.

 

 

DATA PROCESSING METHOD AND SCOPE OF CIRCULATION OF PERSONAL DATA

 

Gilmar processes personal data on paper and with the help of electronic and automated means, within the limits of the purposes set out in this Privacy Policy and taking the appropriate measures to maintain the confidentiality and privacy of said data.

 

Gilmar pays great attention to the protection and privacy of personal data and consequently does not engage in the dissemination and/or marketing of personal data.

 

In some cases, your personal data may be transferred outside the European Union. This transfer shall take place ensuring adequate protection levels for your personal data, including pursuant to the requirements set out in Articles 45 and 46 of the GDPR.

 

In particular, personal data shall be transferred outside the European Union to countries that provide an adequate level of data protection, as determined by specific decisions of the European Commission.  

 

In other cases, transfers of personal data outside the European Union may take place where adequate assurances and safeguards for the protection of your personal data are issued by Gilmar’s suppliers or subcontractors that receive said personal data, such as the subscription of the standard contractual clauses for the protection of personal data adopted by the European Commission, also assisted by - where necessary and possible - additional measures.

     

 

DATA RETENTION PERIOD

 

Your personal data shall be retained by Gilmar for a limited period of time, necessary to achieve the purposes of each data processing activity identified above. At the end of this period, your data shall be deleted or made anonymous.

 

Personal data processed in order to fulfil the commitments provided for by the contracts, including pre-contractual activities, shall be retained by Gilmar for a period of 10 years from the execution of the contractually provided service, or, in the case where the pre-contractual activities do not lead to the conclusion of a contract, for a period of 10 years following the last communication received by Gilmar in such regard.

 

Personal data submitted through the “Contact Us” form will be retained for the time that is strictly necessary to reply to your requests, then they will be deleted.

 

Personal data processed as part of the management and keeping of company accounts and for billing purposes shall be retained by Gilmar for the time necessary to fulfil the company’s tax and record keeping obligations, and, in any case, no later than 10 fiscal years from the invoicing date.

 

 

YOUR RIGHTS

 

You may contact Gilmar at any time, by sending an email to privacy@gilmar.it, requesting to receive the list of Data Processors (i.e., Gilmar services’ providers entrusted to process your personal data on the basis of the instructions and guidelines provided by Gilmar).

 

Still by sending an email to privacy@gilmar.it you can request to exercise the rights provided for by the applicable legislation on the protection of confidentiality of personal data (pursuant to the provisions set out in Articles 15 to 22 of the GDPR), and in particular:

  1. the right to obtain confirmation of whether your personal data are being processed or not, to have access to your personal data processed by Gilmar, to know the purpose of such processing, the categories of processed data and the recipients or categories of recipients to whom your data have been or will be communicated or disclosed. You are also entitled to know the retention period of your personal data or, if this is not possible, the criteria used to determine this period.

  2. the right to verify the accuracy and correctness of your personal data and its origin, to request the integration, updating, correction, deletion or anonymisation of your personal data, as well as the limitation of the processing of your data (pursuant to the cases provided for in Articles 17 and 18 of the GDPR);

  3. submit a complaint to the Supervisory Authority (the Italian Authority for the Protection of Personal Data, “Garante”).

  4. in case of transfer of your data to a third country, the right to be informed of the existence of adequate safeguards relating to such transfers, pursuant to Article 46 of the GDPR.

  5. the right to oppose the processing of personal data, carried out by Gilmar on the basis of its legitimate interest, for reasons related to a particular situation, provided that no prevailing motives exist to allow Gilmar to continue with the data processing (e.g., the need to protect its rights in court);

  6. the right to be informed of the existence of an automated decision-making process, including profiling, as referred to in Article 22, paragraphs 1 and 4 of the GDPR and, in such cases, to obtain meaningful information about the logic involved, as well as the significance and the expected consequences of such processing for the Data Subject.

  7. the ability to exercise the right to portability of your personal data.

 

Once your request has been received, Gilmar shall process it as quickly as possible and with utmost seriousness, in order to allow you to exercise your rights, providing a reply without delay and, in any case, within one month from receiving the request. In cases of particular complexity, the timeframe for replying to your request may be extended to up to 2 months from receiving the request. In this case, Gilmar shall keep you informed on the status of the fulfilment of your request.

 

(last updated 29 January 2025)

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