Pursuant to Articles 13 of the Legislative Decree 196/03 (hereinafter referred to as the "Code") and Articles 13 and 14 of the Regulation 2016/679/EU (hereafter referred to as the "GDPR") GIMOTO SRL (hereinafter referred to as the "Data Controller") with its registered office in Cassano D'Adda (MI), Via Casotta, 20 - 20062, in its capacity as "Data Controller", hereby informs you that your personal data is collected within the procedure called “Essential processing for the execution of the contract with the customer”, and will be processed in compliance with the aforementioned legislation, in order to guarantee the rights, fundamental freedoms, as well as the dignity of individuals, with particular reference to your privacy and personal identity. We also hereby inform you that if the activities outsourced to you provide for the processing of personal data of third parties, as the rightful owner of such information, it will be your responsibility to ensure that you have complied with the legal provisions with regard to the interested parties in order to make such processing legitimate on our part.

Origin, purpose, legal basis and nature of the data processed

The processing of the personal data you supplied directly, is carried out by GIMOTO SRL for the following purposes:

• Customer management
• Management of litigation
• Monitoring of contractual obligations
• Planning of activities
• Internal control services
• Services for consumer’s and users’ protection
• Monitoring customer satisfaction
• Information to customers of new services/products
• Sending information and/or advertising material including by telephone or internet - the sending of advertising material is carried out because you are an existing or potential client of the Data Controller, and there are commercial relations between the parties
• Protection of the customer’s or worker’s property
• Accounting or treasury management
• Services for the protection of company assets

On the following legal bases as foreseen by Article 6:

• Processing is necessary for the execution of a contract of which the interested party is a member or for the execution of pre-contractual measures taken at the request of the same.
• Processing is necessary to fulfil a legal obligation to which the Data Controller is subject
• Processing is necessary for the pursuit of a Data Controller’s or third parties’ legitimate interest

The processing of your personal information relates to the following data:

• Tax code and other personal identification numbers
• Name, address or other elements of personal identification
• Economic, commercial, financial and insurance activities
• Bank account details
• Nature of goods
• Email address
• Address of residence

Communication

Your personal information is subject to communication on the basis of the legal provisions established under Article 6 herein, to the following third parties:

• Courts
• Consultants and freelancers
• Companies and businesses
• Banks and credit institutions
• Other public administrations
• Professional orders and colleges
• Associations of entrepreneurs and companies
• Controlling companies
• Subsidiaries and associates
• Ministries (economics and finances)
• Law enforcement
• Chambers of commerce, industry, crafts and agriculture

These bodies, organisations, companies and professionals act as Data Processors appointed by GIMOTO SRL or they themselves are Data Controllers of the personal data transmitted thereto. For the processing of information that will be communicated to these subjects, equivalent levels of protection to the processing of their staff's personal data will be required. In any case, only the data necessary for the pursuit of the intended purposes will be communicated and the regulatory instruments will be applied in accordance with Articles 43 and 44 of the Code and by Paragraph V of the GDPR.

Methods, processing logic and retention times

Your information is collected and registered lawfully and correctly for the purposes indicated above and in compliance with the principles and provisions of Article 11 of the Code and Article 5, Paragraph 1 of the GDPR.
Data is processed via manual, computer and electronic means on a logical basis strictly correlated to the purposes and, in any case, ensuring the security and confidentiality of the information itself. Data retention will last 10 years from the end of the contract.

Nature of conferment

In relation to the aforesaid purposes, the conferment of your data is essential for the execution of the assignment between yourself and GIMOTO SRL, and also to allow GIMOTO SRL to comply with the requirements of the applicable regulations: in the absence of such conferral of personal information it is impossible to establish and maintain the position between yourself and GIMOTO SRL.
We hereby inform you that the processing of personal information takes place on the basis of the provisions of Article 24, Paragraph 1, Letter b) of the Code and Article 6, Paragraph 1, Letter b) of the GDPR.

Rights of the Data Subject

In compliance with the limits and conditions established by the legislation on personal information protection regarding the exercise of data subjects’ rights with reference to the subject matter of this Disclosure Paper concerning data processing, as a data subject you have the right to request confirmation on whether your personal data is being processed, access to your personal data, and in relation thereto, you have the right to request rectification, cancellation, notification of corrections and deletions and to whom any data is transmitted by GIMOTO SRL. The limitation of processing in the cases envisaged by the law, the portability of the personal data you provided - in the cases indicated by the law, to oppose the processing of your data and, specifically, you have the right to object to decisions concerning processing your information provided that it is based solely on automated processing, including profiling. In the event that you believe that the processing of your information violates the rules of the GDPR, you have the right to lodge a complaint with the Guarantor pursuant to Article 77 of the GDPR. If you wish to request further information on the processing of your personal data or for exercising your rights, you can write to Alfreda Delaiti (gimoto@gimoto.com).

GIMOTO SRL is the Data Controller for the processing, pursuant to Article 4 of the Code and the GDPR, with its registered office in Cassano D'Adda (Milan), Via Casotta, 20 - 20062

The Data Controller
GIMOTO SRL
Cassano D'Adda, 27/06/2018 - Ver 1.1