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Privacy Policy
This document describes the manner by which the IR App, features IR Free, IR Pro, Lost&Found and the IR- Web Portal (“Portal”) is managed, with reference to the processing of personal data belonging to the users (“User/Users”) consulting them.
It is an information notice issued in accordance with article 13 of the EU Regulation no. 679/2016 (“GDPR”), for anyone who visits the IR App and the Site and/or communicate with GT Line S.r.l. (“GT Line”).
This information notice is provided only for the IR App and the Site and not for any other App and/or websites viewed by users through the links.
1. The data controller
The data controller is GT Line S.r.l. (Vat number 00696831205), with registered office in Valsamoggia (BO) Via del Lavoro, 9 ITALY - e-mail: privacy@gtline.com (“Data Controller”).
2. Types of data processed
2.1 Browsing data
During normal use, the electronic systems and software procedures enabling this Site to operate, acquire certain personal data; transmission of same is implicit in the use of internet communication protocols.
This information is not being collected in order to be associated to well-identified data subjects, but its nature, by means of processing and associations with data held by third parties, could make the users identification possible.
The category of data could be listed as follow: (i) IP addresses or domain names of computers used by users connecting to the IR App and/or the Site, (ii) addresses in URI (uniform resource identifier) notation for resources requested, (iii) the time of request, (iv) the method used to submit the request to the server, (v) the dimension of the file obtained in response, (vi) the numerical code indicating the status of the response given by the server (success, error etc) and (vii) other parameters regarding the user’s operating system and the IT environment.
This data is used only to glean anonymous statistical information on the use of the Site and to check that it operates correctly and this data is deleted immediately after processing.
2.2. Cookie
For the Users data processing carried out by the cookies, please see the relevant cookie policy available on the Site: www.intellirespond.com/cookiepolicy.
2.3 Data provided by users of their own free will and/or communicated by third parties
- the Data Controller will process the information that User may spontaneously provide by sending an email message to the address indicated on the IR App and/or on the Site. Such information are processed by the Data Controller only for the purposes set up under paragraph 3;
- the filling of the registration form on the IR App for the features IR Free, IR Pro and Lost&Found in the section “Log In” and “My Profile” and on the Site involves the communication of your personal data (name, surname, e-mail address, area of work and optionally address, nationality, mobile phone, photo of the suitcase purchase receipt for the sole purpose of storing it for the product warranty, date of birth);
- the selection of the button “Share your position with IR App at the time of filling in the registration form made available by Data Controller in the IR App, with the consent of the data subject, involves the communication of personal data concerning User’s geolocation.
- the filling of the customer form available on the Site, for User’s IR Pro, involves the communication of customers’ personal data (name, surname, address, e-mail address) for those User is Data Controller, and GT Line is Data Processor in accordance to art.28 GDPR;
- the User acknowledges that the possible indication (for example in the filling of section “My Product – Personal combination code, shipping combination code of the IR App) of personal and contact data of any third party different from the interested person shall be held as a personal data processing, with regards to which he shall act as independent controller, undertaking all the obligations and responsibilities provided for by the current legislation with reference to personal data protection. To that effect, the user guarantees to GT Line that any third party data which shall be indicated in such way by the User (and which shall be accordingly handled as if the third party granted his informed consent to the processing and the disclosure of the data to GT Line) was collected by the User himself in full compliance with the current legislation with reference to personal data protection.
3. Purposes and lawfulness of data processing
The personal data of the Users are processed by the Data Controller in order to:
- pursue, in accordance with article 6(1) let. f) of GDPR, an its own legitimate interests consisting in ensuring network and information security, i.e. the ability of a network or an information system to resist, at a given level of confidence, accidental events or unlawful or malicious actions that compromise the availability, authenticity, integrity and confidentiality of stored or transmitted personal data, and the security of the related services offered by, or accessible via, those networks and systems;
- allow the User to ask for informations by the e-mail: privacy@gtline.com, pursuant to article 6(1) let. b) of GDPR;
- fulfil performance of the agreement to which the User is a party and to consent to User to use all the IR App and Site features, pursuant to article 6(1) let. b) of GDPR; Data retention period: retention period necessary to fulfill the pre-contractual request or period necessary to perform the agreement.;
- fulfil administrative management of the User, pursuant to article 6(1) let. c) of GDPR; Data retention period: duration of the contractual relationship with the customer
- pursue purpose of judicial protection, to prevent or prosecute infringements, pursuant to article 6(1) let. c) of GDPR Data retention period: it is equal to the period reasonably necessary to enforce our rights from the moment we become aware of the offence or of its potential commission;
- send newsletter about IntelliRespond IR App and pursuant to art. 6(1) let. f) GDPR;
- allow in the section “Go Work” and “Lost&Found” geolocation of User, pursuant to art. 6(1) let. a) GDPR;
- send via e-mail marketing communications about GT Line Products pursuant to art. 6(1) let. a) GDPR;
- send via e-mail marketing communications about GT Line Products also through profiling, taking into account your area of work, pursuant to art. 6(1) let. a) GDPR
4. Consequences of any refusal to respond
The provision of data for the purposes referred to in the previous paragraph, let. a), b), c), d), e) and f) is optional.
Any refusal, however, would make impossible for the User to communicate with the Data Controller, as well as for GT Line to provide a response to Users’ requests and/or to perform the contract with the User, and guarantee the security of the IR App and/or the Site and the information exchanged on it.
The provision of data for the purposes referred to in the previous paragraph, let. g), h) and i) is optional and only under a specific granted consent. The denial will not involve any consequence, except for the impossibility to perform activity described above.
In any case, even if you have granted your consent, you shall remain in any case free to revoke it in any moment, by sending a clear notice on the matter to GT Line.
5. Manner of data processing
The personal data is processed through computerized, automated manual systems.
The personal data, moreover, is processed only by those subject appointed to carry out such fulfilments, currently identified and duly educated on the constraints provided by the applicable law, as well as by adopting specific security measures aimed to ensure the protection of Your confidentiality and to avoid the loss of data, any unauthorized accesses to the data and any data processing which may be qualified as unlawful or not in compliance with the abovementioned purposes.
6. Communication of personal data
The personal data collected by the Data Controller through the IR App and/or the Site will not be distributed, sold or transferred to third parties, save for those eventualities contemplated by law.
In any case, it remains understood that the Data Controller retains the right to communicate the Users personal data to the companies in charge for carrying out specific services within its activity and/or, in general, in its favor, that will operate as independent data controllers or processors, as well as the right to communicate and/or to distribute the User personal data that, in compliance with the applicable law, the police, the judicial authority, the information and security agencies or other public subjects might ask for purposes related to defense or State security or to preventing, detecting or suppressing crimes.
7. Data subject’s rights
As per Articles 15 et seq. of GDPR, the user has the right to receive from the Data Controller information on the existence of the processing of his/her personal data, as well as to access his/her own data, to obtain the rectification, integration, updating, erasure or blocking of the data; each data subject will also has the right to obtain a copy of his/her data, the limitation of the processing and/or, moreover, to oppose against processing, as well as the right to data portability and to bring a complaint with the competent supervisory authorities under the conditions and within the limits given in the art. 13 of GDPR. The User has the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal
In order to exercise the aforementioned rights, it is necessary to write to the Data Controller at the following e-mail: privacy@gtline.com “Privacy – exercise of the data subject rights” as object.
8. Duration of the processing and retention period
The processing will last only for such period of time that is necessary for achieving the purposes mentioned at the previous paragraph 3. The Data Controller will then store Your personal data only in compliance with the legal obligations provided by the applicable laws, for administrative purposes and/or to claim or to defend an own right in the case in which a litigation or a pre-litigation procedure arise.
For the purpose referred to paragraph 3 let. h) data retention period is 24 months.
For the purpose referred to paragraph 3 let. i) data retention period is 12 months.
This privacy policy takes effect on 18/06/2019. Any possible amendments will be published on this page.