This Privacy Policy applies to all cases in which a person accesses the website and decides to navigate within it and use its services, regardless of whether they purchase products. It provides all the information required to understand how the data and information identifying the users of http://www.garmont.com and all the Garmont® sites linked to it are collected and used (for the purposes of the legislation on the processing of personal data, these individuals are referred to as “data subjects”).
INFORMATION PURSUANT TO ARTICLE 13 OF REGULATION (EU) 2016/679
This information is only being provided for the websites of GARMONT INTERNATIONAL and does not also apply to any third-party websites consulted by the user through links.
CONTROLLER
The Controller for the processing of data collected through this website is GARMONT INTERNATIONAL S.R.L. (hereinafter also “GARMONT INTERNATIONAL” for short), with registered offices at Via del Lavoro, 18 - 31050 Vedelago (TV), Italy.
The Controller independently establishes the purposes and methods of processing, as well as the security procedures to be applied to ensure the confidentiality, integrity and availability of the data.
APPOINTMENT OF THE DATA PROTECTION OFFICER (or “DPO”).
GARMONT INTERNATIONAL has appointed a Data Protection Officer (DPO) who can be contacted at the e-mail address: dpo@garmont.com.
PURPOSES OF PROCESSING
The data collected may be processed for the following purposes:
- To register with the website in order to make use of the services offered by GARMONT INTERNATIONAL and for the subsequent management of your account.
- To handle and fulfil purchase orders and any returned goods and complaints.
- To manage the payment methods used to purchase products on the GARMONT INTERNATIONAL website.
- To handle the data subject’s technical, commercial or order status-related requests and any inquiries.
- To receive Curricula Vitae.
- To send newsletters.
- To send marketing and/or commercial notices using both electronic and data transfer (e-mail, text messages) and traditional channels (ordinary mail).
- To collect data: a) on the purchasing experience and the products purchased with the consequent publication of the corresponding rating on the GARMONT INTERNATIONAL website and/or on websites linked to it, as well as on the social media channels it uses (e.g., reviews on purchased products); b) on purchasing preferences, including through participation in specific questionnaires in order to personalize the commercial notices to be sent to the data subject.
DATA PROCESSING AND STORAGE METHODS
Personal data will be processed using mainly electronic and data transfer means.
Processing operations will be implemented so as to ensure the logical and physical security and the confidentiality of the data acquired through this website.
The data provided will be stored for the time strictly necessary to achieve the purposes for which it was collected, namely:
- Data regarding a registered user and their account: until the user asks for them to be erased. It should be noted that data processing will not be indefinite, since after 10 years of inactivity, registered users will be contacted to confirm their registration and if they fail to do so, their account will be automatically deactivated and the data erased.
- Data collected to conclude and fulfil purchase orders: for as long as is necessary to process the order and in any case for 10 years from the purchase order date.
- Billing data and data regarding payment methods (where applicable): for 10 years.
- Data related to the handling of data subject requests: for as long as is necessary to fulfill the data subject's request.
- Data contained in a CV: for 12 months.
- Data collected in order to send newsletters: until consent is withdrawn by asking to unsubscribe. It should be noted that data processing will not be indefinite, since when a profile has been inactive for 5 years, the user will be sent test e-mails and if on the second attempt to send such e-mails, the profile continues to remain inactive, the data provided in order to receive newsletters will be permanently erased.
- Data collected to send direct marketing communications (based on legitimate interest): until the data subject exercises their right to object by asking to unsubscribe.
- Data regarding shopping experience and purchased product ratings (i.e., reviews) intended for publication: for 12 months.
- Data collected—including through participation in specific questionnaires—to personalize commercial notices: for a period of 12 months, unless previously granted consent is withdrawn before that time.
Providing GARMONT INTERNATIONAL with personal data, which are requested on various occasions, may be mandatory or optional.
In cases where it is mandatory to provide data, failure to do so will make it impossible to fulfil the request.
The legal basis (also referred to as lawfulness) of processing:
- For the purposes stated in points 1 to 4 is the contract; therefore, if such data is not provided, it will be impossible to place orders or use the services of GARMONT INTERNATIONAL. For registration with the website and creating the corresponding account, the legal basis is the consent the user gives by entering data in the appropriate form and creating their account.
- For the purpose outlined in point 5, the processing of spontaneously submitted Curricula Vitae is legitimate insofar as it is expressly authorized by law (Article 111-bis of Legislative Decree No. 196/ 2003), which specifies that the consent of the person to whom the personal data refer is not required in this case.
- For the purposes outlined in points 6, 7 and 8 is consent, without which it will not be possible to send newsletters or commercial notices or to collect data—including through voluntary participation in specific questionnaires—to personalize the aforementioned commercial notices. For some commercial notices sent as part of digital campaigns, data is collected using tracking systems, please consult the cookie policy (link) for information on how data are processed in these cases. For the purpose outlined in point 8, consent will be requested at a later time in a specific e-mail.
For the sake of completeness, it should be mentioned that in some cases (not regarding the ordinary management of this website) the Authority may request news and information pursuant to Article 157 of Italian Legislative Decree No. 196/2003, in order to monitor the processing of personal data. In these cases, a response is mandatory under pain of an administrative sanction.
MARKETING CAMPAIGNS AND PROFILING
GARMONT INTERNATIONAL also carries out personal data processing activities as part of digital marketing campaigns. For such processing, the legal basis will be the consent given by the user when they accept the cookies on the website. This consent can be withdrawn at any time using the cookie settings, as outlined in the Cookie Policy.
In particular, using digital platforms, GARMONT INTERNATIONAL may display marketing and advertising content based on the interests of the user, whose information has been acquired as a result of the profiling activity carried out on the GARMONT website and shared with the digital platforms or based on the correspondence between the preferences and interests expressed by the user who has visited the website and accepted the profiling cookies and the user cluster identified by the digital platform (e.g., retargeting).
Further information regarding the processing carried out using tracking tools is provided in the Cookie Policy.
GARMONT may also collect certain personal data when a user interacts with social media pages. Indeed, a user directly provides GARMONT with some information when they use their profile to share advertising images posted on GARMONT's social media pages or to comment on posts and/or products present therein.
Whether or not personal information is provided will depend on the settings of the individual social media platform used by the user and the content they choose to make public. Users are therefore encouraged to consult the privacy policy of the various social media and check their privacy settings.
SCOPE OF DATA DISCLOSURE AND DISSEMINATION
The data collected may be disclosed to:
- All persons who are entitled to access such data under the applicable regulations.
- Financial administrations and other public companies or agencies, in order to fulfil regulatory obligations.
- Our collaborators and employees appointed to process the data you provide, within the scope of their respective duties.
- Appropriately selected, experienced, capable and reliable third parties that offer suitable guarantees of full compliance with current regulations on data processing, including the data security profile. Such third parties have been appointed as “Data Processors” and carry out their tasks in accordance with the instructions imparted by GARMONT INTERNATIONAL.
| DATA | RECIPIENTS OF THE DATA |
| Bank details used for payment (where applicable) | Banking institutions for the management of collections |
| EXTERNAL DATA PROCESSORS | |
| Data related to billing and/or to the conclusion of the purchase order | Companies and professionals of which the Controller avails itself, including tax consultants and IT consultants |
| Customer-related data for marketing purposes | Agents, representatives, dealers, advertising agencies, consultants |
| Data on the ratings (reviews) left by purchasers of GARMONT INTERNATIONAL | Zoorate S.r.l. |
| Newsletter-related data | Caffeina S.p.A. |
| Commercial notice-related data |
|
| Data related to the management of the website platform | TeamSystem S.p.A. |
TYPES OF DATA PROCESSED
Browsing Data
The IT systems and software procedures used to operate this website acquire, in the course of their normal operation, some personal data whose transmission is implicit to the use of Internet communication protocols.
This information is not collected to be associated with identified data subjects, but by its very nature could, through processing and association with data held by third parties, allow users to be identified.
This category of data includes the IP addresses or domain names of computers used by users who connect to the website and other parameters related to the user's operating system and IT environment.
This data is used for the sole purpose of obtaining anonymous statistical information on use of the website and to check that it functions properly and is deleted immediately after it has been processed. The data could be used to ascertain liability in the event of hypothetical computer crimes committed against the website.
Personal Data
| Stage and Purpose of Processing | Personal Data |
| For registration with the website and the handling and fulfilment of purchase orders |
|
| Account management |
|
| Newsletter subscription and sending of commercial notices by e-mail | E-mail address |
| Rating of the purchase experience and of the products purchased (i.e., reviews) |
|
| Personalized commercial notices | Data contained in the questionnaires |
The explicit and voluntary sending of e-mail, to the addresses indicated on this website, entails the subsequent acquisition of the sender's address, which is necessary in order to respond to requests.
SECURITY MEASURES
GARMONT INTERNATIONAL has taken appropriate security measures in order to minimize the risk of data being destroyed or lost, including accidentally, unauthorized access or processing that is not permitted or not in accordance with the stated purposes of collection.
COOKIES
The use of cookies by GARMONT INTERNATIONAL falls under the privacy policy of the Provider and is in accordance with the new Guidelines on the use of cookies and other tracking tools that were issued on 10.06.2021 and came into force on 9.01.2022.
Please consult the Cookie Privacy (link).
DATA SUBJECT RIGHTS pursuant to Articles 15, 16, 17 18, 20, 21 and 22 of REGULATION (EU) 2016/679
We wish to inform you that in your capacity as a data subject, in addition to the right to lodge a complaint with a supervisory authority, you have the rights listed below, which you can enforce by addressing an appropriate request to the Controller.
Article 15 - Right of access
The data subject has the right to obtain from the Controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, to access the personal data and the information regarding processing.
Article 16 - Right to rectification
The data subject has the right to obtain from the Controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Article 17 - Right to erasure (right to be forgotten)
The data subject has the right to obtain from the Controller the erasure of personal data concerning him or her without undue delay and the Controller shall have the obligation to erase personal data without undue delay.
Article 18 - Right to restriction of processing
The data subject has the right to obtain from the Controller restriction of processing where one of the following applies:
a) The accuracy of the personal data is contested by the data subject, for a period enabling the Controller to verify the accuracy of the personal data.
b) The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
c) The Controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
d) The data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the Controller override those of the data subject.
Article 20 - Right to data portability
The data subject has the right to receive the personal data concerning him or her, which he or she has provided to a Controller, in a structured, commonly used and machine-readable format and has the right to transmit those data to another Controller without hindrance from the Controller to which the personal data were provided.
In exercising his or her right to data portability pursuant to paragraph 1, the data subject has the right to have the personal data transmitted directly from one Controller to another, where technically feasible.
Article 21 - Right to object
The data subject has the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions.
Article 22 - Automated individual decision-making, including profiling
The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.
Article 7 - Withdrawal of consent to processing
You also have the right to withdraw your consent to the processing of your personal data.
Once this operation has been completed, your personal data will be removed from the archives as soon as possible.
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If you wish to receive further information regarding the processing of your personal data, or to exercise your rights under the previous point, you may write to: privacy@garmont.com or to the Data Protection Officer: dpo@garmont.com.
Before we can provide you with or change any information, we may need you to verify your identity and answer some questions. You will receive a reply as possible and in any case no more than 30 days after you made your request.
In addition, requests may also be addressed to the Controller by writing to:
GARMONT INTERNATIONAL S.R.L.
Via del Lavoro, 18
31050 Vedelago (TV) - Italy