Privacy Policy

This Privacy Policy has been drawn up by Glacom Italia S.r.l., with its registered offices in Toscolano Maderno (BS), Via Trento No 124 (hereinafter “Glacom”), pursuant to Article 13 of Legislative Decree No 196 of 30 June 2003 on the protection of personal data (hereinafter the “Privacy Code”), in order to outline the management procedures of the website www.glacom.it (hereinafter the “Website”) and of the services made available through the Website by Glacom (hereinafter the “Services”) regarding the processing of the personal data of users who visit the Website and/or use its Services (hereinafter the “Users”).   
This Privacy Policy only applies to the Website and not for any other websites that Users may visit via links.

1.    Our Policy
All persons shall have the right to the protection of their personal data. Glacom shall respect the rights of its Users to obtain information on the collection and other processing operations of their personal data. Pursuant to the provisions of the Privacy Code, when processing any data that could directly or indirectly identify the User, Glacom shall only process the data that is strictly necessary.
Consequently, Glacom has designed the Website to minimise the use of the User’s personal data and to exclude the processing of personal data when we can provide services in individual cases through the use of anonymous data or any other means, which identify the User only when it is necessary or requested by the authorities.

2.    Personal data collection
Subscription to the newsletter
It is free to browse the Website and does not require any prior registration.
However, to use certain Services made available for Users, they shall need to register beforehand under a special section of the Website.
Only with express consent from the User will this data be used for a whole series of additional activities.
In particular, registration is required to receive newsletters sent by Glacom via e-mail to the address indicated by the User, which will keep Users up-to-date about Glacom’s exclusive initiatives and its commercial news (hereinafter “Newsletter”). This registration is also necessary to receive commercial, promotional and/or advertising material via e-mail to the address indicated by the User.

Data provided voluntarily by the User
If the User sends e-mails optionally, explicitly or voluntarily to the addresses indicated on the Website, the sender’s address and any other personal data included will then be acquired to reply to the requests.
Similarly, if the User provides personal data under the “Contacts” section of the Website, this data voluntarily entered by the User in the appropriate fields will then be acquired by Glacom and processed to reply to any messages and requests.

Browsing data
During their ordinary course of operation, the IT systems and software procedures required to run this Website will acquire certain personal data, the transmission of which is implicit in the use of Internet communication protocols.
This information is not collected to be associated with identified data subjects. However, by its very nature, it may identify users through the processing and matching of data held by third parties.
This category of data includes the computer IP or MAC addresses of users who visit the Website, as well as the URI addresses (Uniform Resource Identifier) of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file received in reply, the numerical code indicating the status of the reply from the server (successful, error, etc) and other parameters relating to the operating system and computer of the user.
This data is only used to extract anonymous statistical information on how the Website is used and to ensure that it is running properly.

Cookies
Cookies are files or bits of information that are stored on the hard disk of the user’s computer (i.e. files sent by the website server to the user’s browser) while browsing websites.
The cookies saved on the User’s computer cannot be used to recover any data from the hard disk, spread computer viruses or identify and use the User’s e-mail address. Each cookie is unique to the browser and helps the User to access the Website.

* Types of cookies used

Glacom only uses technical cookies, i.e. cookies that help to speed up the browsing and use of its Website.
More specifically, these include:

Necessary Cookies
These cookies are essential for browsing the Website; they enable various tasks such as authentication, validation, management of browsing sessions and fraud prevention.

Functional Cookies
These cookies provide added features and enable the tracking of Users’ preferences, such as language selection or font size.

Performance Cookies
These cookies track the pages visited most often by Users and their activity on the Website. They also immediately identify and resolve any technical problems which the User might encounter when browsing the Website. These cookies store aggregate, anonymous information and are not used to collect personal data for advertising purposes.

Session Cookies
Session cookies aim to speed up the analysis of Internet traffic and to help the User to access the services offered by the Website.  
They do not acquire Users’ personal data for the website. No Cookies are used to transmit personal information, nor are any type of persistent cookies or user tracking systems.
Session cookies are only used to send session identifiers (consisting of random numbers generated by the server), which are required to allow safe and efficient browsing of the Website.
The session cookies used by this Website mean that we do not need to use any other IT procedures that could potentially jeopardise the confidentiality of user browsing, nor do they acquire any personal data that could identify the user.

First-party and third-party cookies
The aforementioned categories of cookies are used directly by Glacom; they are therefore “first-party cookies” from the Website.
However, technical cookies are also used from third party websites, and therefore from third parties, which are sent to the User’s computer via the Website: they are known as “third party” cookies.
Analytics cookies are also “third party” cookies, i.e. cookies that are used by website operators to collect aggregate information on the number of users and how they use the website, and therefore to compile general statistics on the service and how it is used. The analytics cookies used by Glacom are provided by Google Inc. through its Google Analytics service. Google Analytics makes use of cookies in order to allow the Site to analyse the modalities by which users make use of it. The information generated by these cookies on the usage of the Site (including one’s IP address) will be transmitted to Google Inc. on servers located in the United States, and there they will be stored. Google will use such information in the purpose of evaluating the usage of the Site, generating reports on the Site’s activity and providing other services related to the Site’s activity and the usage of the internet. Google could also transfer such information to third parties as by law, whether this was requested or whether such third parties elaborate such information on behalf of Google. Google won’t associate the user’s IP address with any other data detained by Google. Nevertheless, it could technically be possible for Google to identify single users on the basis of data obtained by the elaborations performed. In such regards, refer to cookie policy and related consent form on https://tools.google.com/dlpage/gaoptout?hl=en, through which it is possible to deactivate Google Analytics and therefore prevent the transferral of data to Google Inc.

This Website does not use profiling, “first party” or “third party” cookies.

* User rights
Cookies will only be used on the Website after data subjects have given their consent.
Users can agree to the use of cookies by clicking “OK” on the banner displayed when they first access the Website’s homepage, or by closing the banner and scrolling down the homepage, or clicking on any part (and therefore scrolling down).
However, please remember that the requested consent on the aforementioned banner only refers to the use of “third party” technical cookies and does not include first party technical cookies.
To disable the use of first party technical cookies, Users must change their browser settings by following the instructions below.
If the data subject refuses the use of cookies, they will not be used but certain services may be restricted. In this case, some of the Website’s functions may not run properly and certain services might not be available. Cookies cannot and will not be used to collect Users’ e-mail addresses, nor will they be used to obtain information from Users’ hard disks or their personal and sensitive data.
In any case, Users can disable cookies through the software they use for browsing the Internet (the “browsers”). Many browsers are set up to accept cookies, unless instructed otherwise by the User.
Glacom invites Users to check the cookie settings on their browsers and to adjust them according to their preferences.
The configuration for managing cookies and User preferences is different for each browser. They can be found under the menu of the browser guide and will show you how to change your cookie preferences.
For Internet Explorer™: click here
For Safari™, Safari on iPhone, iPad, or iPod touch: click here
For Chrome™: click here
For Firefox™: click here
For Opera™: click here

To manage their cookie preferences, Users can also visit the website http://www.youronlinechoices.com/uk  and change their cookie settings as they so wish.

3.    Optional data provision
Apart from the specifications on browsing data, the User is free to provide personal data when registering under the “Contacts” section or when subscribing to the Newsletter service, or when sending e-mails containing certain personal data, for example, to request information and/or commercial material or any other communications.
Please note that if you fail to provide this data to Glacom, it may not be possible to fulfil your request.

4.    Data Controller and Supervisor
The Data Controller behind the processing of Users’ personal data for the Newsletter service and for sending other information and/or informative, promotional and advertising material from the Website is Glacom Italia S.r.l., with its registered offices in Toscolano Maderno (BS), Via Trento No 124, under tax code and VAT No 03482190984.
The Data Supervisor is Mr Fausto Dibitonto.
You may also ask Glacom for the updated list of all the other specifically appointed Data Supervisors, pursuant to Article 29 of the Privacy Code, by sending your request to the following e-mail address: privacy@glacom.com.
For any other requests, information, clarifications or questions on the processing of personal data, please send a written request to Glacom at the following e-mail address: privacy@glacom.com.    

5.    Processing methods and purposes

Data storage and access
In its capacity as the Data Controller, Glacom will, either directly or through specifically appointed Supervisors, save Users’ personal data onto special databases stored on the servers provided by the company, Hetzner Online AG, with its registered offices in Stuttgarter Str. 1, 91710 Gunzenhausen (Germany), with whom Glacom has signed a special web hosting contract. This company only performs web hosting services for Glacom and guarantees to comply with all the necessary security measures pursuant to European legislation for the correct processing and protection of personal data.
The servers made available for this web hosting service are located within the European Union, in Germany.
You can read the privacy policy of Hetzner Online AG at the following address: https://www.hetzner.de/en/hosting/legal/datenschutz.
Moreover, to collect and process Users’ personal data, Glacom will use the special databases stored on its own servers located at the offices of Seeweb Srl, Via Caldera No 21, in Milan, and will also conduct all the other processing operations through the Data Controller’s staff specifically appointed for this purpose, or through potential external Supervisors, including for maintenance/upgrading operations.   
All data is therefore solely processed by staff, including technical staff, who have been appointed for the processing or by people authorised to perform maintenance and/or upgrading/improvement operations for the Website. This processing will be based on the principles of fairness, lawfulness, transparency and relevance and will not exceed the purposes of the collection and the subsequent processing.
The databases can only be accessed by qualified individuals in accordance with procedures that guarantee the protection and confidentiality of data, due to the adopted security measures for the prevention of data loss, unlawful or inappropriate use and unauthorised access. The data will only be stored for the time strictly necessary to process Users’ data, depending on their choices, preferences and instructions.

General processing
Glacom will use Users’ data according to the choices that the Users have freely made by giving their consent when the data was collected or thereafter. It will also comply with legal obligations, regulations and European Directives.
Personal data is processed with automated means for the time strictly necessary to achieve the purposes for which it has been collected.
This processing may involve the collection, processing, recording and/or storage of personal data. The personal data of Users who ask for documents or information materials (answers to questions, additional documentation, etc) is solely used for the service requested and is only passed on to third parties when it is strictly necessary in order to handle the User’s request.

Processing operations subject to the consent, communication and dissemination of data

Only with express authorisation from the User will Glacom, through its specifically appointed Supervisor, proceed with the processing of Users’ personal data through the use of automated means for the purposes authorised each time by the User. In order to perform the activities requested by Users in full, Glacom will communicate the personal data provided by Users to third party companies, co-owners or external data supervisors appointed to perform certain activities.
This data will not be circulated.


6.    Security
Personal data is collected and stored securely through the use of technical and organisational procedures and measures adopted to protect and secure the information and data collected on the Website.

7.    Links to external content
The Website might connect or direct you to other websites, services, social networks or external content beyond Glacom’s control. Once the User has left the Website, Glacom cannot protect the User’s personal data or be held liable for the protection and privacy of any personal data that the User might provide to other websites.

8.    User rights
Pursuant to Article 7 of the Privacy Code, Users have the right to obtain confirmation of the existence or otherwise of their personal data, even if not yet recorded, and to request the communication of this data in an intelligible form.
Data subjects have the right to obtain information on:
a) the source of their personal data;
b) the purposes and methods of the processing;
c) the software used in the event of electronic processing;
d) the identity of the data controller, the data supervisors and the designated representative, pursuant to Article 5, paragraph 2;
e) the subjects or categories of subjects to whom the personal data may be disclosed or who may come across this data in their capacity as the designated representative of State, the data supervisor or processor.
Data subjects have the right to obtain:
a) updated, corrected or, where relevant, supplemented data;
b) the cancellation, anonymisation or blocking of any data being processed illegally, including the storage of any data that is not required in relation to the purposes for which it was collected and subsequently processed;
c) confirmation that the parties to which the data has been disclosed or circulated have been notified of the operations specified under points a) and b), including their content, except in the case where this notification proves impossible or requires the use of methods clearly disproportionate to the right being protected.
Users have the right to object, wholly or in part:
a) on legitimate grounds, to the processing of their personal data, even if this data is relevant to the purpose for which it has been collected;
b) to the processing of their personal data for the purpose of sending advertising or direct marketing material, or for carrying out market research and commercial communications.
You may exercise the aforementioned rights by writing to Glacom at the following e-mail address: privacy@glacom.com.  


9.    Changes to this Privacy Policy
While Glacom will not perform any processing operations other than those expressly authorised and/or requested by each User, this Privacy Policy may be amended in order to comply with new legislation or if Glacom changes its data processing policies.
Every updated version of this Privacy Policy will be published on the Website under the appropriate section: Glacom therefore invites all Users to regularly check the Website to keep up-to-date with the latest uploaded version.