Complete information for site visitors
We wish to inform you that the European Regulation no. 679 of 27 April 2016 (the “General Regulation on Data Protection” – below, the EU Regulation 2016/679 – also known by the English acronym GDPR) provides for the protection of individuals with regard to the processing of personal data. According to the law, this treatment will be based on fundamental principles such as, for example, correctness, lawfulness, transparency, and protection of your privacy and your rights.
It is specified that the rules regarding the processing of personal data also include navigation data and cookies.
In particular, we inform all users who connect to the website www.gbsapri.it (hereinafter, the “Site”), both registered and unregistered, that personal data collected, acquired from third parties, or spontaneously conferred by the interested parties through the various options on the Site, will be processed in a lawful and correct manner, in compliance with the principles established by the EU and Italian law.
We neither process “particular” personal data on a large scale, nor do systematic monitoring and profiling, nor locate users via GPS. However, following access to restricted areas of the Site, specific profiling may be carried out in order to identify the user type for the sole purpose of providing customized and adequate services or products to the specific needs of individual users.
In the light of the above, and in accordance with articles 13 and 14 of EU Regulation 2016/679, we provide the following information
- Name of Data Holder
The Data Controller is GBSapri S.p.A., in the person of its legal representative, based in Via Nomentana 183, 00161 – Rome (hereafter, GBSapri or “Data Controller”). GBSapri can be reached at the email address email@example.com.
- Data Protection Officer
The Data Protection Officer is Dr. Pasquale Davide, available at the email RPD@GBSAPRI.IT.
- Legal basis of processing
The legal basis of the processing is identified in the voluntary consent given by the customer as well as in the current national and EU legislation.
- Object of the treatment
Browsing our Website may involve the acquisition of “Personal Data” (as defined in Article 4 of the 2016/679 EU Regulation) which concern the Site visitor?
In particular, the personal data processed by GBSAPRI through its website are as follows:
Data provided voluntarily by the user
In order to request informative material or other communications, the user is free to provide personal data, reported via application forms, or supplied in the course of contacts with the company office. Failure to provide such data may make it impossible to receive what has been requested.
The completion of the request forms or the optional, explicit and voluntary sending of e-mails to the addresses indicated on this Site, entail the subsequent acquisition of the sender’s address, as well as any other personal data entered. The personal data acquired are processed in order to allow GBSapri, in the person of the Data Controller, to process the request made. The data will not be disseminated and may be made available to GBSapri collaborators (Managers or Representatives) who are authorized to process them.
The user assumes full responsibility in the case of publication or sharing, through this Site, of personal data relating to third parties and guarantees to having the right to communicate or disseminate such data, freeing the Data Holder from any liability to third parties.
The computer systems and software procedures used to operate this Website acquire, during their normal operation, some personal data, the transmission of which being implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified subjects but which by their very nature could allow, through processing and association with data held by third parties, to the identification of users. This category of data includes IP addresses or domain names of the computers used by users who connect to the Site, the addresses in the Uniform Resource Identifier (URI) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (success, error, etc.) and other parameters relating to the operating system and the user’s computer environment.
Furthermore, the data acquired could be used to ascertain responsibility in the event that computer crimes are committed to the detriment of the Website.
- Purpose and legal basis of the data treament
The data collected will be processed by GBSapri, without the need for explicit consent pursuant to art. 6, paragraph 1, letter b) of EU Regulation 2016/679, to provide the services listed in the Conditions of Use. These services are mainly aimed at obtaining and/or comparing updated insurance quotes and connecting users with insurance partners for the purchase of policies, without prejudice, with the sole responsibility of GBSapri for its service of insurance brokerage.
In particular, the data will be processed:
for the provision of insurance consulting and brokerage services, including, in particular, the drawing up of personalized insurance estimates, the saving of research and estimates, and the processing and forwarding of updated insurance quotes;
to allow for the purchase of insurance products chosen by the user through the Site and offered by subjects (mainly insurance companies and insurance intermediaries) with which GBSapri has stipulated or will stipulate commercial agreements for free collaboration;
to allow for the purchase of insurance products chosen by the user through the Site and offered by subjects (mainly insurance companies and insurance intermediaries) with which GBSAPRI has stipulated / stipulated commercial agreements for free collaboration;
to facilitate the use of the entire Site, in its various sections and versions, for example by recognizing users returning to the Website, simplifying and customizing the user experience, saving searches and estimates for each type of product;
for customers consulting and telephone assistance in order to promptly respond to the needs of users as related to an insurance product on the Site;
to provide up-to-date estimates for future deadlines and to carry out periodic insurance check-ups related to the comparative insurance coverage;
to collect and manage customer feedback on the service provided;
for the administrative management of relationships, including commercial ones, between GBSapri and the parties with whom it has stipulated or will stipulate commercial or collaboration agreements;
to respond to comments and indications sent by customers;
for the monitoring and prevention of fraud and unauthorized use of the service;
comply in general with legal and regulatory obligations.
In general, GBSapri will not proceed with the collection or processing of “particular Data”, as per art. 9 of the 2016/679 EU Regulation (relating, for example, to health). However, in order to provide certain customized products and services, it may be necessary to complete questionnaires that require these particular data. These questionnaires will be attached to the estimate calculated through the Site.
In order to pursue its legitimate interest, Collected data will also be processed by GBSapri without the need for explicit consent, (pursuant to article 6, paragraph 1, letter f) of EU Regulation 2016/679) to promote its services to previous users by sending informative and commercial e-mail communications. In all cases it remains the users’ right to oppose the processing of data concerning them at any time.
It is understood that such processing of data is carried out in compliance with the provisions of article 130, paragraph 4, of Legislative Decree no. 196/2003 and s.m.i. (the Privacy Code).
The data collected may be processed by GBSapri, subject to the explicit and free consent of the data subject pursuant to Article 6, paragraph 1, letter a) of EU Regulation 2016/679, for the following purposes:
- the sending of promotional communications and advertising material, the offer of products and/or services of own or third parties, the carrying out of surveys and market research, by any means including, in particular, the use of telephone with operator and/or automated systems (e.g. SMS, MMS, fax, automated replies, push notifications, social media).
It is understood that failure to consent to the processing of your data for these purposes does not affect the right to use them in order to promote the services offered by GBSapri to users who have already used it, as already specified in this paragraph
- the profiling of users for commercial and marketing purposes on the basis of the use of the GBSapri.it website, of the interest shown for the various products / services and exposure to advertising.
- Origin and nature of the data
The collection of data can be done through the Site, through the analysis of navigation or the spontaneous insertion of the same by the interested party, using the modules made specifically.
If the user has entered certain data in the site – such as, for example, personal data, telephone and telematic contact details, as well as bank details, and, if any, payments communications, in addition to any other data, the Data Holder is obliged to perform their processing.
The conferment is therefore mandatory since, in case of non-release of consent or revocation of the same, the request cannot be dealt with.
Any incorrect or insufficient communication of the requested data may result in the total or partial impossibility of executing the requests of the interested party or of obligations related to the commitments undertaken, with consequent possible non-correspondence of the treatment results to the agreements or obligations imposed by norms and regulations.
Finally, additional data may be requested to up-date any promotional campaigns or offers to the interests of customers and/or other involved subjects. Therefore, such data is not mandatory and any refusal to process or revocation of consent will not affect the establishment or continuation of the main relationship.
- Data relative to minors under the age of 16
Children under 16 cannot provide data without the consent of the parent or guardian.
GBSapri will not be in any way responsible for any false statements that should be provided by minors and, should the falsity of the declaration be ascertained, any personal data and any information obtained will immediately be deleted. In any case, consent to the processing of data by children over sixteen is authorized until the eighteenth year for access to information services only. However, minors under eighteen years can not approve and sign terms and conditions of service.
Types of cookies used
The following types of cookies are used
Functional Technical Cookies
they have the purpose of storing consent choices for their use by the user. For the installation of these cookies, the prior consent is not required.
THIRD PARTY Cookies
these are related to services provided by third parties. The third party provides these services in exchange for information regarding the user’s visit to the Website. Third-party cookie suppliers are also obliged to comply with the relevant legislation. For this reason, we refer to the links of the website pages of the third part, where the user can find the consent forms for cookies and their relative information.
The following, in particular, are used:
Google Adwords Conversion (// www.google.com/intl/it/privacy/ads/privacy-policy.html).
Microsoft Atlas (// privacy.microsoft.com/it-it/fullnotice.mspx).
No other use is made of cookies for the transmission of personal information. The use of persistent cookies and session cookies (which are not stored permanently on the user’s computer and disappear when the browser is closed) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) required to allow the safe and efficient exploration of the Site. The so-called session cookies used on this site avoid the use of other technologies that could compromise the privacy of users’ browsing and do not allow the acquisition of personal identification data.
By selecting the OK button shown by the superimposed banner, the user authorizes the installation of cookies on the device used by the interested party. The settings of downloaded cookies can be changed through the browser features. It is also possible to block the installation of third-party cookies and remove previously installed cookies, including those containing preferences for cookies. To adjust or change the browser settings, refer to the software or application manufacturer’s guide. Disabling cookies can determine the malfunction of the Site or part of it
- Communication and dissemination
The data processed through the Website are not intended for dissemination. The Data Controller does not require and has no interest in disseminating particular data (health, genetic, biometric, etc.) or penalties, without prejudice to legal obligations. However, the aforesaid data may be communicated to:
subjects who need access to the data of the interested party for purposes related to the relationship with the Data Controller (credit institutions, financial intermediaries, electronic money institutions and payment management, debt collection companies, customer verification companies, carriers, etc. .);
consultants, collaborators, service companies, within the limits necessary to carry out the task conferred by the Holder;
subsidiaries and / or affiliated companies that can access data, within the limits strictly necessary to carry out the tasks entrusted to them by the Holder.
User data may be transferred to third parties in the fulfilment of obligations arising from laws or regulations (Institutions, Law Enforcement, Judicial Authorities, etc.) or for activities directly or indirectly related to the relationship established, such as insurance companies and insurance intermediaries with whom GBSapri has commercial or collaboration agreements in place, in order to provide estimate services and the possible purchase of insurance policies, and in particular for the consultation of legitimately accessible databases, useful for determining the applicable tariff and verify the possession of specific requirements required for access to specific benefits and advantages, for the preparation and stipulation of insurance contracts, as well as for telephone assistance and recontacting customers in relation to the saved estimates.
In order to identify in greater detail the purposes, processing methods, subjects or categories of subjects to whom the personal data may be communicated, the scope of dissemination of the data, the rights of the data subject, the manner in which these can be exercised and the identification details of GBSapri, please refer to the privacy policies of the insurance companies and the intermediary insurance partners.
Furthermore, the data collected may be communicated to subjects operating within the European Union, or in countries that guarantee the same level of protection as foreseen by the EU Regulation 2016/679 and by Legislative Decree 196/2003, where applicable.
- Data transfer
Where expressly permitted by the interested party, the user’s data may be communicated to subjects operating in non-EU countries. In order to ensure the highest level of protection, such data processing will be subject to the most restrictive rules. For purposes directly or indirectly related to the activity of GBSapri, The user’s data may be transferred to third parties, even for a fee, on condition that the interested party give express consent.
- Data conservation
Your data will be kept for 10 years from the termination of the relationship if related to pre-contractual, contractual and legal obligations. Personal data may also be processed for a longer period, where an interruption and/or suspension action is triggered that prescribes the extension of data retention. Data provided by the user for marketing purposes will be retained for a period not exceeding 24 months or until the user asks to withdraw his consent with regard to the aforementioned purposes.
After this period, the data will be deleted and/or rendered anonymous so as not to allow, even indirectly or by linking other databases, to identify the data subjects.
As an interested subject, the user will have the right to lodge a complaint with the Supervisory Authority.
In order to quickly solve problems encountered by our customers and to do so in the best way possible, we invite users to make complaints directly to the GBSapri by sending an email to firstname.lastname@example.org or by registered letter addressed to GBSapri SpA, via Nomentana, 183, Rome – 00161.
- Rights of the interested
As an interested subject, the user will have the right to ask the Data Controller to access your personal data, correct inaccurate personal data and integrate them, or delete data (so-called “right to be forgotten”), limit processing or the right to object to data processing. Finally, you will have the right to request data portability.