We recommend that users of our mobile application software (“app”) read this privacy statement in full. It sets out the types of personal information we collect about our users when they use our app or when we provide services, as well as how we use and store their personal information and what rights they may have in respect of that information. Our app is not intended for children and we do not knowingly collect data about children.
We are Gaposa Srl, a manufacturer of automation systems for industrial and garage doors, roller shutters and solar protection systems. We are the controller and responsible for your personal information (we refer to Gaposa Srl as “we”, “us” or “our” in this privacy statement). Where we instruct our suppliers, clients and other third parties to use your personal information, these data processors will process your information on our behalf and only on our instructions and for the purposes set out in this privacy statement. We have appointed a Data Protection Officer (DPO) who is our point of contact for all issues relating to the protection of personal information and is responsible for overseeing questions in relation to this privacy statement. If you have any questions about this privacy statement or our privacy practices, please contact us using the contact details set out below.
Full name: MARCO GASPARRINI
Job Title: DIRECTOR
Email address: firstname.lastname@example.org
Postal address: GAPOSA Srl, Via Ete 90, 63900 FERMO (FM) - ITALY
This privacy statement was published on 24th September 2020. We keep it under regular review and any changes we make to it will be, where appropriate, notified to you by email.
Personal information means any information about you from which you can be identified. It does not include information where your identity has been removed (this is anonymous data).
We may collect and use the following personal information about you:
Generally, we collect your personal information directly from you – through your use of our app and services, or in person, by telephone or email. In particular, this may occur in the following circumstances:
Under data protection law, we can only use your personal information if we have a proper reason for doing so, for example:
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
Generally, we do not rely on consent as a legal basis for processing your personal information although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent, in compliance with the rules set out in this section, where this is required or permitted by law.
We will use your personal information for the following purposes and on the following grounds:
We have a legitimate interest in processing your personal information for promotional purposes (see above). This means we do not usually need your consent to send you updates about our products and/or services, including exclusive offers, promotions or information about new products and/or services. However, where consent is needed, we will ask for this consent separately and clearly.
We will not sell your personal information to or share it with other organisations outside the Gaposa group for marketing purposes, except where we remain the controller of your personal information and share it with third parties who act as a data processor on our behalf and only process the personal information on our instructions and for the purposes set out above.
You have the right to opt out of receiving promotional communications by contacting us, using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts, or updating your marketing preferences in your user profile in the app.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We have instructed FAB Controls Ltd to act as a data processor and process your personal information on our behalf and instruction.
We may also share your personal information with:
Your personal information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above. Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see Section 8 below.
We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary to respond to any questions, complaints or claims you raise, to show that we treated you fairly, and to keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this statement. By law we have to keep basic information about our customers (including Identity and Contact Data) for six years after they cease being customers.
When it is no longer necessary to retain your personal information we will securely destroy your personal information in accordance with applicable laws and regulations. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
If, to deliver our services to you, it is necessary for us to share or transfer your personal information outside the European Economic Area (EEA), then some additional safeguards will apply.
Where we need to make a transfer of this nature, we will only do so if such a transfer is safe and your personal information will be secure.
This means that when we transfer your personal information outside the EEA we will only do so where (i) there are Binding Corporate rules in place; or (ii) the country where we are making the transfer to is a country deemed by the European Commission to have an adequate level of protection in place for your personal information; or (iii) if there is no adequacy decision, where we have contractual arrangement with the service provider containing protections for your personal information (the EU Commission approved Standard Contractual Clauses, for example) or (iv) where the service provider is part of an approved scheme.
Under the applicable data protection laws you have a number of rights, as set out below:
If you would like to exercise any of these rights, please contact us.
You will not have to pay a fee to access your data or to exercise any of the other rights. However, we may charge a reasonable fee of your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We have put in place appropriate security measures to prevent personal information from being accidentally lost, used or accessed unlawfully, altered or disclosed. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
Via Ete 90, 63900 – Fermo
Tel: +39 0734 220701
Fax: +39 0734 226389
Gaposa Espana sl
Tel: +34 96 1501380
Fax: +34 96 1519298