This Privacy Policy ("P.P.") is applied to the processing of personal data carried out by General Logistics Systems Italy S.p.A, with registered office in San Giuliano Milanese (MI), Via Basento 19 (hereinafter referred to as "GLS Italy" or "Data Controller" or even just " Controller") through the application made available by GLS Italy through the Apple App Store and Google Play platforms available on iOS and Android operating systems ("App") which if installed, provides access to various services, differentiated by type of User ("Visitor", "Basic", "Occasional" and "Subscriber"), as indicated in article 2 of the Terms and Conditions, available at the following Terms ad Conditions.
The Data Controller collects and processes your personal data, by computer and/or telematic means, in accordance with the principles of Regulation (EU) 679/2016 ("Regulation") and Legislative Decree 196/03 and subsequent additions and amendments ("Privacy Code").
Your data will be:
- processed lawfully and fairly;
- collected and recorded for specified, explicit and legitimate purposes, and used in other processing operations in terms not incompatible with those purposes;
- accurate and, if necessary, updated;
- relevant, adequate and limited to what is necessary in relation to the purposes for which they are collected and subsequently processed;
- kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which they were collected and subsequently processed.
In particular, personal data will be processed for the following purposes:
- for the activation and operational management of the online services and tools offered by the App (e.g. "Flex Delivery Service" and "Shop Delivery Service") and for the management of the related administrative-accounting purposes. In particular, depending on the type of User to which you belong, you may benefit from different services, as better described in the Terms and Conditions.
With regard to these purposes, the legal basis for the processing of your personal data is the performance of the service you expressly requested and for the fulfilment of legal and regulatory obligations.
- for registration on the App and account creation. With regard to these purposes, the legal basis for the processing of your personal data is the performance of the service you expressly requested and for the fulfilment of legal and regulatory obligations.
- for the association of your GLS web profile to the account created on the App and, where possible, with the association to any active subscription contracts signed with GLS/franchisee. With regard to these purposes, the legal basis for the processing of your personal data is the performance of the service you have expressly requested and for the fulfilment of legal and regulatory obligations.
- for Users belonging to the "Visitor", "Basic" and "Subscriber" types, for the sending of operational communications, such as information on strikes and on the possibility of release with the Flex Delivery service, through push notifications. In this case, the legal basis for the processing of your personal data is your express, free and optional consent, which you may express and at any time withdraw, however, affecting your ability to use the services offered by accessing the settings on your device.
- to send you information and communications, including promotional communications, regarding new services offered by GLS Italy. In this case, the legal basis for the processing of your personal data for such purposes is represented by the legitimate interest of GLS Italy in sending you information communications and updates regarding services similar to those you use and of potential interest to you, pursuant to recital 47 of the Regulation: therefore, your consent is not required, but you may object to the processing at any time.
- for the performance of marketing activities, such as the sending of informative and promotional material and commercial communications on GLS Italy's services and/or products through push notifications. In this case, the legal basis for the processing of your personal data is your express, free and optional consent, which you may express and at any time withdraw, without prejudice to the possibility of using the services offered by accessing the settings on your device.
- with your prior consent, to allow you to use specific services (e.g. "find shop locations") through the geolocation of your device's position. In this case, the legal basis for the processing of your personal data is represented by your express, free and optional consent, which you can withdraw at any time, through the features of your device, by enabling and disabling the position detection for the App, being able to use the services even without the use of geolocation. The geolocation function is disabled by default, only the User with an active manifestation is able to enable it and withdraw it from time to time.
- for optional participation in surveys aimed at measuring User satisfaction in order to improve the services offered. Participation will be requested through pop-ups with which the User may choose whether or not to participate. Non-participation may be expressed by closing the banner ("X"). The information collected in the survey will be processed and treated in an anonymous aggregate manner. Survey results, without any information that can identify the User, may be shared with GLS Group companies and GLS's business partners (e.g. franchisees).
- for the pursuit of the legitimate interests of GLS Italy and/or third parties (including GLS Group companies and franchisees), such as, for example, the right of defence in court, the management of complaints and litigation, the possible recovery of judicial and extra-judicial debts, the prevention of fraud and/or unlawful activities, which, according to the assessments carried out, do not prevail over your fundamental rights and freedoms and which represent the legal basis for the processing.
- for purposes connected with the fulfilment of legal obligations, regulations, national and European Union rules, and arising from provisions issued by authorities entitled under law to process such data, which constitute the legal basis for the processing.
The provision of your personal data for the purpose of providing the services and using the online tools offered by the App is always optional. However, if you decide not to provide them, it may not be possible to provide the services in whole or in part.
Similarly, the provision of your consent where required for the performance of specific purposes is entirely optional and failure to provide it will in no way preclude the possibility of using the services and/or registering with the App.
Moreover, GLS Italy, through the App, may also collect data from any user that is not provided voluntarily but whose acquisition is automatic and implicit during the use of the App, and in particular
- browsing data: the App may use some information that is automatically generated during its use, to collect statistics and take the necessary actions to improve the functionality of the App and the security of the platform used to provide the services.
The App does not require the GPS coordinates of the Device (as defined in the Terms and Conditions), which will only be acquired if you have activated the option on the Device, nor does it access information included in the calendar, address book or contact list of the Device.
The data provided by you as well as the data collected by the App within the scope of its services (e.g. IP address) will not be disclosed and may be communicated, also abroad in non-EU countries, exclusively for the purposes and means described above, to the categories of subjects listed below:
- collaborators, consultants, companies that GLS Italy uses to perform tasks of a technical or organisational nature (such as IT service providers), or with which GLS Italy collaborates, for the purpose of the provision and operation of its services ;
- persons, companies or professional firms providing assistance and consulting services to GLS Italy, with particular, but not exclusive, reference to accounting, administrative, legal, tax and financial matters;
- Group companies, franchisees and business partners of GLS Italy, for the marketing purposes outlined above, where required by law, subject to your consent;
- subjects whose right to access the data is recognized by law or by orders of the authorities. The subjects belonging to the above-mentioned categories will use the data as autonomous data controllers according to the law or as data processors duly appointed by GLS Italy. For information on the individual recipients of the communication, please write to the e-mail address dataprotection@gls-italy.com.
In connection with the provision of services in the territory related to the express courier activity of GLS Italy, your personal data may be communicated to the companies territorially competent for the management of such services and, possibly, in case of international shipments to non-EU countries, also transferred there. For such communications and transfers, moreover, pursuant to art. 49 of the Regulation, your consent is not required since they are necessary "for the conclusion or performance of a contract concluded in the interest of the data subject between the controller and another natural or legal person". Should the extra-EU transfer of your personal data not fall within the above-mentioned hypotheses, GLS Italy will adopt the necessary privacy measures to ensure the lawfulness of such transfers, for example by signing standard contractual clauses approved by the European Commission.
.
The data are processed for the time necessary to provide the services you requested and to carry out the activities connected and instrumental to the same, as illustrated in paragraph 1 above, and are delete when are no longer necessary in relation to the purposes for which they were collected or otherwise processed, including any limitation periods provided for by the Civil Code. On the other hand, the data collected for marketing purposes will be retained until they are withdrawn or objected, after which they may be stored in anonymous form for analysis and statistical purposes.
You, as a data subject, may exercise at any time, by contacting GLS Italy, the rights listed in Articles 15 to 21 of the Regulation, and in particular:
- to obtain confirmation that personal data are being processed and, if so, to ask the Data Controller for access to information relating to such processing (e.g. purposes, categories of data processed, recipients or categories of recipients of the data, storage period, etc.);
- request the rectification of inaccurate or incomplete data;
- request the data controller to delete the data (e.g. if the personal data are no longer necessary for the purposes for which they were collected, if the consent on which the processing is based is withdrawn, etc.)
- request the restriction of the processing (e.g. in the event of a dispute as to the accuracy of the data; if the processing is unlawful and you object to the deletion of the personal data; if the data are necessary for the exercise or defence of a right in court, even if the Controller no longer needs them; in the event of the exercise of the right to object, for the time necessary to verify the existence of legitimate grounds).
- receive in a commonly used and machine-readable format (e.g. pdf) personal data concerning you and transmit them to another data controller, or obtain direct transmission from one data controller to another, if technically feasible (so-called data portability).
You also have the right to object, in whole or in part, on legitimate grounds, to the processing of personal data concerning you, as well as the right to object, even in part in relation to the various means of communication, to the processing of personal data for the purposes of commercial information, advertising or marketing.
You may exercise the aforementioned rights by contacting the e-mail address dataprotection@gls-italy.com as well as the e-mail addresses indicated in the Privacy Policy at www.gls-group.com/it.
Finally, if you consider that the processing of the data provided violates data protection legislation, you have the right to file a complaint with the Data Protection Authority (www.garanteprivacy.it).
In order to facilitate GLS Italy in promptly replying to your requests to exercise the above-mentioned rights, we invite you to fill in the form downloadable here and send it to the e-mail address dataprotection@gls-italy.com as well as to the e-mail addresses indicated in the Privacy Policy at www.gls-group.com/it.
The Data Protection Officer for GLS Italy and the companies belonging to the GLS Group in Italy, domiciled at GLS Italy, can be contacted at the e-mail address dataprotection@gls-italy.com.
GLS Italy may make changes to this P.P. at any time, giving notice thereof by e-mail. Should the changes be particularly significant and/or have a significant impact on your rights, GLS Italy may ask you to read the notice again when you open the App.
In addition to the information provided in this P.P., GLS Italy remains at your complete disposal to answer any questions you may have concerning the processing of your personal data.
For further information, please write to the e-mail address: dataprotection@gls-italy.com.