[www.oldgentlemenltd.com]
User Privacy Policy
You are visiting www.oldgentlemenltd.com
This policy is provided pursuant to Article 13 of Legislative Decree No. 196 of June 30, 2003, Updated May 14, 2018 (hereinafter, the "Privacy Code") and concerns the processing of personal data provided by users who interact with the services or promotional initiatives offered by the Data Controller through its website or third-party websites with which it has commercial agreements (hereinafter, the "Site").
The data controller is Old Gentlemen Ltd.
This document describes how Old Gentlemen Ltd. processes personal data. We therefore recommend that you read this Privacy Policy carefully.
Old Gentlemen Ltd. provides the following privacy policy pursuant to Article 13 of Legislative Decree No. 196/2003 (hereinafter, the "Privacy Code") and Article 13 of EU Regulation 2016/679. 13 of EU Regulation 2016/679 of 27 April 2016 (hereinafter, the "Regulation"; the Regulation and the Privacy Code are together referred to as the "Applicable Legislation"), as the data controller of the personal data of users registered on the Site (hereinafter, the "Users").
This Site and any services offered through the Site are reserved for individuals who are at least eighteen years of age. Old Gentlemen Ltd. therefore does not collect personal data relating to individuals under the age of 18. Upon request from Users, Old Gentlemen Ltd. will promptly delete all personal data inadvertently collected relating to individuals under the age of 18.
Old Gentlemen Ltd. takes the utmost account of its Users' right to privacy and the protection of their personal data. For any information regarding this privacy policy, Users may contact Old Gentlemen Inc. at any time using the following methods:
By sending an email to privacy@oldgenrtlemenltd.it
Purpose of Processing
Users' personal data will be lawfully processed by Old Gentlemen Ltd. pursuant to Article 6 of the Regulation for the following processing purposes:
The User data collected by Old Gentlemen Ltd. through the completion of forms includes: name, surname, date of birth, province of residence/domicile, gender, email address, telephone number, employment, as well as any personal information the User voluntarily discloses. Unless the User gives Old Gentlemen Ltd. specific and voluntary consent to the processing of their data for marketing purposes pursuant to paragraph 2 below, the above data will be used by Old Gentlemen Ltd. to: verify the User's identity (including through email address validation); telemarketing and teleselling activities carried out by e-service or partner companies; administrative and accounting purposes: i.e., to carry out organizational, administrative, financial, and accounting activities, such as internal organizational activities and activities necessary for the fulfillment of contractual and pre-contractual obligations;
The provision of personal data for the processing purposes indicated above is optional but necessary, as failure to provide such data will make it impossible for the User to use the services offered by Old Gentlemen Ltd. on the Site.
Additional processing purposes: Telephone interviews with registered users to propose commercial offers, Preparation of quotes or commercial offers, Newsletters, Sending commercial or informational text messages, Sending commercial or informational emails.
With the User's free and optional consent, some of the User's personal data (i.e., first name, last name, email address, etc.) may also be processed by Old Gentlemen Ltd. for marketing purposes (telephone interviews to propose commercial offers, preparation of quotes or commercial offers, newsletters, sending commercial or informational text messages, sending commercial or informational emails), or so that Old Gentlemen Ltd. may contact the User by post, email, telephone (landline and/or mobile, with automated calling or call communication systems with and/or without the intervention of an operator), and/or SMS and/or MMS to propose the purchase of products and/or services offered by Old Gentlemen Ltd. and/or third-party companies, and to present offers, promotions, and commercial opportunities.
Consent to the processing of personal data for this purpose is free and optional. Even if consent is given, the User may revoke it at any time by making a request to Old Gentlemen Ltd. using the methods indicated in the following paragraph 6.
The User may also easily object to further promotional communications via email. Once consent is revoked, Old Gentlemen Ltd. will send the User an email confirming the withdrawal of consent. If the User wishes to revoke their consent to the sending of promotional communications by telephone, but would still like to receive promotional communications via email, or vice versa, please send a request to Old Gentlemen Ltd. using the methods indicated in the following paragraph 6.
Old Gentlemen Ltd. informs that, following the exercise of the right to object to the sending of promotional communications via email, it is possible that, for technical and operational reasons (e.g., contact list creation already completed shortly before Old Gentlemen Ltd. receives the request to object), the User may continue to receive some additional promotional messages. If the User continues to receive promotional messages after 24 hours have passed since exercising the right to object, please report the problem to Old Gentlemen Ltd. using the contact details indicated in the following paragraph 6.
Processing Methods
The processing of Users' personal data will be carried out using manual and electronic means, with logic strictly related to the purposes themselves and, in any case, in a manner that guarantees the security and confidentiality of the data.
The personal data of Site Users will be retained for the time strictly necessary to carry out the primary purposes related to the User's participation in the competition and described in the previous paragraph 1, or in any case for the time necessary to protect the interests of both the Users and Old Gentlemen Ltd. in civil proceedings.
In the cases referred to in the previous paragraph 2, Users' personal data will be retained for the time strictly necessary to carry out the purposes described therein and, in any case, for no longer than twenty-four (24) months[1].
Scope of communication and dissemination of data
Users' personal data may be disclosed to employees and/or collaborators of Old Gentlemen Ltd. responsible for managing the Site. These individuals, who have been instructed to do so by Old Gentlemen Ltd. pursuant to Article 29 of the Regulation, will process the User's data exclusively for the purposes indicated in this policy and in compliance with the provisions of the Privacy Code.
Users' personal data may also be disclosed to third parties who may process personal data on behalf of Old Gentlemen Ltd. as "external data processors," such as, for example, IT and logistics service providers for the operation of the Site, outsourced or cloud computing service providers, professionals and consultants, and companies tasked with sending promotional emails on behalf of Old Gentlemen Ltd. Users have the right to obtain a list of any data processors appointed by Old Gentlemen Ltd. by making a request to Old Gentlemen Ltd. using the methods indicated in paragraph 6 below.
Users' personal data may be disclosed by Old Gentlemen Ltd., to the extent necessary to perform contractual obligations and/or comply with legal obligations, to independent third-party data controllers, such as notaries and Chamber of Commerce officials responsible for identifying the winners of the prize competition organized on the Site, the Ministry of Economic Development, as well as the third parties indicated in the prize competition rules, to whom the data must be disclosed. Necessarily disclosed to allow the User to redeem any prizes won (e.g., travel agencies, ticket offices, hotels, etc.).
Further communications: communication of data to Old Gentlemen Ltd. Partners.
With the User's free and optional consent, the User's personal data (name, surname, address, email address, telephone number, IP address, and registration timestamp) may be disclosed by Old Gentlemen Ltd. to the following categories of third-party companies:
(i) landline and mobile telephone companies;
(ii) companies operating in the publishing sector (print, internet, television, and new media);
(iii) companies operating in the e-commerce sector for products and services;
(iv) companies operating in the energy sector;
(v) companies operating in the travel and leisure sector;
(vi) companies operating in the professional and/or educational training sector;
(vii) advertising agencies, media centers, and contact centers;
(viii) companies operating in the food sector;
(ix) NGOs and non-profit organizations;
(x) companies operating in the financial and insurance sectors (collectively, the "Old Gentlemen Inc. Partners")
(xi) companies operating in gambling regulated by the State Monopolies (AAMS).
Old Gentlemen Ltd. Partners, as independent data controllers, will process the User's personal data for their own marketing purposes (direct sales, sending advertising materials, and commercial communications) and may contact the User by mail, email, telephone (landline and/or mobile, with automated calling systems or call communication with and/or without the intervention of an operator), and/or SMS and/or MMS to propose the purchase of products and/or services offered by the same categories of third-party companies and/or other companies and to present the User with offers, promotions, and commercial opportunities. Once the transfer has taken place, the Old Gentlemen Ltd. Partner will be responsible for providing Users with the necessary information pursuant to art. 14, paragraph 3, of the Regulation, all information required by the same Article 14 of the Regulation.
Old Gentlemen Ltd.'s Partners may process the User's personal information, for example, through "sponsored questions": when the User responds affirmatively to a specific question relating to a promotion or survey, Old Gentlemen Ltd. may provide the above data to the User in order to contact them and provide them with information and offers.
Please note that the content or privacy policies of third-party Old Gentlemen Ltd. Partners' websites may differ from those of Old Gentlemen Ltd. itself. Old Gentlemen Ltd. strongly recommends reviewing the terms and conditions and privacy policies of such websites, as Old Gentlemen Ltd. is not responsible for the conduct of Old Gentlemen Ltd. Partners and third-party websites.
Failure to consent will not affect your ability to register on the Site and participate in the prize competition organized on the Site.
Even if you have given your consent, you may withdraw it at any time by making a request to Old Gentlemen Ltd. using the methods indicated in paragraph 6 below. Old Gentlemen Ltd. will suspend the communication of your data to Old Gentlemen Ltd. Partners within forty-eight (48) hours of receiving your request for withdrawal. Old Gentlemen Ltd. will notify Old Gentlemen Inc. Partners of the User's withdrawal of consent, but will not be liable if the Old Gentlemen Ltd. Partner continues to use the User's data. Old Gentlemen Ltd. informs that the User's personal data will be processed by Old Gentlemen Ltd. Partners as independent data controllers, based on the specific information provided by Old Gentlemen Ltd. Partners to Users. Any requests to opt out of receiving further commercial communications from Commercial Partners to whom the data has already been communicated by Old Gentlemen Ltd. must therefore be addressed directly to such Old Gentlemen Ltd. Partners.
Rights of Data Subjects
Users may exercise the rights guaranteed to them by Applicable Law by contacting Old Gentlemen Ltd. in the following ways:
By sending an email to privacy@oldgentlemenltd.it.
The User must provide Old Gentlemen Ltd. with all the details necessary to exercise their rights, as well as any supporting evidence deemed useful to Old Gentlemen Ltd.
Old Gentlemen Ltd. will analyze the request and define the necessary steps to be taken (if necessary) to provide a proper response. Old Gentlemen Ltd. will contact the User if it requires any additional information and will provide written feedback on the outcome of the analysis within a reasonable timeframe.
Pursuant to Applicable Law, Old Gentlemen Inc. informs Users that they have the right to obtain information on:
(i) the source of the personal data;
(ii) the purposes and methods of processing;
(iii) the logic applied in the event of processing carried out with the aid of electronic means;
(iv) the identification details of the data controller and data processors;
(v) the entities or categories of entities to whom the personal data may be communicated or who may become aware of it.
Furthermore, Users have the right to obtain:
a) access to, updating, rectification, or, where interested therein, integration of their data;
b) the deletion, anonymization, or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which it was collected or subsequently processed;
c) certification that the operations referred to in letters a) and b) have been notified, including their content, to those to whom the data was communicated or disseminated, except where such disclosure proves impossible or involves a manifestly disproportionate effort compared with the right being protected.
Furthermore, Users have:
a) the right to withdraw consent at any time, if the processing is based on their consent;
b) the right to data portability (the right to receive all personal data concerning them in a structured, commonly used, and machine-readable format), the right to restriction of processing, and the right to erasure ("right to be forgotten");
c) the right to object:
i) in whole or in part, on legitimate grounds, to the processing of personal data concerning them, even if pertinent to the purpose of collection;
ii) in whole or in part, to the processing of personal data concerning them for the purpose of sending advertising materials or direct selling or for carrying out market research or commercial communications;
iii) where the personal data are processed for direct marketing purposes, the right to object at any time to the processing of their data for such marketing, including profiling to the extent that it is related to such direct marketing.
d) if they believe that the processing of their personal data violates the Regulation, the right to lodge a complaint with a supervisory authority (in the Member State of their habitual residence, place of work, or place where the alleged violation occurred). The Italian supervisory authority is the Italian Data Protection Authority, located in Piazza di Monte Citorio no. 121, 00186 – Rome (http://www.garanteprivacy.it/).
Any request received from Users will be processed by Old Gentlemen Ltd. within one month of acceptance of the request. To help Old Gentlemen Ltd. identify the personal data to which the User refers, the User is requested to include all details that will allow Old Gentlemen Ltd. to identify the relevant personal data. To ensure that the User's data is not disclosed to an unauthorized party, Old Gentlemen Ltd. may require the User to provide proof of identity before any action is taken or personal data is disclosed.
Old Gentlemen Ltd. reserves the right to make changes to this Policy. Any updates will be posted on this page. Users are advised to consult the Policy from time to time to ensure they are always informed of the current Policy. If Old Gentlemen Ltd. deems any updates to be material, they will be notified in advance and by appropriate means to allow them to exercise their rights pursuant to this paragraph.
Continued use of the websites or services offered by Old Gentlemen Ltd. will be deemed acceptance of these changes by the User. If the User does not accept the terms of this Policy, they are requested to refrain from using the Site and/or accessing the services offered by Old Gentlemen Ltd. and/or to revoke any consent previously granted.
Old Gentlemen Ltd. is not responsible for updating all links displayed in this Policy. Therefore, whenever a link is not functional and/or up-to-date, Users acknowledge and agree that they must always refer to the document and/or section of the websites linked to.
Other data archives and cross-border transfers
Regarding these data transfers, we note that for all destination countries, secure data transfer is guaranteed in accordance with EU data protection and privacy regulations. We also specify that in the event of data transmission to non-EU countries, before this occurs, Old Gentlemen Ltd. declares its commitment to verify the correct application of the applicable data processing regulations applied by the partners in question. Only after checking these procedures, reviewing the privacy policy, and validating the transfer by the data controller and data processor will the data be transferred.
Retention Period
Your personal data will be collected for up to 3 years by Old Gentlemen Ltd., as explained below, unless a data controller requests us to collect data for a shorter period. Please note that our partners have their own retention periods and rules; please consult their privacy policies for more details. We can store your review and associated data securely indefinitely, but only for the purpose of responding to a customer's request for access to the data.
This privacy policy was last updated on June 1, 2023.
[1] As required by the General Provision of the Italian Data Protection Authority (Garante per la protezione dei dati personali) consumer guarantees.
Cookies
Cookies are small text files that websites visited by users send to their terminals (e.g., computers, tablets, smartphones, notebooks, etc.), where they are stored before being re-transmitted to the same websites on the same user's next visit, in order to improve access. While browsing a website, users may also receive cookies from other websites or web servers (so-called "third-party" cookies) on their terminals. This occurs because the website or app may contain elements such as images, maps, sounds, or specific links to web pages on other domains hosted on servers other than the one hosting the requested page. In other words, these are cookies set by a website other than the one they are currently visiting.
Cookies can be technical and/or profiling.
Old Gentlemen Ltd. does not use profiling cookies, either its own or those of third parties, but only uses technical cookies, for which consent is not required. Specifically, the following cookies are used:
– Session or navigation cookies: these allow access to the services available for each type of user and to load any customizations to the interface and functionality of the website.
- Analytics cookies: these are used directly by the website and/or app operator to collect analytical information, in anonymous and aggregate form, on how users use the website and monitor its performance.
- Functional or customization cookies: These are cookies used to recognize and remember your preferences and allow you to access a version of the site based on predefined criteria, such as the language used.
How to block or delete cookies: Each user can set their own privacy preferences in their browser so as not to store cookies, delete them after each visit or each time you close the browser, or even accept only website or app cookies and not third-party cookies. If you choose to delete Old Gentlemen Ltd. cookies, access to some features and areas of the site may be impaired or limited, and in any case, not fully satisfactory.
