GDPR

Last updated: September 19, 2024

Data Controller under the General Data Protection Regulation (GDPR)

Geoffrey B. Small Made in Italy S.r.L.

via dell'Artigianato, 4

30014, Cavarzere, Venezia, VE Italy

E-mail: geoffreyb.small@gmail.com

(“We”, "Our", "GBS," "Our Company")

1. Data protection and joint controllership

a. We are pleased that you have decided to visit this website and showing your interest in our offerings. The security of your personal data is very important to us. This data protection information explains how we collect and process your personal data, for what purposes and on what legal bases the data processing takes place, as well as your rights and options as a data subject.

b. Our data protection information for the use of our websites and the Mercedes-Benz data protection policy do not apply to your activities on the websites of social networks or other providers that you can access via links on our pages. We therefore ask you to inform yourself about the data protection guidelines published on the websites of these providers.

c. In the context of the analysis and marketing activities on these websites described in more detail below, we work closely with the other controllers, as specified above. We process data about your visit to our websites jointly with the other controllers using the following technologies:

• For analysis purposes:

- Google Analytics

The processing of personal data for the purposes stated above only takes place if you consent to it, as described in more detail in section 5.c. of this data protection information.

The controllers have concluded an agreement on the joint processing of personal data, defining their respective responsibilities in accordance with the legal requirements. For further information on the essential contents of this agreement, please contact us using the contact details provided in Section 9.d. of this Data Protection Notice.

2. Collection and processing of personal data

a. When you visit our websites, we store certain data about the browser and operating system used, the date and time of the visit, the access status (e.g. whether you were able to call up a website or received an error message), the use of the website functions, any keywords entered, the frequency of access to individual websites, the names of the files called up, the amount of data transferred, the website from which you accessed our websites and the website you visit from our websites, either by clicking on links on our pages or by entering a domain directly into the input field of the same tab (or window) of your browser in which you opened our websites. Furthermore, for security reasons, in particular to prevent and detect possible cyber attacks on our websites or attempted fraud, your IP address and the name of your Internet Service Provider will remain in our archive for a period of seven days.

b. Further personal data are only processed by us if you provide them in the context of a registration, a contact form, a chat, a survey, a price quote or for the execution of a contract, and even in these cases exclusively on the basis of a consent given by you or to the extent permitted by applicable law (see section 7).

c. There is no legal or contractual obligation to provide your personal data. However, it is possible that certain functions of our websites depend on the provision of personal data. If you do not provide your personal data in such cases, this may result in the limited or unavailability of certain functions.

3. Purpose of use

The personal data collected during visits to our websites are used exclusively to make navigation as easy as possible for users and to protect our IT systems from cyber attacks and other illegal activities.

b. If you provide us with additional personal data, e.g. in the context of a registration, a chat, a contact form, a survey, a competition or for the purpose of executing a contract, we use this data for the aforementioned purposes, for customer management and - if necessary - for the purpose of processing and accounting of any business transactions, only to the extent necessary in individual cases.

c. For other purposes (e.g. displaying personalized content or advertising based on your usage behavior), we and any selected third parties use your data to the extent that you have given your declaration of consent (= approval) within our Consent Management System under "Settings" in the footer at the bottom of the website.

d. We also use personal data to the extent that we are legally obliged to do so (e.g. storage for the purpose of fulfilling commercial or tax obligations, disclosure in accordance with government or legal orders, e.g. to law enforcement agencies).

4. Transmission of personal data to third parties; social plugins; use of service providers

a. Our websites may also contain offers from third parties. When you click on such offers, we transmit your data to the necessary extent to the respective providers (for example, the indication that you have found this offer on our site and any other information already provided by you on our websites in this regard).

b. On our websites, we may have linked the use of so-called "social plugins" from social networks such as Instagram, and Facebook to the conditions set out below.

When you visit our website, the social plugins are deactivated, i.e. they do not transmit any data to the operators of the respective social networks. If you want to use one of the social networks, you must click on the respective social plugin to establish a direct connection to the servers of the respective social network.

If you have a user account with the social network and are logged in when you activate the social plugin, the network can associate your visit to our websites with your user account. If you want to prevent this, you must log out of the social network before activating the social plug-in.

When you activate a social plug-in, the social network transmits the content made available directly to your browser, which may integrate it into our website. In this situation, data transmissions can also take place that are initiated and controlled by the respective social network. Your connection to a social network, the data transfers taking place between the social network and your system, and your interactions on that platform are governed exclusively by the privacy policies of the respective social network.

The social plug-in remains active until you deactivate it or delete your cookies (see Section 5.d).

c. If you click on a link in an offer or activate a social plug-in, your personal data may be transmitted to providers in countries outside the European Economic Area that, according to the European Union (“EU”), do not guarantee an “adequate level of protection” in accordance with EU standards for the processing of personal data. Please consider this possibility before clicking on a link or activating a social plug-in and thereby enabling the transmission of your data.

d. We also may use qualified service providers (e.g. IT service providers, marketing agencies) to operate, optimize and protect our Internet pages. The personal data collected would be transmitted to these providers only to the extent strictly necessary for the preparation and use of the Internet pages and their functionalities, for the pursuit of legitimate interests or if you have given your consent (see Section 7). Further information on any recipients can be found using the contact details provided in Section 9.d. of this Data Protection Notice.

5. Cookies

a. Cookies may be used when you visit our website. Technically, these are so-called HTML cookies and similar software tools such as Web/DOM Storage or Local Shared Objects (so-called “Flash cookies”), which we collectively refer to as “cookies”.

b. Cookies are small files that are stored on your desktop, notebook or mobile device when you visit a website and read later. This makes it possible to determine whether there has already been a connection between your device and the web pages, which language or other settings you prefer, to offer you certain functions (e.g. online shop/dealer reservation services) or to recognize your interests based on usage. Cookies may also contain personal data.

c. Whether and which cookies are used when you visit our website depends on which sections and functions of our pages you have used and whether or not you have given your consent to the use of non-technically necessary cookies in our Consent Management System. Further information and optional options can be requested using the contact details provided in Section 9.d. of this Data Protection Notice.

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d. The use of cookies also depends on the settings of your Internet browser (e.g. Microsoft Edge, Google Chrome, Apple Safari, Mozilla Firefox). Most browsers are configured to accept certain types of cookies automatically; however, you can usually change this setting. You can also delete any cookies already on your device at any time. Web/DOM Storage and Local Shared Objects can be deleted separately. For more details on how this works, please refer to the instructions provided by the manufacturer of your browser or device.

e. The declaration of consent (= approval), as well as the rejection or deletion of cookies depend on the device used and the Internet browser currently in use. If you use multiple devices and/or Internet browsers, your decisions and/or settings may vary on a case-by-case basis.

f. Please note that the decision not to use or delete cookies may result in the unavailability or limitation of some accessible functions on our Internet pages.

6. Security

We take technical and organizational security measures to protect your data managed by us from manipulation, loss, destruction and access by unauthorized persons. Our security measures are constantly improved in line with technological developments.

7. Legal bases for data processing

a. Where you have given consent to the processing of your personal data, this constitutes the legal basis for the processing (Art. 6 para. 1 lit. a) GDPR).

b. For the processing of personal data for the purpose of initiating or performing a contract with you, the legal basis is Art. 6 para. 1 lit. b) GDPR.

c. Where the processing of your personal data is necessary for the fulfillment of our legal obligations (for example data retention), we are authorized to do so pursuant to Art. 6 para. 1 lit. c) GDPR.

d. We also process your personal data for the purposes of pursuing our legitimate interests, as well as the legitimate interests of third parties, in accordance with Art. 6 para. 1 lit. f) GDPR. These legitimate interests include not only maintaining the functionality of our IT systems, but also the (direct) marketing of internal and external products and services (unless this is done with your consent), as well as the documentation of business contacts in accordance with the legal provisions. Based on the necessary balancing of interests, we take into account in particular the nature of the personal data, the purpose of the processing, the circumstances of the processing and your interest in the confidentiality of your personal data.

8. Deletion of personal data

Your IP address and the name of your Internet Service Provider, which we store for security reasons, are deleted after seven days. We also delete your personal data as soon as the purposes for which we collected and processed them no longer apply. Beyond these periods, data storage takes place only if this is necessary in accordance with laws, regulations or other legal provisions of the European Union or third countries, provided that they guarantee an adequate level of data protection, to the observance of which we are subject. If deletion is not possible in individual cases, the corresponding personal data will be highlighted with the aim of limiting their future processing.

9. Rights of the data subject

a. As a data subject, you have the right to access information (Art. 15 GDPR), to rectification (Art. 16 GDPR) and to erasure of data (Art. 17 GDPR), to restriction of processing (Art. 18 GDPR) and to data portability (Art. 20 GDPR).

b. If you have consented to the processing of your personal data by us, you have the right to withdraw this consent at any time. The withdrawal of consent does not affect the lawfulness of data processing carried out up to this point on the basis of the previously granted consent, nor the right to further processing of the aforementioned data by virtue of another legal basis, for example for the fulfillment of legal obligations (see section “Legal bases of data processing”).

c. Right to object. For reasons relating to your particular situation, you have the right to object at any time to the processing of your personal data carried out on the basis of Art. 6 para. 1 lit. e) GDPR (processing necessary in the public interest) or Art. 6 para. 1 lit. f) GDPR (data processing based on a balance of interests). If you object, we will continue to process your personal data only if we can demonstrate compelling legitimate grounds that outweigh your interests, rights and freedoms, or if the processing is necessary for the establishment, exercise or defense of legal claims. Insofar as we process your personal data for direct marketing purposes for the purposes of legitimate interests based on a balance of interests, you also have the right to object to this at any time without stating a reason.

d. For any requests or further clarifications, please contact the following address:

geoffreyb.small@gmail.com

e. If you believe that the processing of your personal data violates the law, you have the right to lodge a complaint with a competent data protection authority (Art. 77 GDPR).

10. Newsletter

If you subscribe to a newsletter offered on our website, unless you agree to extended use, the data provided during the subscription will only be used to send the newsletter. You can unsubscribe at any time using the unsubscribe function provided in the newsletter.

11. Transmission of data to recipients outside the European Economic Area

a. When using service providers (see section 4. d.) and forwarding data with your consent (= approval) to third parties (see section 3.c), personal data may be transmitted to recipients in countries outside the European Union (“EU”), as well as Iceland, Liechtenstein and Norway (= European Economic Area, EEA), including in particular the United States of America and India, and processed there.

b. In the opinion of the European Union, an “adequate level of protection” for the processing of personal data in accordance with EU standards is guaranteed in the following countries (so-called “adequacy decision”): Andorra, Argentina, Canada (limited), Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, South Korea, Switzerland, United Kingdom, United States of America (limited), Uruguay. With other recipients, we agree to apply EU standard contract clauses, binding corporate rules or other permitted mechanisms to ensure an “adequate level of protection” in accordance with legal requirements. For more information on this, please use the contact details provided in Section 9.d. .