Global Technology SA’s privacy policy (GDPR version)
INTRODUCTION
Welcome to the GLOBAL TECHNOLOGY SA’s privacy notice.
Global Technology SA respects your privacy and is committed to protecting your personal data. This privacy notice will
inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from)
and tell you about your privacy rights and how the law protects you.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Global Technology SA collects and processes your personal data
through your use of this website.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may
provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of
how and why we are using your data. This privacy notice supplements the other notices and is not intended to override
them.
CONTROLLER
Global Technology SA is the controller and responsible for your personal data (collectively referred to as” Global Technology
SA”, “we”, “us” or “our” in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If
you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the
data privacy manager using the details set out below.
CONTACT DETAILS
Our full details are:
Full name of legal entity: GLOBAL TECHNOLOGY SA
Name or title of data privacy manager: Pietro Cucciati
Email address: pietro.cucciati@global-technology.ch
Postal address: Via Selva 20, 6990 Cassina d’Agno (TI), Switzerland
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO). We would, however,
appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 20 May 2023.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal
data changes during your relationship with us.
THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those
connections may allow third parties to collect or share data about you. We do not control these third-party websites and
are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice
of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be
identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of
birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers, website.
• Financial Data includes bank account, payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you
have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting
and location, browser plug-in types and versions, operating system and platform and other technology on the devices
you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences,
feedback and survey responses.
• Usage Data includes information about how you use our website and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties
and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data
may be derived from your personal data but is not considered personal data in law as this data does not directly or
indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users
accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it
can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with
this privacy notice.
We may collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity,
religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about
your health and genetic and biometric data) and process these in accordance with your instructions. We may also collect
any information about criminal convictions and offences, if this is required to carry out our services to you in accordance
with our letter of engagement and/or your instructions.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide
that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (i.e, to
provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the
case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding
with us by post, phone, email or otherwise. This includes personal data you provide when you: •Instruct us to provide you with our services; •request marketing to be sent to you; •enter a competition, promotion or survey; or •give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical
Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server
logs and other similar technologies.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and
public sources as set out below: •Technical Data from the following parties:
(a) analytics providers;
(b) advertising networks; and
(c) search information providers.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
• Identity and Contact Data from data brokers or aggregators.
• Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based
inside the EU.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the
following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights
do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
Please see below to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to 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 through our website.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the
legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which
we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process
your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a new client | (a) Identity | Performance of a contract with you |
| (b) Contact | ||
| To provide our services to you including: (a) Store personal data and information and disclose these to external third parties, as defined in the Glossary below. (b) Manage payments, fees and charges (c) Collect and recover money owed to us |
To provide our services to you including: (a) Store personal data and information and disclose these to external third parties, as defined in the Glossary below. (b) Manage payments, fees and charges (c) Collect and recover money owed to us |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To use data analytics to improve our website, products/services, marketing, client relationships and experiences |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about services that may be of interest to you |
(a) Identity (b) Contact |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
| (c) Technical (d) Usage (e) Profile |
MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or
need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you
(we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from
us and, in each case, you have not opted out of receiving that marketing.
THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your personal data with any company outside GLOBAL
TECHNOLOGY SA for marketing purposes.
OPTING OUT
You can ask us or third parties to stop sending you marketing messages by contacting us at any time.
COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you
disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
CHANGE OF PURPOSE
We will only use your personal data 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 you wish to get an explanation as to
how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which
allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above
rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4
above.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we
may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners
may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do
not allow our third-party service providers to use your personal data for their own purposes and only permit them to
process your personal data for specified purposes and in accordance with our instructions.
6. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or
accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those
employees, agents, contractors and other third parties who have a business need to know. They will only process your
personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable
regulator of a breach where we are legally required to do so.
7. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the
purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the
personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which
we process your personal data and whether we can achieve those purposes through other means, and the applicable legal
requirements.
By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for
six years after they cease being clients.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may 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.
8. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge
a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with
your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your
personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not
disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in
relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may 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.
9. GLOSSARY
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you
the best service/product and the best and most secure experience. We make sure we consider and balance any potential
impact on you (both positive and negative) and your rights before we process your personal data for our legitimate
interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless
we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we
assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you
are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance
with a legal or regulatory obligation that we are subject to.
EXTERNAL THIRD PARTIES
• Service providers acting as processors based in the Europe who provide IT and system administration services,
including billing.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, agents and insurers
based in the Europe or abroad.
• Professional advisers acting as legal representatives of counterparties.
• Regulators and other authorities and agencies acting as processors or joint controllers based in the Europe or abroad
who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a
copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate
data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no
good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where
you have successfully exercised your right to object to processing (see below), where we may have processed your
information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that
we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if
applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and
there is something about your particular situation which makes you want to object to processing on this ground as you feel
it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your
personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate
grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your
personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is
unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you
need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify
whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have
chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to
automated information which you initially provided consent for us to use or where we used the information to perform a
contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect
the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not
be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your
consent.
Last update 04 October 2023
