As required by the European Union Regulation n. 679/2016 (hereinafter “GDPR“) And in particular in Article 13, below we provide the information required by law regarding the processing of personal data.

We do not intentionally process personal data of children under the age of 16. If we find the existence of data belonging to minors under the age of 16, we will immediately delete them without any prior communication.

The website (hereinafter “Site“) Is owned by GT POLIFILM Sr.l. (hereinafter GTPOLIFILM“).

This information is provided to users who interact with the web services of the Site (hereinafter “Interested“) Not only to comply with legal obligations, but also because transparency and fairness towards the interested parties is a fundamental part of our business.

Navigation within the Site is free and does not require any registration.

  1. Data Controller

The data controller pursuant to art. 4, paragraph 7 of the GDPR is GT POLIFILM S.r.l., with registered office in Via Orazio, 143 – 80122 Napoli and Operational site in Corso Salvatore D’Amato, 75 – 80022 Arzano (NA), Italy, VAT number 06287250630, email: (hereinafter “Holder“).

  1. What are personal data?

Pursuant to Article 4 of the GDPR, personal data are defined as any information concerning an identified or identifiable natural person (interested) directly or indirectly, with a particular reference to an identifier such as the name, an identification number, data relating to the ‘location, an online identifier or one or more characteristic elements of its physical, physiological, genetic, psychic, economic, cultural or social identity.

  1. Provision of data

Personal data will be acquired directly from the interested party, through:

  1. Direct conferment of the same
  2. Automatic acquisition (sections 4.2 and 4.3 “Navigation data” and “Cookies” or similar technologies).
  3. Types of data

The categories of data indicated below (collectively, the “Data”):

  1. Navigation data: the computer systems and software procedures used to operate the Site acquire, during their normal operation, some personal data (such as the IP addresses or domain names of the computers used by users, the pages visited and the date / time of the visit) whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified interested parties but which by their very nature could, through processing and association with data held by third parties, allow users to be identified. These data, recorded anonymously, are used for the sole purpose of obtaining statistical information on the use of the Site and to check its correct functioning. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the Site.
  2. Cookies: to make navigation on this site more efficient and immediate, when users access this website, cookies are used: small text strings that allow you to maintain the connection to the site. Please refer to the cookie information on the GT POLIFILM web page.
  3. Data provided voluntarily by the user: these are personal data freely released by the user to access certain freely chosen services. Failure to provide them may make it impossible to obtain the requested service. Specific information and requests for consent are shown on the pages of the Site dedicated to services on request.
  4. Purpose of the processing and legal bases
  1. Purpose: The Data is processed for the following purposes:
  • prevent or unmask fraud or abuse to the detriment of our Site to allow third parties to carry out technical, logistical and other activities on our behalf;
  • manage your contact request through the special “Contact form” called “Contact GT Polifilm” (name and email);
  1. Legal bases
  • activities related to contact management (examples of activities are: filling in the contact form on the site or more generally sending an e-mail that involve the processing of personal data such as, for example, name, surname, subject; the legal basis of the aforementioned purpose is identified in the contract and pre-contractual measures (Article 6.1, letter b, GDPR);
  • activities related to the execution of the contract to which you are a party, including the pre-contractual phase (examples of activities are: the provision of a service, the response to a request, the request for contact via the “contacts” form (etc.); the legal basis of the aforementioned purpose is identified in the contract and pre-contractual measures (Article 6.1, letter b, GDPR), but also (if applicable) in the legitimate interest (Article 6.1, letter f, RGDP) as regards the necessity to defend a right and as well as in the fulfillment of an obligation of law or regulations in force or to fulfill an obligation imposed by the Authorities (Article 6.1, letter c, GDPR);
  • maintenance of computer systems and devices (the subjects in charge of carrying out maintenance and repairs on the Site may accidentally have access to your personal data. These are completely occasional and unpredictable events and in any case without identification purposes and limited in duration to the execution of the maintenance / repair intervention); the legal basis of the aforementioned purpose is identified in the legitimate interest (Article 6.1, letter f, GDPR).

None of our processing is based on consent. The legal bases on which we operate are: contract, legitimate interest and legal obligation.

We do not carry out treatments with automated decision-making processes or profiling.

  1. Consent and optional / compulsory provision

The processing of your Personal Data, for the purposes described above, may be carried out without your consent. The provision of your data that you undertake to provide us contractually or by law, is mandatory and constitutes a necessary requirement for the conclusion of the contract and failure to provide it will make it impossible for us to execute contracts and other related obligations. Any other provision of your personal data (i.e. for sending requests not yet contracted or for browsing the site) is purely optional. The only consequence of failure to provide the optional will be the inability to provide or perform the requested services.

  1. Communication and dissemination of data

The data collected as part of the service provision may be disclosed to:

  • companies that perform functions strictly connected and instrumental to the operations – including technical ones – of GT POLIFILM services, such as for example suppliers that provide services for the review and verification of advertisements, customer care, companies that provide technical components for the supply some features of the service;

Under no circumstances do we transfer personal data to third parties in any way (including the sale).

Should the Data Controller entrust the processing operations to third parties, the latter will necessarily be appointed as data processors pursuant to Article 28 of the GDPR, after verifying the compliance of their activity with the provisions on the protection of personal data.

The Data Controller will only resort to data processors who present sufficient guarantees to implement adequate technical and organizational measures, so that the processing meets the requirements of the GDPR and guarantees the protection of the rights of the data subject.

  1. Compulsory or optional nature of providing data

The provision of personal data is mandatory only for the processing necessary for the provision of the services offered by GT POLIFILM (any refusal for the purpose of providing the service makes it impossible to use the service).

  1. Methods and duration of the treatment

Personal data will be processed by persons authorized to process the processing acting under the authority of the Data Controller, adequately instructed by the Data Controller himself, in compliance with the provisions of art. 29 of the GDPR through automated tools for the time strictly necessary to achieve the purposes for which they were collected, as well as for any further period necessary to fulfill specific legal obligations.

Except for the hypothesis of ascertaining responsibility in the event of hypothetical computer crimes against the Site, the data relating to navigation on the Site will not be kept for more than 30 (thirty) days.

The Data may be processed both electronically and on paper.

Data relating to telematic traffic, excluding the contents of communications, will be kept for a period not exceeding 6 years from the date of communication, pursuant to art. 24 of Law no. 167/2017, which transposed the EU Directive 2017/541 on counter-terrorism.

GT POLIFILM guarantees the lawful and correct treatment of the Personal Data provided through the Site, in full compliance with current legislation, as well as the maximum confidentiality of the data provided during registration.

All Data is collected according to the indications of the relevant legislation, with particular regard to the security measures provided for by art. 32 of the GDPR for their treatment by means of computerized, manual and automated tools and with logic strictly related to the purposes indicated in article 4 and in any case in order to guarantee the security and confidentiality of the data.

Your personal data will be kept for the time strictly necessary to carry out the purposes described above and to fulfill the obligations established by law. In particular, for the activities related to contact management Your personal data are deleted when the purpose of contact, reply or correspondence is definitively exhausted, for the activitiesrelatedtotheexecutionofthecontracttowhichyouareaparty(includingthepre-contractualphase),your personal data are stored

for the entire duration of the contractual relationship and, once the relationship is concluded, they will be kept for any needs to ascertain / exercise / defend a right or for the fulfillment of a legal obligation or regulations in force or to fulfill an obligation imposed by the Authorities (Article 6.1, letter c, GDPR), for the maintenanceofcomputersystemsanddevices, referring to personal data that we have for the other purposes indicated in this Notice, the retention times coincide with those identified from time to time for the aforementioned purposes.

  1. Categories of recipients

Furthermore, your Personal Data may be disclosed to third parties, for technical and operational needs strictly related to the purposes set out above and in particular to the following categories of subjects:

  1. subjects necessary for the provision of the services offered by the Site including, by way of example, the sending of e-mails and the analysis of the functioning of the Site who typically act as data processors of our reality;
  2. persons authorized by our company to process Personal Data who are committed to confidentiality or have an adequate legal obligation of confidentiality;
  3. judicial authorities in the exercise of their functions when required by the applicable legislation in force.
  4. Transfer of Data abroad

This Site does not share any data collected with services located outside the European Union area.

The Data Controller, however, reserves the right to use cloud services; in which case, the service providers will be selected from among those who provide adequate guarantees in compliance with the applicable legislation in force.

  1. Rights of the interested parties

At any time, you can exercise, with a written request sent to the email , pursuant to art. 7 of Legislative Decree 196/2003 and of the articles 15-22 of the GDPR, the right to:

  • ask for confirmation of the existence or not of their personal data
  • obtain information about the purposes of the processing, the categories of personal data, the recipients or categories of recipients to whom the personal data have been or will be communicated and, when possible, the retention period
  • obtain the correction and deletion of data
  • obtain the limitation of the processing
  • obtain data portability, i.e. receive them from a data controller and transmit them to another data controller without impediments to
  • oppose the processing at any time
  • oppose an automated decision-making process relating to natural persons including profiling
  • asks the data controller to access personal data and to correct or delete them or limit their processing or to oppose their processing, in addition to the right to data portability
  • revoke the consent at any time without prejudice to the lawfulness of the processing based on the consent given before the revocation.

Any requests will be processed at the latest within one month of receipt, except for the possibility of extending this deadline for a further two months, if necessary, taking into account the complexity and number of requests received by the Data Controller.

Furthermore, you can lodge an appeal before the judicial authority (in accordance with the provisions of art.80 of the GDPR and of the art.13 Legislative Decree 101/2018) or a complaint to the Guarantor for the Protection of Personal Data, by:

  • registered letter with return receipt addressed to the Guarantor for the Protection of Personal Data, Piazza di Monte Citorio, 121, 00186 Rome, e-mail to the address: or, fax to the number: 06696773785

It should be noted that the complaint to the Guarantor cannot be lodged if, for the same object and between the same parties, an appeal has been lodged before the judicial authorities.

Any request relating to the Data processed by the Data Controller can be sent by email to the following address

  1. Review clause

This information may be subject to changes. If substantial changes are made to the use of the data relating to the user by the owner, the latter will notify the user by publishing them with the utmost evidence on their pages or through alternative or similar means.


Arzano (NA), 06/09/2021