According to article 12 and 13 of the EU regulation 2016/679 (hereinafter “GDPR”), Generac Mobile Products S.r.l with its registered offices in Milan (Italy) (”Generac Mobile Produtcs”), in the quality of Data Controller, informs individuals, hereinafter “User(s)” acceding to the websites www.towerlight.com and www.magnum-tl.com (hereinafter the “Websites”) to  obtain technical and commercial information with regards to the products and the activities of Generac Mobile Products and other companies of Generac Mobile Products’ Group, on the scope, manner, nature, communication and disclosure of data collected through the User(s) registrations and website navigation.

1. Types of data

Data can be collected through different types, as follows:

  • Data voluntarily provided by the User

Generac Mobile Products collects data provided voluntarily by the Users on the forms present on the Websites, on paper forms or, in any other manner appropriate to the purpose.

  • Website navigation data

The information systems and software procedures for the Websites operation, on an ordinary basis, acquire some personal data, which transmission is implicit in the use of Internet communications protocols. This information is not collected in order to be associated with any identified data subject; however, it could allow identification of Users due to its own nature, by processing and associating with data held by third parties. This data category includes: IP addresses or name dominions of  computers used by Users connecting to the Websites; addresses in URI (Uniform Resource Identifier) notation of the requested resource; time of request; method used to submit the request to the server;  size of the file obtained in reply; numerical code indicating the state of the reply given by the server (successful, error, etc.) and, other parameters referring to the operating system and IT environment of the User. These data are used only to collect anonymous statistical information about use of the Websites and to check their proper operation, to identify unusual conditions and/or abuse, and will be deleted immediately after processing.

This kind of data could be used to ascertain responsibility on hypothetical cases of internet crime against the Websites; With the exception of this case, data is currently retained for the time required by the relevant legal regulations in order to provide the User with the service requested by him and to guarantee transmission of communication.

  • Cookies

The Websites use cookies to ensure integrity of the registration procedure and to customise them. A cookie is a small size text file, saved in the User’s hard disk from a web page. Cookies cannot be used to execute programs or send viruses to the User’s computer. Cookies are assigned to the User in a unique manner and can be read only by the web server of the domain which sent them.

One of the main purposes of cookies is to help the User save time. For example, if a web page is customised or if one visits a website, the cookie will allow the visited website to recall information specific to the User at the following visits. Use of cookies makes it possible to provide the User with customised contents and facilitates visits to the website. At the following visit to the website, information previously provided may be recovered to simplify use of customised functions by the User.

To send cookies, Generac Mobile Products’s websites may employ web technology based on beaconing, also known as “clear gif” or action tag technology. This technology allows Generac Mobile Products to draw up aggregate statistics on use of the Websites, for example the number of visitors who have interacted with key elements of a page on the Websites, for example links or images. Generac Mobile Products may provide aggregate statistics to its partners.

Users may accept or reject cookies. Most web browsers automatically accept cookies. The User may however change his browser settings so as to reject cookies. Should he decide to reject cookies, it is possible that he will no longer be able to use interactive functions provided on the website.

2. Purpose of the processing

User’s personal data is collected and processed for the following purposes:

  1. To reply to requests (information, estimates, help, etc…) which the Users may make using the email addresses or data forms present on the Websites;
  2. to allow navigation and consultation of the Websites and access to reserved areas;
  3. to perform direct marketing  by email, fax or SMS, for services and/or products similar to those requested;

to draw up studies, research or market statistics, to send advertising information, commercial information or promotional material;

3. Manner of processing and use of the data

User’s personal data will mainly be processed using electronic means, or in any case automatically, according to articles 25 and 32 of the GDPR and in any case through the implementation of the specific security measures in order to prevent loss of data, illicit or improper use and/or unauthorised access.

Data is stored on electronic and/or paper form, in compliance with the applicable laws and limited to the necessary term to achieve its purpose.

4. Legitimacy of the processing and optional or obligatory consent

For the purposes referred to in the above item n. 2 (a and b) submission of data by  User is necessary and, failure to provide data requested, even partially, will result in the impossibility i) to perform the obligations arising from the agreement in which the data subject is involved and/or ii) to provide the offered/requested services; in relation to this purpose, consent is not required and processing is legitimate pursuant to Art. 6 (1) (b) of GDPR.

Processing under item 2(c), carried out for direct marketing purposes on products or services similar to those purchased by the User, finds its applicability pursuant to Art. 6.1.f  of the GDPR, on Generac Mobile Products’s legitimate interest to promote its own products or services in a context where data subject may reasonably expect such processing, to which User may oppose at any time.

Processing carried out for commercial and promotional purposes as described under item 2(d) is based on the User consent pursuant to Art. 6(1)(a) of the GDPR. Submission of Personal data for these purposes is entirely optional and does not compromise make use of the services.

5. Communication and transfer of personal data

User data is collected and processed at the offices of Generac Mobile Products or at the offices of the technical staff appointed for the maintenance of the Websites, called the External Processor.

Without prejudice to those communications made to fulfil legal obligations, all data collected for the purposes set forth under item 2 may be communicated to the following:

  • parties appointed by Generac Mobile Products to perform activities directly related or connected to the delivery and distribution of products or services requested by User;
  • parties that may become aware of data due to their role as Data Processor or as people in charge of the Generac Mobile Products data processing.

Users’ personal data may be transferred to companies belonging to Generac Mobile Products Group based in or outside the EU in order to allow those companies to carry out their own marketing activities, provide information, offers on the products, services and/or further initiatives.

Some countries outside the EU might not guarantee secure and correct data processing; therefore, even though Generac Mobile Products Group polices carefully regulate intercompany transfers protecting personal data, Generac Mobile Products requests Users’ explicitly consent  to data transfer to those Generac Mobile Products Group companies based outside the EU according to article  49 of GDPR. The companies belonging to Generac Mobile Products are Joint Controllers of data processing.

Failure to submit data requested and/or data transfer consent to transfer data to those extra EU countries (that might not guarantee appropriate rules on data privacy) Generac Mobile Products shall not consider the related request.

The data will not in any case be subject to dissemination.

6. User Rights

User has the right to ask Generac Mobile Products, at any time, for access to his Personal data, rectification or erasure of such data (so-called “right to be forgotten”) or to object to their processing in the cases provided for under article 20 of the Regulation; User has the right to restriction of processing in the cases provided for under Art. 18 of the Regulation, and the right to obtain the data concerning him (portability)  in a structured format, of common use and readable from an automatic device, in the cases provided for under Art. 20 of the GDPR.

In any case, User always has the right to lodge complaint with the relevant supervisory authority (Garante della Privacy) pursuant to Art. 77 of the GDPR, should User considers that the processing of his data is contrary to applicable legislation.

Furthermore, pursuant to Art. 7 (3) of the GDPR, User has the right to revoke consent at any time; revocation of consent does not affect the lawfulness of the processing based on the consent obtained before the revocation.

To exercise his rights, User may at any time contact the Data Controller or related Data Processor(s) contacting Generac Mobile Products S.r.l. Via Stazione 3bis – Villanova d’Ardenghi – Pavia – Italy, sending a fax to the number (+39) 0382 400247 or emailing privacy@towerlight.com

7. Changes to this privacy information notice

This Privacy Policy has come into effect on July 2019; Generac Mobile Products may decide to amend or update it in whole or in part, and also to introduce any changes following applicable regulations. In case of substantial changes to the contents of the information notice, Generac Mobile Products will notify Users publishing notices on the home page of the Websites or, as an alternative, sending notice directly to Users. Generac Mobile Products suggests the User should read this privacy information notice from time to time, to keep constantly abreast of the initiatives taken by Generac Mobile Products to protect the confidentiality of collected personal information.

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