Circular on the processing of personal data

Last updated: 03 June 2018

Pursuant to Legislative Decree n. 196/2003 (hereinafter, the Privacy Code) as well as, starting from 25 May 2018, by EU Regulation no. 679/2016 (hereafter, the GDPR or, together with the Privacy Code, the Privacy Policy), Gummy Advertising ltd., with registered office in St.Peter street 3 floor, San Gwan, Malta, Fiscal Code and VAT no. 24973309 (hereinafter, the Company or the Data Controller), as data controller, informs you of the methods and circumstances with which it will process personal data and information
– provided to you by one of the following sites: :,, (hereinafter, individually, the Website), or
– provided to the Company by a third party previously authorized by you, as the owner, to the processing of your personal data, giving consent to
the communication to third parties for promotional, commercial and marketing purposes.

Type of data being processed

Personal data

The personal data processed by the Company are the following: name, surname, date of birth, gender, telephone number, residential address, postcode, telephone number, e-mail address. In the event that we collect such personal data directly from you and through the Site, the system stores the IP address of the network you used at the time of registration in order to keep proof of the registration of your consent. Moreover, in the event that your data have a different origin (for example, when we have obtained your data from a third party), the system will store also the IP address of the network you used when you gave your specific consent to the disclosure of your third-party data, including promotional, commercial and marketing purposes.
The registration of the IP address of the network used at the moment of the consent can be useful in order to allow the competent Authorities to carry out any investigative or in-depth investigation deemed appropriate in your interest and against any unlawful act carried out by third parties involving your data.

Navigation data

The computer systems and software procedures used to operate the Site acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified individuals, but which by their very nature could through processing and association with data held by third parties, allow users to be identified.
This category of data includes IP addresses or domain names of the computers used by users connecting to the site, the addresses in the Uniform Resource Identifier (URI), the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (success, error, etc.) and other parameters relating to the operating system and the user’s computer environment. This data, except for the data corresponding to the IP address of the network you used at the time of enrolment for which the same is specified in paragraph 1 above, are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to control correct operation and are deleted immediately after processing.


No personal data of users is acquired by the Site in this regard. Cookies are not used to transmit information of a personal nature, nor are cds used. persistent cookies of any kind, or systems for tracking users. The use of cd. session cookies (which are not stored permanently on the user’s computer and are automatically deleted when the browser is closed) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to allow exploring safetly and efficiently the website. The cd. session cookies used on this site avoid the use of other technologies that could compromise the privacy of users’ browsing and do not allow the acquisition of personal identification data.

Legal basis and purpose of the processing

Promotional, commercial and marketing purposes

Prior to obtaining your explicit consent (except in cases where the Company has obtained legitimate consent your data from a data controller to which you had previously and specifically consented for promotional, commercial and marketing purposes, including communication to third parties), the processing of your data will take place to achieve the purposes related and instrumental to sending, always exclusively from the Company, on a periodic basis of offers, discounts and / or other commercial initiatives of the Company or of our commercial partners. Failure to provide consent for these purposes will not allow you to receive such offers, discounts and / or commercial communications. The company shall specify that by accepting the treatment for promotional, commercial and marketing purposes, your data will not be disclosed to any third subject.
In fact, in the absence of your specific consent, the Company never shares your data with the subjects who use the services of the same to spread their commercial offers. Also, even if you decide to consent to the processing of data for the purposes specified in this point, will still have the right to oppose, in whole or in part, to the processing for the aforementioned purposes, making it simple request to the Company, without any formalities, to the addresses already indicated at the bottom of this document.

Communicating to third parties for promotional, commercial and marketing purposes

Before obtaining your explicit consent (except in the case where the Company has legitimately obtained your data from a data controller to whom you previously and specifically consented for promotional, commercial and marketing purposes, including communication to third parties), your data may be used by the Company in order to communicate them to third parties (as better specified in the next point called “Data Recipients”) for sending commercial communications (marketing) and / or direct sales on own initiatives and its partners, by e-mail, fax, telephone, sms and any other remote communication technology – including communications via social media. The consent to the processing of your data for this specific purpose data is absolutely optional and your refusal to treatment will not affect in any way the possibility of continuing to receive communications for the other purposes described above. Also, even if you decide to consent to the processing of data for the purposes specified in this point, you will still have the right to object, in whole or in part, to the processing for the aforementioned purposes, making a simple request
to the Company, without any formalities, to the addresses already indicated in the footnote to the present information.

Owner, persons in charge of processing

Person in charge of processing

Person in charge of processing of data provided by users is the Company, as defined, in the person of its legal representative pro tempore.

Indications of the processing

The subjects employed as personnel of the Company, or other external subjects purposely and in accordance with the data processors, may become aware of your data as they are responsible for the execution of certain processing operations connected and instrumental to the provision of the service and / or additional purposes permitted by you.

Responsible for processing

The data controllers appointed by the data controller, we inform you that with reference to the processing concerning the delivery activity by means of e-mail messages of communications for promotional, commercial and, in general, marketing purposes, the Company has appointed.
External processors responsible for the following subjects:
– Advice Global ltd. with registered office in St.Peter street 3 floor, San Gwan, Malta,
– FreeMedia Internet S.L. based in C / Filà Cordòn, 36. Pol. Ind. Cotes Altes, Acoy (03804), Alicante, Spain.
Also, for the storage of a back-up copy of your data, the Company may use the hosting services offered by the following entity, appointed for this
purpose as external data controller:
– Advice Global ltd. with registered office in St.Peter street 3 floor, San Gwan, Malta,

– Gidinet based in Via Medeghino, 15 – 20141 Milan (MI).

Treatment modalities

The processing of your personal data will be carried out using manual or electronic means, with methods strictly related to the purposes indicated above and, in any case, in order to guarantee the security, protection and confidentiality of the data. further specifies that the processing of personal data is carried out in ways that minimize the risk of destruction or loss, even accidental, of the data itself, unauthorized access or treatment not allowed and not in accordance with the purpose of the collection. In particular, in the processing of data, the Company and the individuals identified as data controllers will take appropriate organizational, physical and logical measures to guarantee their security and confidentiality, with the use of any appropriate measures to enable and guarantee the classification, storage and confidentiality of the data (eg, by way of example, periodic checks, storage in closed cabinets, fire protection devices, electrical continuity, user identification, antivirus check, periodic backups, etc.). Personal data may be processed by employees, collaborators and consultants of the Company, specifically appointed as persons in charge of processing, for the performance of specific operations necessary for the pursuit of the aforementioned purposes, under the direct authority and responsibility of the Company and in accordance with the instructions that will be from the same imparted.

Addresses of the data

The data potran not be communicated, your prior express consent, and exclusively for the purposes indicated above, to the categories of subjects operating in the following economic / merchandise categories: Services and products relating to the communications and technology sector and the like.
Finance and banking sector: financial entities , insurance, investment, social security and the like.
Free Time: pay TV, editorials, sports, collectibles, photography, pastime, games, transport, navigation, tourism (hotels, tour operators, travel agencies, airlines, etc.), aerospace, gardening, hobbies, lottery, competitions, communication and entertainment, art, music and similar.
Distribution and trade: electronics, information technology, image and sound, fashion, accessories, clothing, textiles, bazaars, cosmetics and health, chemical and pharmaceutical hygienic and biotechnology, agro-food, supermarkets, beverages, office equipment, furniture, and the like.
Automotive: products and services related to aut or, industrial vehicles, cycles and motorcycles, trucks, mechanics and metallurgy, and the like. Energy and water:
products related to electricity, hydrocarbons, gas, water and utilities, and the like.
Education, training, education, universities, and the like.
Communication and services: advertising agencies, marketing, events, consultancy, advertising, PR, advertising dealers, media centers, telecommunications, market research, mobile marketing agencies, and the like.
Ecology and environment.
Construction, civil engineering and real estate products / services: construction, decoration, home, design, real estate agencies, and the like. Fairs and events, and the like.
Computer science, internet, e-commerce sites, etc.

In particular, regardless of this product list, ‘Now we specify that your data, in the case of specific consent to the purposes of processing communication and / or transfer to third parties for promotional, commercial and marketing purposes, will be communicated to third-party companies that they will use according to what is provided in the informative reports provided by them, for example through communication to your e-mail address.
For completeness, we inform you that in some cases these companies, in their capacity as independent data controllers, may prefer to write directly to inform you in detail on how they will process your data, what opportunities they have in store for you and how you can do to exercise your rights to them. These subjects, acting as independent data controllers, after sending appropriate information to the interested party, will process your data in order to send you promotional, commercial and marketing communications, via e-mail, fax, telephone, text messages and any other technology distance communication, without prejudice to your right to oppose the processing for such purposes at any time, making a simple request without any formalities to the relevant data controller.

Data retention period

You may object to the processing of your personal data at any time by sending an e-mail. -mail to the address indicated at the end of this Notice. You can also unsubscribe from our lists by clicking on the appropriate hyperlink for the deletion contained at the bottom of our e-mails. In these cases, your data will be deleted in the time necessary to complete your request. Even after your cancellation, although we will no longer send you our commercial communications or communications on behalf of third parties, we may continue to retain some of your data at order to be able to prove that you have obtained valid consent for all communications that occurred until your cancellation request. We will not share this information with anyone except as permitted by law. If you receive our communications on the basis of a contractual relationship with the Company, we will delete your information only when this relationship is interrupted and / or according to the provisions of the contract and the applicable law. Finally, in case the e-mail sending systems encounter problems in the delivery of the communications to your e-mail address, or in the case in which they were to find the inactivity of your account for a prolonged period, the Company it may cancel your data after an unspecified period of time, between 6 and 10 years.

Transferring data abroad

The Company may use services offered by third-party companies, which will process your data as managers of the treatment and in accordance with the instructions given to them by the Company. It is possible that some of the treatments carried out by the managers take place outside the territory of the European Union, such as in the USA. In these cases, the Company uses legal instruments to ensure adequate protection of your personal data (eg by requesting such counterparts to sign Standard Contractual Clauses).

Your rights

As an interested party, you are granted the following rights on personal data collected and processed by the Data Controller as part of the treatment described above:

Right of access

You have the right to obtain from the Company confirms that personal data processing is in progress for you and in this case, to obtain access to personal data and the following information: (i) the purposes of the processing; (ii) the categories of personal data in question; (iii) the recipients or categories of recipients to whom your personal data have been or will be disclosed, in particular if recipients of third countries or international organizations; (iv) when possible, the retention period of the personal data provided or, if not possible, the criteria used to determine this period; (v) the right to lodge a complaint with a supervisory authority.

Right of rectification, opposition and cancellation

You have the right to obtain the correction of inaccurate personal data concerning yourself and, having regard to the purposes of the processing, the right to obtain the integration of incomplete personal data, including by providing an additional declaration. In addition, you have the right to obtain the deletion of your personal data if there is one of the following reasons: (i) personal data are no longer necessary for the purposes for which they were collected or otherwise processed; (ii) the data are processed unlawfully; (iii) you have revoked the consent on the basis of which the Owner has the right to process your data and there is no other legal basis that allows the Data Controller to process the data; (iv) you opposed the processing activity and there is no legitimate overriding reason; (v) personal data must be deleted to fulfil a legal obligation.
However, the Company has the right to disregard the exercise of the aforesaid cancellation rights if the right to freedom of expression and information prevails or for the exercise of a legal obligation or to defend one’s right in court. At any time, you can oppose the processing even for only one of the purposes of treatment described above.
In addition to the above, starting from May 25, 2018, by virtue of the full operation of the GDPR, you are also recognized the following rights:

Right to data portability

You have the right to receive in a structured format, in common and legible, your personal data provided to the Company and processed by it on the basis of consent, as well as the right to transmit such data to another data controller indicated by you without any impediment.

Right to limit the treatment

You have the right to obtain the limitation of processing by the Company: (i) for the period necessary for the Data Controller to verify the accuracy of such personal data concerning you which you have contested the accuracy; (ii) in case of unlawful processing of your personal data; (iii) when you need your data to be processed for the assessment, exercise or defense of a right in court; (iv) for the period necessary for the verification of the possible prevalence of the legitimate reasons of the Owner with respect to your request for opposition to the treatment. You can exercise the rights listed above by contacting the Company through the contact details indicated in the following paragraph. Remember that you are guaranteed the right to contact the competent data protection authority in case you believe there has been a non-compliant treatment of your data.

Company contacts

You can exercise your rights at any time, by request to be sent to the Company as the data controller by e-mail at


Registered office: CMS House, Third Floor, St. Peter’s Street, San Gwann, SGN, 2310 – MALTA