Privacy Policy
Information notice on the processing of personal data
Last updated: July 2026
I – GENERAL INFORMATION
1. General information
1.1 This Privacy Policy contains information concerning the processing of personal data carried out through the website www.gearlineconsulting.com, associated with the Gearline Consulting brand.
1.2 This information notice is provided pursuant to Article 13 of Regulation (EU) 2016/679, the General Data Protection Regulation (“GDPR”), and the applicable Italian legislation on the protection of personal data.
1.3 This information notice is intended to inform Users of the website about the categories of personal data processed, the purposes of processing, the legal bases, the methods of processing, retention periods and the rights granted to data subjects under the legislation in force.
1.4 The website is intended for Users over the age of 18 and for persons acting mainly in a professional, entrepreneurial or business capacity.
II – PARTIES INVOLVED IN THE PROCESSING OF DATA
2. Data Controller
2.1 The Data Controller is the person or entity that determines the purposes and means of the processing of personal data.
2.2 With reference to this website, the Data Controller operates under the Gearline Consulting brand.
2.3 For any clarification concerning the processing of personal data or for the exercise of the rights granted under the legislation in force, Users may contact the Data Controller using the following contact details:
Gearline Consulting
Website: www.gearlineconsulting.com
E-mail: info@gearlineconsulting.com
Telephone: +39 324 872 8906
Territorial reference: Turin, Italy
3. Data Processors
3.1 In carrying out activities connected with the management of the website and related services, Gearline Consulting may use external providers that process personal data on behalf of the Data Controller.
3.2 Such parties may include, by way of example, providers of hosting services, domain services, e-mail services, technical website maintenance, IT security, communication tools, newsletters and statistical analysis.
3.3 Where necessary, such parties are appointed as data processors pursuant to Article 28 GDPR, or operate as independent data controllers according to their respective roles and responsibilities.
4. Place and methods of processing
4.1 Personal data are processed using IT, telematic and organisational tools, in accordance with the principles of lawfulness, fairness, transparency, minimisation, accuracy, integrity and confidentiality.
4.2 Processing operations connected with the management of the website are carried out through the technical infrastructure and providers necessary for the operation of the website itself, including hosting, domain management, e-mail and maintenance services.
III – DATA PROCESSED
5. Types of data processed
5.1 The website may collect technical information relating to browsing, including through log files and statistical tools, in order to enable the website to function, verify its correct use, maintain adequate security levels and obtain aggregated information on the use of the pages.
5.2 The following personal data of Users may also be collected and processed through the website:
first name and surname, if voluntarily provided by the User;
e-mail address, if voluntarily provided by the User;
telephone number, if voluntarily provided by the User;
company, professional role, company website or other professional information that may be entered in forms or communications;
IP address and other technical data connected with browsing;
technical cookies and, where applicable, cookies or similar statistical tools.
5.3 The User is invited not to transmit data that are not relevant to the request and, in particular, not to send data belonging to special categories pursuant to Article 9 GDPR, such as data relating to health, religious or philosophical beliefs, political opinions, trade union membership or other strictly personal information that is not necessary.
5.4 In the event of the spontaneous submission of curricula vitae, job applications or collaboration requests, the data contained in the communication will be processed solely to assess the request received and, where necessary, will be subject to a specific information notice.
IV – PURPOSES, LEGAL BASIS AND RETENTION
6. Purposes of processing
6.1 Personal data may be processed for the following purposes:
6.1.1 to enable the correct technical functioning of the website;
6.1.2 to ensure the security of the website and prevent abuse, unauthorised access or improper use;
6.1.3 to respond to requests sent by Users through contact forms, e-mail or other professional channels;
6.1.4 to manage professional, commercial or pre-contractual communications with companies, partners, potential clients or other counterparts interested in the services of Gearline Consulting;
6.1.5 to send newsletters, updates, professional content, market analyses and informational communications to Users subscribed to the service;
6.1.6 to analyse the use of the website in aggregated form and improve content, navigation, page structure and digital communication;
6.1.7 to comply with obligations provided for by the applicable legislation;
6.1.8 to establish, exercise or defend a right of the Data Controller, including in judicial or extrajudicial proceedings.
7. Legal basis for processing
7.1 The legal bases for processing are as follows:
7.1.1 for the technical functioning and security of the website, the legitimate interest of the Data Controller in ensuring the proper functioning, security and protection of the website;
7.1.2 for responding to the User’s requests, the performance of pre-contractual measures taken at the request of the data subject or the legitimate interest of the Data Controller in managing professional communications;
7.1.3 for professional or commercial communications in a B2B context, the legitimate interest of the Data Controller in developing its business, in compliance with the fundamental rights and freedoms of the data subjects;
7.1.4 for the sending of the newsletter, the User’s freely given, specific, informed and revocable consent;
7.1.5 for statistical analysis of the use of the website, the legitimate interest of the Data Controller in improving the website and its digital content, or the User’s consent where required by the applicable legislation on cookies and tracking tools;
7.1.6 for compliance with legal obligations, the need to comply with obligations laid down by law;
7.1.7 for the protection of the Data Controller’s rights, the legitimate interest in preventing abuse, managing any disputes and defending its rights.
8. Data retention period
8.1 Personal data are retained for the period strictly necessary to achieve the purposes for which they were collected, unless retention is required to comply with legal obligations or to protect the rights of the Data Controller.
8.2 Data sent through contact forms, e-mail or other professional channels are retained for the time necessary to manage the request and any subsequent professional communications.
8.3 Data processed for the sending of the newsletter are retained until consent is withdrawn or the User requests deletion.
8.4 Technical and statistical browsing data are retained according to the settings of the tools used and as indicated in the Cookie Policy.
8.5 Data that may be necessary to comply with legal obligations or to protect the rights of the Data Controller may be retained for the period provided for by the applicable legislation or for the time necessary to manage any disputes.
V – NEWSLETTER AND INFORMATIONAL COMMUNICATIONS
9. Newsletter
9.1 Users may subscribe to the Gearline Consulting newsletter through the relevant form available on the website or through other channels made available.
9.2 The newsletter may contain updates, professional content, market analyses, observations on international markets, topics relating to export development, digital presence for export and the services offered by Gearline Consulting.
9.3 Subscription to the newsletter is optional and is based on the User’s consent.
9.4 The User may withdraw consent and unsubscribe at any time through the unsubscribe link included in the communications received or by writing to info@gearlineconsulting.com.
9.5 Withdrawal of consent does not affect the lawfulness of processing carried out before such withdrawal.
VI – NATURE OF DATA PROVISION
10. Natura del conferimento dei dati
10.1 The provision of browsing data necessary for the technical functioning of the website is necessary to allow access to and consultation of the pages.
10.2 The provision of data through contact forms or e-mail is optional. However, failure to provide the necessary data, such as an e-mail address or the content of the request, may prevent Gearline Consulting from responding properly.
10.3 The provision of data for subscription to the newsletter is optional. Failure to provide such data will only make it impossible to receive the newsletter.
VII – TRANSFER OF DATA TO NON-EU COUNTRIES
11. Trasferimento dei dati verso Paesi extra UE
11.1 Some service providers used for the operation of the website, technical management, communication, newsletter or statistical analysis may process data outside the European Economic Area.
11.2 In such cases, the transfer takes place in compliance with the conditions set out in Articles 44 et seq. of the GDPR, including adequacy decisions of the European Commission, standard contractual clauses or other applicable legal instruments.
VIII – SICUREZZA
12. Security measures
12.1 Gearline Consulting processes personal data in a lawful, fair and transparent manner, adopting reasonable technical and organisational measures to protect data against unauthorised access, loss, disclosure, modification or unauthorised destruction.
12.2 Access to the data may be granted only to authorised persons or external providers involved in the management of the website, communication, newsletter, IT security or other necessary services.
IX – COOKIES AND SIMILAR TOOLS
13. Cookie
13.1 The website may use technical cookies necessary for the functioning of the pages and the correct use of the content.
13.2 The website may also use cookies or similar tools for statistical purposes, in order to understand the use of the website in aggregated form and improve its content, structure and navigation.
13.3 Cookies are small text strings that the websites visited may send to the User’s device, where they are stored and then sent back to the same websites on subsequent visits.
13.4 For more information on the types of cookies used, their purposes, retention periods and how to manage or disable them, please refer to the Cookie Policy.
14. Cookie di profilazione
14.1 Profiling cookies are tools designed to create profiles relating to the User, including for the purpose of sending commercial communications or advertising messages in line with preferences expressed during browsing.
14.2 Where such tools are used, the User’s consent will be requested in accordance with the methods provided for by the applicable legislation.
X – LINKS TO EXTERNAL WEBSITES AND SOCIAL NETWORKS
15. Link esterni e social network
15.1 The website may contain links to third-party websites or to Gearline Consulting social media profiles.
15.2 By clicking on such links, the User leaves the Gearline Consulting website. The processing of data carried out by third-party websites or social platforms is governed by their respective privacy notices, over which Gearline Consulting has no control or responsibility.
XI – RIGHTS OF THE DATA SUBJECT
16. User rights
16.1 The User may exercise, within the limits and under the conditions provided for by the GDPR, the following rights:
right of access to personal data;
right to rectification of inaccurate data;
right to erasure of data;
right to restriction of processing;
right to object to processing;
right to data portability, where applicable;
right to withdraw any consent given;
right to lodge a complaint with the Italian Data Protection Authority.
16.2 Requests may be addressed to Gearline Consulting by sending an e-mail to info@gearlineconsulting.com.
16.3 Where processing is based on consent, the User has the right to withdraw it at any time, without affecting the lawfulness of processing carried out before withdrawal.
17. Complaint to the Supervisory Authority
17.1 If the User considers that the processing of personal data is carried out in breach of the legislation in force, the User has the right to lodge a complaint with the Italian Data Protection Authority, in accordance with the procedures indicated by the Authority.
XII – CHANGES TO THIS PRIVACY POLICY
18. Changes to the document
18.1 This Privacy Policy, published on the website www.gearlineconsulting.com, may be updated or amended at any time following regulatory, technical or organisational changes, or the evolution of the services offered.
18.2 Users are invited to consult this page periodically to check for any updates.
18.3 This Privacy Policy was last updated in July 2026.
