The following General Privacy Notice to Suppliers refers only to the processing of personal data managed by Gulliver Srl, as Data Controller, for the purpose of executing contracts with Suppliers, as well as for commercial and marketing development purposes.

With reference to any processing of personal data conducted by Suppliers on behalf of Gulliver Srl, as Data Processor, please refer to the provisions of the contracts between the Data Controller and Data Processor signed between the parties.



1. Owner and managers of the treatment

The Data Controller is GULLIVER S.R.L, with registered office in Via Orzinuovi 73, 25125 Brescia, Tax Code and Partita. VAT number 03559600170; Gulliver srl has appointed its own Data Protection Officer (DPO) who can be contacted for any request at the e-mail address 

The updated list of data processors is kept at the registered office of the Data Controller


2.Object of the processing - categories of personal data processed

The Data Controller processes the personal data of your appointees, to be understood as common identification data of commercial contact (such as name, surname, address, telephone, e-mail), communicated by you when defining and / or concluding contracts in as a customer for the services of the owner or, still during the contractual relationship. The Customer receiving this information undertakes to give it to their employees whose data is processed by the Data Controller.

The Data Controller may also process the personal data of your appointees, to be understood as common commercial contact identification data (such as name, surname, address, telephone, e-mail), acquired by third-party owners (ex. trade fair organizations) who have acquired their legitimate consent to the transfer for commercial contact purposes.


3.Purpose and legal basis of the processing

3.1 Contractual and pre-contractual purposes:

Legal basis

3.1.1 the processing is necessary for the execution of a contract of which the interested party is a party or for the execution of pre-contractual measures adopted at the request of the same,

3.1.2 the processing is necessary to fulfill the obligations established by law, by a regulation, by community legislation or by an order of the Authority

3.1.3 the processing is necessary to exercise the Data Controller's legitimate defense interest in court.

3.2 Commercial Development and Marketing Purposes: to send you commercial or marketing communications relating to the Controller's products or services (by e-mail)

legal basis

3.2.1 based on the legitimate interest of the Data Controller (so-called Soft Spam) if you have already purchased our products or used our services and for products / services similar to those you have already used, unless you disagree,

3.2.2 on the basis of your explicit and specific consent given to us or provided to third parties from whom the data was acquired.


4.Processing methods and duration

The processing of your personal data may be carried out by means of the operations indicated in art. 4 n. 2) GDPR and more precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data may be subjected to both paper and electronic processing.

The Data Controller will process personal data for the time necessary to fulfill the aforementioned contractual purposes and in any case for no more than 10 years from the termination of the contractual relationship. For marketing purposes, the Data Controller will process personal data for the time strictly necessary to fulfill the purposes for which they were collected, for the period required by law or under the provisions of the authority. Given your desire to revoke the consent given or express decision to cancel from our commercial mailing list, your data will be promptly deactivated from our marketing databases so that you will not receive further communications. In any case, the personal data contained in previous communications will be kept for a period not exceeding 24 months from their registration, without prejudice to the transformation of said data into anonymous form.


5.Access to data

Your data may be made accessible for the purposes referred to in the previous art. 3:

  • to employees and collaborators of the Data Controller in their capacity as persons in charge of processing and / or system administrators;

  • to third-party companies or other subjects (by way of example, professional firms, consultants, insurance companies, credit institutions, etc.) who carry out activities on behalf of the Data Controller, in their capacity as independent Data Controllers or external Data Processors appointed by the Data Controller.


6.Communication of data

Pursuant to art. 6 lett. b) and c) GDPR, therefore without the need for express consent, the Data Controller may communicate your data for the purposes deriving from the contractual relationship to judicial authorities as well as to those subjects to whom the communication is mandatory by law for the accomplishment of the purposes said. These subjects will process the data in their capacity as independent Data Controllers.

Your data will not be subject to disclosure.


7.Data transfer

Personal data may be transferred, for the purposes referred to in this information as well as for archiving and storage purposes, both to countries of the European Union and to third countries with respect to the European Union.

In any case, the Data Controller ensures from now on that the transfer of data outside the EU will take place in accordance with the applicable legal provisions.


8.Nature of the provision

The provision of data for the contractual purposes of art. 3.1 is mandatory. In their absence, we will not be able to guarantee the execution of the contractual relationship.

The provision of data for the marketing purposes of art. 3.2 is optional; you can therefore decide not to provide any data or to subsequently deny the possibility of processing data already provided and any consent given, in this case, you will not be able to receive the aforementioned commercial communications and advertising material concerning the products or services offered by the Data Controller.  


9.Rights of the interested party

By contacting the Data Controller by e-mail at, any interested party may exercise the rights referred to in art. 15 GDPR and precisely:

  • obtain confirmation whether there is any existence of personal data concerning him, even if not yet registered, and their communication in an intelligible form;
  • obtain the indication: a) of the origin of personal data; b) the purposes and methods of the processing; c) of the logic applied in case of processing carried out with the aid of electronic tools; d) the identification details of the Data Controller, the Managers and the designated representative pursuant to art. 3, paragraph 1, GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the State, managers or agents;
  • obtain: a) updating, rectification or, when interested, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including data which need not be kept for the purposes for which the data were collected or subsequently processed; c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfillment is proves impossible or involves the use of means that are manifestly disproportionate to the protected right;
  • fight, in whole or in part: a) for legitimate reasons to the processing of personal data concerning him, even if pertinent to the purpose of the collection; b) to the processing of personal data concerning him for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by e-mail and / or through traditional marketing methods by telephone and / or paper mail. It should be noted that the right of opposition of the interested party, set out in point b) above, for direct marketing purposes through automated methods extends to traditional ones and that in any case the possibility remains for the interested party to exercise the right of opposition also only partially. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or neither of the two types of communication.
  • Where applicable, the interested party will also have the rights referred to in Articles 16-21 GDPR (right of rectification, right to be forgotten, right to limitation of processing, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority.
  • Finally, where the conditions exist, the interested party will have the right to compensation for any damage suffered as provided for by art. 82 of the GDPR.



Rif. GUL_INFO05 del 16/02/2021