01 / Who we are

Data controller and contact details

For the purposes of applicable data-protection laws, the controller of personal information processed through this website is:

• [LEGAL ENTITY NAME], trading as GICinno.
• Registered or business address: [REGISTERED ADDRESS].
• Website: [WEBSITE URL].
• General contact email: [GENERAL EMAIL].
• Privacy contact email: [PRIVACY EMAIL].
• Telephone, if applicable: [PHONE NUMBER].

If GICinno appoints a Data Protection Officer or a privacy lead where required or appropriate, their contact details will be published here or provided through the privacy contact email above.

02 / Scope of this policy

When this policy applies

This Privacy Policy applies to personal information processed by GICinno when you:

• Visit or interact with the GICinno website.
• Submit a contact, inquiry, partnership or consultation request.
• Subscribe to the GICinno Journal, newsletter or other communications.
• Apply for a job, internship, talent network or other career opportunity.
• Contact us by email, phone, social media, messaging service or other channel.
• Attend a GICinno event, webinar, briefing or research activity.
• Engage with GICinno as a client, supplier, partner or prospective client.

This policy does not necessarily apply to personal information processed solely on behalf of a client under a separate services agreement. In that situation, the relevant client or agreed contractual documentation may govern the processing relationship.

03 / Personal information we may collect

Information collected directly, automatically or from professional sources

The categories of personal information we collect depend on how you interact with GICinno. We aim to collect only information that is relevant and appropriate to the purpose for which it is needed.

Please do not submit sensitive personal information through general website contact forms unless GICinno specifically asks for it through a secure, documented process. Sensitive information may include health data, financial account information, government identifiers, passwords, biometric data or other special-category information.

04 / How we use personal information

Purposes for processing

GICinno may use personal information for the following purposes, subject to applicable law:

• Responding to your questions, contact requests or consultation inquiries.
• Managing prospective-client, client, supplier, partner and professional relationships.
• Providing, administering and improving GICinno services and communications.
• Sending requested newsletters, event information or marketing communications where permitted.
• Managing events, webinars, briefings, research activities and registrations.
• Recruiting, reviewing job applications and maintaining a talent network where appropriate.
• Operating, maintaining, securing and improving the website, systems and digital services.
• Detecting, preventing and investigating misuse, fraud, security incidents or unlawful activity.
• Meeting legal, regulatory, contractual, accounting or record-keeping obligations.
• Establishing, exercising or defending legal claims where necessary.

GICinno will not use your personal information for a materially different purpose without providing appropriate notice or obtaining consent where required by applicable law.

05 / Legal bases and consent

Why GICinno may process personal information

Where applicable data-protection law requires a legal basis for processing, GICinno may rely on one or more of the following:

• Consent: where you have voluntarily agreed to receive communications or participate in a particular activity.
• Contractual necessity: where processing is necessary to enter into, perform or manage a contract or requested pre-contractual steps.
• Legitimate interests: where processing is reasonably necessary for legitimate business purposes and does not override your rights and interests.
• Legal obligation: where processing is necessary to comply with applicable legal, regulatory, tax, accounting or record-keeping obligations.
• Protection of vital interests or other lawful grounds: where permitted under applicable law in limited circumstances.

Where we rely on consent, you may withdraw it at any time by using the unsubscribe mechanism in an email, contacting us at [PRIVACY EMAIL], or following the instructions provided when consent was collected. Withdrawal of consent does not affect the lawfulness of processing that occurred before withdrawal.

06 / Sharing and international transfers

Who may receive personal information

GICinno may share personal information only where necessary and appropriate with the following categories of recipients:

• Authorized GICinno personnel, contractors and advisors who need the information for legitimate business purposes.
• Service providers supporting website hosting, analytics, email delivery, form handling, cloud infrastructure, CRM, security, recruitment or professional operations.
• Professional advisers, including legal, accounting, insurance or audit advisers, where necessary.
• Business partners or clients where you have requested, authorized or reasonably expect such sharing in connection with a project or opportunity.
• Competent public authorities, regulators, law-enforcement bodies or courts where disclosure is required or permitted by law.
• A successor organization if GICinno is involved in a merger, acquisition, restructuring, financing or transfer of assets, subject to appropriate safeguards.

GICinno does not sell personal information for money. If applicable law defines certain data disclosures, advertising technologies or cross-context behavioral practices in a broader way, GICinno will update this policy and provide any required notices or choices.

International transfers

GICinno may process information in countries other than the country where you live or where information was collected. Where cross-border transfers are subject to legal requirements, GICinno will use appropriate safeguards, such as contractual protections, adequacy mechanisms or other legally recognized transfer methods, as applicable.

07 / Retention

How long we keep personal information

GICinno keeps personal information only for as long as reasonably necessary for the purposes described in this policy, including to meet legal, contractual, accounting, tax, security, dispute-resolution and record-keeping requirements.

Retention periods may vary depending on the nature of the relationship and information involved. For example:

• General inquiries may be retained long enough to respond, follow up and maintain an appropriate business record.
• Newsletter information may be retained until you unsubscribe or until the relevant list is retired, subject to required record keeping.
• Career information may be retained for the duration of an application process and, where legally permitted, for a limited talent-network period.
• Client, supplier and contractual records may be retained for the contract period and a further period required for legal, accounting or dispute-related purposes.
• Security, analytics and technical logs may be retained for a period necessary for security, diagnostics, performance and operational management.

When information is no longer required, GICinno will delete, anonymize or securely archive it in accordance with applicable requirements and internal retention practices.

08 / Your privacy rights

Choices and rights available to you

Depending on your location and the law that applies to you, you may have rights in relation to your personal information. These may include:

• The right to request access to personal information we hold about you.
• The right to request correction of inaccurate or incomplete information.
• The right to request deletion of information in certain circumstances.
• The right to request restriction or objection to certain processing.
• The right to request data portability where applicable.
• The right to withdraw consent where consent is the basis for processing.
• The right to opt out of direct marketing communications.
• The right to raise a concern or lodge a complaint with an applicable data-protection authority.

To make a privacy request, contact [PRIVACY EMAIL] with the subject line “Privacy Request.” We may need to verify your identity before responding, and we may retain limited information needed to document or comply with the request.

You may also have the right to complain to the relevant supervisory authority in your jurisdiction. Where required, GICinno will provide applicable authority contact details here: [SUPERVISORY AUTHORITY DETAILS, IF APPLICABLE].

09 / Cookies and similar technologies

How website technologies may be used

GICinno may use cookies, pixels, local storage, server logs and similar technologies to operate the website, remember preferences, understand website performance, protect against misuse and, where enabled and lawful, measure communications or marketing activity.

Cookies may include:

• Strictly necessary cookies: required for website security, navigation or core functionality.
• Preference cookies: used to remember user settings, such as visual-mode preferences where available.
• Analytics cookies: used to understand website use, performance and content effectiveness.
• Marketing cookies: used only where enabled and subject to required consent or notice mechanisms.

You can manage cookies through browser settings and, where deployed, our cookie-consent tool. For more information, see our Cookie Policy.

10 / Security

How we work to protect personal information

GICinno uses reasonable technical, organizational and administrative measures intended to protect personal information against unauthorized access, loss, misuse, alteration, disclosure or destruction. Measures may include access controls, authentication, encryption where appropriate, system monitoring, secure service-provider selection, backups, security review and staff or contractor confidentiality obligations.

However, no website, internet transmission, cloud service or information system can be guaranteed completely secure. You should avoid sending sensitive information through unencrypted email or general web forms unless GICinno has specifically provided a secure method for that purpose.

Data incidents

If GICinno becomes aware of a personal-data incident, we will investigate and respond in accordance with applicable law, contractual obligations and our internal incident-management procedures. Where notification is required, we will take appropriate steps to notify affected individuals or authorities.

11 / Automated decision-making

How automated systems may be used

GICinno does not currently intend to make solely automated decisions that produce legal or similarly significant effects on individuals through this website. If this changes, GICinno will provide appropriate notice, information about the logic involved where required, and any rights or safeguards available under applicable law.

GICinno may use analytics, security tooling, AI-assisted internal workflows or other automated support systems to operate and improve its business. Such use will be designed to support appropriate human review and accountability where the context requires it.

12 / Children and sensitive information

Information not intended for general website collection

The GICinno website and general services are not directed to children in circumstances where parental consent would be required for personal-data processing. We do not knowingly collect personal information from children through general website forms without appropriate authorization.

Please do not provide sensitive personal information through general forms, including health information, government identifiers, payment-card details, passwords, biometric information or other highly sensitive data, unless GICinno has provided a specific secure and documented collection process.

13 / Third-party websites and services

External links are governed by their own policies

The GICinno website may include links to third-party websites, platforms, social-media pages, embedded tools or services. GICinno is not responsible for the privacy practices, security or content of those third parties.

We encourage you to review the privacy notices of any third-party service before providing personal information to it. This includes professional networks, video platforms, messaging tools, payment providers, event platforms, recruitment services and cloud applications.

14 / Changes to this policy

How we update this policy

GICinno may update this Privacy Policy from time to time to reflect changes in our practices, website features, services, technologies, legal requirements or organizational structure.

When we make material changes, we will update the “Last Updated” date and, where required, provide additional notice or obtain consent before applying a materially different processing activity. We encourage you to review this page periodically.

15 / Contact us about privacy

Questions, requests or concerns

If you have a question about this Privacy Policy, want to exercise a privacy right, need to update your information or have a concern about personal-data processing, contact GICinno using the details below:

• Privacy email: [PRIVACY EMAIL]
• General email: [GENERAL EMAIL]
• Postal address: [REGISTERED ADDRESS]
• Website: [WEBSITE URL]

Please include enough detail in your request for us to understand the nature of your concern and respond appropriately. Do not include sensitive information in an unencrypted email unless we ask you to use a secure method.