Privacy Policy

Privacy notice on the processing of personal data pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 – www.johngrayeurope.com

Last updated: 10 June 2026

This notice describes how personal data are processed in relation to users who visit the website www.johngrayeurope.com (hereinafter the “Site”), fill in the forms available on it, purchase the products or events offered, or subscribe to informational and promotional communications. It is provided pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (hereinafter the “GDPR”) and the applicable national legislation.

1. Data controller

The controller of the processing of personal data is:

Hi-Performance S.r.l.

Registered office: Via Ruggero Fiore 39 – 00136 Rome (RM), Italy VAT number and Tax Code: 05600831001 Registration: Rome Companies Register – REA RM-905414 Email: info@omsaracom.com
The Site and the related services are also offered under the “OMSARACOM” brand, which belongs to Hi-Performance S.r.l.

2. Types of data processed

In connection with the use of the Site and the services, the Controller may process the following categories of personal data:
  • Identification and contact data: for example first name, last name, email address, telephone number and other data provided voluntarily through the forms or during the purchase process.
  • Purchase and billing data: for example data required to issue tax documents, order details and purchase history.
  • Payment data: handled directly by the payment service providers; the Controller does not store full card details.
  • Browsing data: data that the IT systems acquire automatically while the Site is being used (for example IP addresses, browser type, pages visited), as well as data collected through cookies and similar technologies.
  • Communication data: the content of requests sent to the Controller and the related replies.

3. Purposes and legal bases of the processing

Personal data are processed for the following purposes and on the corresponding legal bases:
  • Provision of services and management of purchases (registration, access to events and products, related support): performance of a contract or of pre-contractual measures – Art. 6(1)(b) GDPR.
  • Compliance with legal obligations (tax, accounting and administrative): Art. 6(1)(c) GDPR.
  • Responding to requests for information or support sent through the forms or by email: performance of pre-contractual measures or legitimate interest of the Controller in handling such requests – Art. 6(1)(b) and (f) GDPR.
  • Sending promotional communications and newsletters (direct marketing, including by email): the data subject’s consent – Art. 6(1)(a) GDPR. For customers, communications relating to products or services similar to those already purchased may be based on the Controller’s legitimate interest, and the data subject may object at any time.
  • Cookies and tracking technologies (analytics and profiling): the data subject’s consent, as described in the Cookie Policy – Art. 6(1)(a) GDPR.
  • Establishment, exercise or defence of legal claims and Site security: legitimate interest of the Controller – Art. 6(1)(f) GDPR.

4. Nature of data provision

Providing data for the purposes of performing the contract and complying with legal obligations is necessary: any refusal makes the purchase or the provision of the service impossible. Providing data for marketing purposes is, on the other hand, optional: refusing consent does not affect the possibility of purchasing and using the services.

5. Processing methods and security

Data are processed mainly by electronic means and, where necessary, in paper format, in accordance with the principles of lawfulness, fairness, transparency, data minimisation and storage limitation. The Controller adopts appropriate technical and organisational measures to ensure data security and to prevent unauthorised access, loss or unlawful use.

6. Recipients and data processors

Data may be disclosed to parties operating on behalf of the Controller, appointed as data processors pursuant to Art. 28 GDPR, or to independent data controllers, exclusively for the purposes indicated above. Depending on the services actually used, the categories of recipients may include:
  • providers of hosting, technology infrastructure and Site management services;
  • platforms for sending emails and managing communications and contacts (e.g. ActiveCampaign);
  • payment service providers (e.g. PayPal, Stripe);
  • technology platforms used to deliver online products and events;
  • providers of analytics and advertising services (e.g. Google, Meta Platforms);
  • professionals and consultants (e.g. in the accounting, tax and legal fields);
  • public authorities and bodies, where required by law.
The data are not disseminated to the public.

7. Transfer of data to third countries

Some providers (in particular those relating to advertising, analytics, email marketing and payments) may also process data outside the European Economic Area. In such cases, the transfer takes place in compliance with the safeguards provided for by Articles 44 et seq. of the GDPR, such as adequacy decisions of the European Commission or standard contractual clauses.

8. Data retention period

Data are retained only for as long as strictly necessary for the purposes for which they were collected and, in particular:
  • data relating to purchases and to tax and accounting obligations are retained for the period required by law (normally 10 years);
  • data processed for marketing purposes are retained until the data subject withdraws consent or objects and, in any event, in compliance with the time limits set by the applicable legislation and by the decisions of the Italian Data Protection Authority (Garante);
  • data relating to contact and support requests are retained for the time needed to handle the request and for the applicable limitation periods thereafter;
  • data collected through cookies are retained for the periods indicated in the Cookie Policy.

9. Cookies and tracking technologies

The Site uses cookies and similar technologies. For detailed information on the types of cookies used and on how to manage consent, please refer to the Cookie Policy, which forms an integral part of this notice.

10. Rights of the data subject

At any time, the data subject may exercise, within the limits and under the conditions laid down by Articles 15-22 of the GDPR, the following rights:
  • right of access to their personal data;
  • right to rectification of inaccurate or incomplete data;
  • right to erasure of data (“right to be forgotten”);
  • right to restriction of processing;
  • right to data portability;
  • right to object to processing, including processing for marketing purposes;
  • right to withdraw consent at any time, without affecting the lawfulness of the processing carried out before the withdrawal.

11. How to exercise your rights and lodge a complaint

To exercise the rights listed above, or for any request concerning the processing of their personal data, the data subject may write to the email address info@omsaracom.com. The Controller will reply within the time limits set by the applicable legislation. The data subject also has the right to lodge a complaint with the competent supervisory authority (in Italy, the Garante per la protezione dei dati personali, the Italian Data Protection Authority – www.garanteprivacy.it) if they believe that the processing of their data infringes the applicable legislation.

12. Processing of minors’ data

The services offered through the Site are intended for an adult audience. The Controller does not knowingly collect personal data relating to minors. Should it emerge that data relating to minors have been processed without adequate consent, such data will be deleted as quickly as possible.

13. Changes to this privacy notice

The Controller reserves the right to amend or update this notice, including as a result of changes in the applicable legislation or in the services offered. Any changes will be published on this page, together with the date of the last update. Users are therefore encouraged to review this page periodically.

14. Contact

For any information regarding this notice or the processing of personal data, you can contact the Controller at the email address info@omsaracom.com.

Hi-Performance S.r.l. • VAT No. 05600831001 • © 2026 Hi-Performance S.r.l. – All rights reserved