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PRIVACY POLICY

This information is provided in compliance with art. 13 of Regulation 2016/679 (GDPR), pursuant to art. 13 of d.lgs. 2003/196 (Code regarding the protection of personal data) and the RSM 2018/171 law regarding the protection of personal data and relates to all personal data processed in the manner indicated below.

THE HOLDER OF THE TREATMENT
The Data Controller of personal data collected is Guidi Calzature - Via XXV Marzo, 50 - 47895 - Domagnano – Repubblica di San Marino, tel. 0549903962, mail: info@guidicalzature.com 
The personal data provided may be communicated to appropriately appointed recipients who will process the data as data processors and / or as appointees, in order to comply with the contracts or related purposes. 
The complete list of data processors and people in charge of processing personal data can be requested by sending an email to info@guidicalzature.com, the reply will be processed within 30 days of the request.

DATA TRANSFER
Personal data is transferred outside the European Union, in the state of San Marino, as the Data Controller is Guidi Calzature, an economic operator of San Marino, for technical and operational purposes and to guarantee a high level of service continuity , the Holder ensures that the transfer is subject to adequate guarantees (standard terms) as envisaged by art. 46 of the GDPR, in order to ensure that the level of protection of natural persons guaranteed by current legislation and in particular by EU Regulation 2016/679 is not prejudiced. Our servers are located in countries of the European Community, and in particular in Germany.

COLLECTED DATA
The personal data are collected as provided directly by the interested party or collected automatically. 
The data collected can be: Name, Surname, address of residence or domicile, telephone number, email , account password, clicked links for users who open the newsletters, IP address, geolocation , browser version and operating system for statistical purposes. These data are collected only for statistical purposes. 
The data provided directly by the interested party are all the personal data that are provided to the Data Controller in any way. 
The data collected automatically also inlcudes the navigation data. Such data, although not collected in order to be associated with the identity of the user, could indirectly, through processing and associations with data collected by the Data Controller, allow its identification. 
Following the sending of newsletters, the platform used makes it possible to detect the opening of a message and the clicks made within the newsletter itself, together with details relating to the IP and the browser / device used. The collection of these data is fundamental for the functioning of the implicit renewal systems of the treatment (see the heading Processing Methods) and an integral part of the operations of the sending platform.

PURPOSE OF THE TREATMENT
The transfer of personal data has the legal basis on the processing of contractual or pre-contractual requirements or the fulfillment of legal obligations to which the Data Controller is subject. For this reason, any refusal or failure to supply the data could result in the impossibility of a correct supply of the service or the impossibility for the Data Controller to respond the requests for information sent by the interested party. 
The provision of data for the purpose of sending newsletters for promotional, informative or research purposes is optional and the refusal to give the relative consent to the Treatment will result in the impossibility of being updated about commercial initiatives and / or promotional campaigns, to receive offers or other promotional material.

REVOCATION OF CONSENT
The interested party can revoke his / her consent to the receipt of promotional and commercial communications immediately, by sending a request to the email address info@guidicalzature.com or by clicking on the appropriate unsubscribe link which can be found in the footer of each promotional and commercial email received.

RECIPIENTS
The personal data provided may be communicated to appropriately appointed recipients who will process the data as data processors and / or as appointees. 
The Data Controller does not disclose any information of the interested parties to third parties without their consent, except where required by law. In any case, the dissemination of the personal data processed is excluded. The complete list of data processors, co-owners and persons in charge of processing personal data can be requested by sending a request to the email address info@guidicalzature.com

METHOD OF TREATMENT
Personal data are processed with automated tools for the time strictly necessary to achieve the purposes for which they were collected, in any case providing for the annual verification of the data stored in order to cancel those deemed obsolete, unless the law does not provide for archiving obligations . 
The processing of data is usually carried out at the Data Controller's headquarters, by personnel or external collaborators duly designated as data processors. The complete list of data processors and persons in charge of processing personal data can be requested by sending a request to the email address info@guidicalzature.com. 
Specific security measures are observed to prevent the loss of data, illicit or incorrect use and unauthorized access. 
The registration and the relative treatment are considered valid until the unsubscription by the user, present in every email , or after 12 months from the last communication of which he has evidence of direct interaction (click, open, reply).

RIGHTS OF THE PERSON CONCERNED
Pursuant to the articles 15 - 21 of the EU Regulation 2016/679 each person is granted a series of rights.
Right of Access: the interested party, pursuant to art. 15, has the right to obtain confirmation that a processing of personal data concerning him is being carried out and, if necessary, to obtain a copy. He also has the right to obtain access to personal data concerning him and to additional information such as the purpose of the processing, the categories of recipients, the data retention period and exercisable rights. 
Right of rectification: the interested party, pursuant to art. 16, has the right to obtain the rectification of inaccurate personal data concerning them or their integration. 
Right to cancellation: the interested party has the right to obtain the cancellation of personal data concerning him, without unjustified delay, if one of the reasons provided for by art. 17. 
Right to limitation of treatment: the interested party has the right, in the cases provided for by Article 18 of Regulation 2016/679, to obtain the limitation of the processing. 
Right to data portability: the data subject has the right to receive in a structured format, commonly used and readable by an automatic device, personal data concerning him and has the right to transmit such data to another owner without impediment, according to what required by art. 20 of Regulation 2016/679; 
Right to object to processing: the data subject has the right to object to the processing of personal data concerning him / her as provided for by art. 21 of Regulation 2016/679. 
The interested party also has the right to lodge a complaint with the competent Control Authority, the Privacy Guarantor. 
The requests referred to in the previous points must be addressed in writing to the Data Controller. The Data Controller will, within the time limits established by current legislation, provide a timely response to requests to exercise the rights of the data subjects. 
Any clarification or request for clarification can be sent in writing to the Data Controller.

UPDATES AND CHANGES
The Data Controller reserves the right to modify, supplement or update this notice periodically in compliance with the applicable legislation or the provisions adopted by the Guarantor for the Protection of Personal Data. 
The aforementioned modifications or additions will be brought to the attention of the interested parties. We invite users to view the Privacy Policy regularly, to check the updated Information and decide whether or not to continue to use the services offered.
Last modification: August 2020.
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