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ITALIAN HANDMADE SHOES & ACCESSORIES

Policy on personal data processing based on REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 (GDPR)

Introduction

The following Terms and Conditions of Sale regulate the sale on this website “https://www.giorgio1958.com” (Website). The seller is Heros s.r.l, with registered office in Via Spineto 3 63837 Piane di Falerone FM 63837 IT, Chamber of Commerce of Fm n. 105434, VAT number 00990820441, share capital of 99.000,00 € fully paid (Company)

Purchasing through the Website

The Company shall acquire and process your personal data to process your request to purchase through the Website.

Registration

The Company shall process the personal data provided by you to enable you to register with the Website and make use of the services restricted to registered users.

Marketing

If you provide your explicit consent, the Company shall process your personal data to send you promotional communications and/or newsletter regarding products offered for sale by the Company or by third parties.

Profiling

If you provide your explicit consent, the Company shall process your personal data for the analysis of your consumer choices and purchasing habits (known as “profiling”), through a study of the type and frequency of your online purchases, in order to send newsletter and/or advertising material of the Company or third-parties that may be of particular interest to you.

Soft Spamming

The Company is entitled to sale its products using the email that you communicated during your first purchase on the Website, if this product is similar of the first sale (soft spamming). You may at any time notify the Company of your refusal to receive this type of communication.

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Pursuant to the GDPR, the Seller shall process the personal data provided by you as indicated in this privacy policy. Article 1. Purpose of the processing. Legal basis. Mandatory or optional nature of data provision and consequences of any refusal. The Company shall process the personal data provided by you for the following purposes: a. to enable you to register with the Website and make use of the services restricted to registered users and for administrative/accounting purposes. The legal basis for the processing is Company’s commitment to be compliance with a legal obligation or to take steps at the request of the data subject prior to entering into a contract, as the case may be; b. in the case of the execution of an online purchase order, to allow the conclusion of the purchase contract and the proper execution of transactions related to the same (and, where necessary, to fulfill tax obligations). The legal basis for the processing is Company’s commitment to be compliance with a legal obligation or to perform a contract to which the data subject is party; c. limited to the email address provided by you when purchasing products offered on the Website, to enable the direct sale of similar products (soft spamming), without requiring your express and prior consent and provided that you do not exercise your right to object. The legal basis for the processing is the Company’s legitimate interest to perform these activities. This legitimate interest is equal to the user’s interest to riceve “soft-spam” comunication; d. if you provide your explicit consent, for the Company to send you newsletter and for market research purposes also aimed at evaluating the level of customer satisfaction and to send you promotional communications in relation to the products of the Company and / or third-parties, by email (marketing purposes); if you provide your explicit consent, for the analysis of your consumer choices and purchasing habits (known as “profiling”), by the Company, through a study of the type and frequency of your online purchases, in order to send informative and/or advertising material about products of the Company and / or third-parties, that may be of particular interest to the user, by email (profiling purposes). The legal basis for the processing is your consent; e. to respond to your requests through the customer care service. The provision of data is purely optional. However, as the said processing is necessary in order to respond to your request, your refusal to provide the relevant data will prevent you from obtaining answer from the customer care of the Company. The legal basis for the processing is the Company’s legitimate interest to perform these activities. This legitimate interest is equal to the user’s interest to use the customer care service of the Website; f. in order to answer to your requests by email, by telephone. The provision of data is purely optional. However, as the said processing is necessary in order to respond to your request, your refusal to provide the relevant data will prevent you from obtaining answer from the customer care of the Company. The legal basis for the processing is the Company’s legitimate interest to perform these activities. This legitimate interest is equal to the user’s interest to receive answer by the Company. The provision of data for the purposes set out in at Point a) and b) is purely optional. However, as the said processing is necessary in order to provide the online purchasing your refusal to provide the relevant data will prevent you from completing an online purchase. Consent to marketing and profiling purposes is purely optional. Failure to consent will have the following consequences. Failure to consent to the processing of personal data for marketing purposes will prevent you to receive promotional communication and newsletter regarding products of the Company and/or third-parties and will prevent the Company to carry out market research purposes aimed at evaluating the level of customer satisfaction. Failure to consent to the processing of personal data for profiling purposes will prevent the Company from studying the type and frequency of your online purchases, in order to send to you newsletter and/or advertising material that may be of particular interest to you regarding products of the Company and/or third-parties. It is understood that the Company may use your personal data to comply with legal obligations and to perform the purchase contract. You may revoke your consent using the relevant link indicated in any promotional email sent by the Company.

“Ship to other address” Service

You may give one or more of products to one of your friends as a present. For this purpose you shall provide the personal data of your friends. The Company will store the personal data only to prove the performing of your request. In order to enjoy this service you shall prove the relevant consent of your friends, if requested by the Company.

Social Network

You may register and/or access to the Website using Facebook e Google Plus. You give consent to the relevant social network to share with the Company your personal data necessary to register and/or access to the Website.

Payment Card Data

In order to make a payment through one of the payment cards offered on the Website, you shall enter the data of the payment card directly on a page that will communicate through secure encryption protocol with the payment service provider (which will act as an independent data controller). These data will not pass through the server of the Company which, therefore, will not process such data in any way. In execution of the legal obligations provided for by Directive 2015/2366/ (EU) on payment services in the internal market (PSD2), You are informed that, with reference to purchases made on the Web Site by credit card, data necessary for the conclusion of the purchase process may include the phone number communicated by You, or a different personal data necessary to complete the purchase process. In order to allow you to complete the purchase, the payment institution in charge of managing the transaction will send you an authentication code, which must be reported by You during the purchase process to meet the authentication criteria provided by PSD2 (Strong Customer Authentication). The processing of your personal data for these purposes has as its legal basis the fulfillment of legal obligations and does not require your consent.   To provide the above-indicated data is necessary to make purchases on the Website.

PayPal

You may make purchases using PayPal. In this event, you will be directed to a page outside the Website, where you must indicate the personal data requested by PayPal to complete the purchase process (PayPal will act as a data controller). These data will not pass through the server of the Company which, therefore, will not process such data in any way. To provide the above-indicated data is necessary to make purchases on the Website.

Special Categories of Personal Data. Judicial Data.

The Company does not process special categories of personal data nor judicial data.

Geolocation

You may receive a notification on your device (fixed and/or mobile) which will allow the identification of the device itself (Geolocation). You may allow or refuse such setting. Your choice will not affect the functionality of the Site. The data relating to the position of the device will not be collected and or stored by the Company. The legal basis for the processing is the legitimate interest of the Company in providing services appropriate to the position of the user. This legitimate interest is equal to the user’s interest in receiving services as relevant as possible to his or her position. Article 2. Methods of Processing Personal Data The processing of your personal data will be carried out by electronic or automated means, in the manner and with the appropriate tools to ensure the security and confidentiality in accordance with the GDPR. The information and methods of processing will be relevant and not excessive in relation to the type of services provided. Data will be managed and protected in environments where access is under constant control. Article 3. Data Disclosure For the purposes described in this privacy policy, the personal data provided by you may be disclosed or communicated to the following parties:

Your data may be disclosed only in anonymous and aggregated form for statistical or research purposes. Article 4. Data Controller You can contact the Company, as Data Controller, at the following addresses: HEROSCALZATURE s.r.l Via Spineto 3 63837 Piane di Falerone FM 63837 IT By fax, writing to: +39.0734.759615 By telephone, calling: +39.0734.750422 By email, writing to: info@heroscalzature.it By selecting the contact form on the Website. You may address requests relating to the processing of your personal data to both the Data Controller and the Data Protection Officer. Article 5. Data Storage   Your personal data will be stored only for the period of time required to ensure the correct provision of the services offered, in any case not beyond the legal limits. If you close your account, your personal data will be stored for administrative purposes for a period not exceeding 90 days, without prejudice to any legal obligations regarding the storage of accounting documents or for public security purposes. In any case, it is understood that personal data will be stored and processed for marketing and profiling purposes for the period of time allowed by law and the provisions of the Italian Data Protection Authority. At the end of this period, the Company may ask you to renew your consent to the processing of your data or to make them anonymous and keep them only for statistical or historical purposes.   Article 6. Rights of the Data Subject Purstuant to GDPR (Article 13), you have the right to:

The above-mentioned rights may be exercised by making a request to at the contacts indicated above.   Article 7. Amedments The Company reserves the right to change this privacy policy at any time, giving suitable notice to users and ensuring in any case an adequate and similar protection of personal data. In order to view any changes, you are invited to regularly consult this privacy notice. Newsletter The site uses the Sendiblue Newsletter service to send commercial offers, coupons and discount vouchers. The acquired emails will not be disclosed to third parties.