PRIVACY POLICY

This privacy policy describes how personal data of Users who access the site www.primabase.it (the “Site”) are processed, whether they are visitors or Users who, upon registration, use the relative services, including the registration of their account, the purchase of products on the Site and further services that Calzaturificio Gal.men S.r.l. makes available through the Site (“Users”). Please, therefore, read it very carefully. This privacy policy applies exclusively to the processing of personal data carried out through the Site. Any possible third party websites which can be consulted by the User through links remain subject to the privacy policy provided by the operator of the relative third party website. Users are therefore invited to read these documents before browsing third party sites.

DATA CONTROLLER
Calzaturificio Gal.men S.r.l. with registered office at 4/6, Via Fonte Giuliano, Montegranaro (FM) 63812, Italy, VAT n. IT01039880446, tel.: +39 0734.892013, email: info@primabase.it. is the holder of the processing of the personal data of Users who visit and navigate the Site (navigation and profiling data), as well as of Users who register and use the services available on the Site (personal data, additional data for the purposes of marketing and profiling, if authorized by the User).

TYPE OF DATA
Navigation data
In order to consult the public pages of the Site no concession of personal data by the User is required. However, any contact with Calzaturificio Gal.men S.r.l. will result in the acquisition of the e-mail address or of the traditional one and / or telephone number necessary to respond to requests and of any other personal data included in the relative communications. These data will be used only to respond to the User’s request and may be disclosed to third parties only where this is necessary for that purpose. These data are kept for the time strictly necessary to provide the User with the requested service and will not be disclosed at all.
In addition, the computer systems and programs used for the functioning of the Site collect some personal data whose transmission is implicit in the use of Internet communication protocols (such as IP addresses or domain names of computers used by users who connect to the Site and the Uniform Resource Identifier addresses of the requested resources). Even if this information is not collected to be associated with identified subjects, by their nature they could, through processing and association with data held by third parties, allow the identification of Users.
These data are only used to obtain statistical information not associated with any identification data of the User about the use of the Site and to check its proper functioning. They will be deleted immediately after processing.
Data provided during registration and use of the services
In the event of registration to the Site through the creation of a personal Account or through the use of other services available on the Site, the processing of personal data will be concerned with operations (for example, collection, registration, consultation, use, organization, processing, storage, selection, communication, modification) that mainly concern data provided by the User during registration and / or when using the services. These data are as follows: 1) User identification and contact data: these data are acquired during registration of the User’s account. Some data are essential for account registration (e.g. name, surname, home address, nationality, telephone contacts, email, username and password). Other data are optional and functional only to the management of the account (e.g. date of birth, gender); 2) Data relating to online purchases: these data are provided by the User and are essential in order to conclude the contract and execute orders (e.g. personal data, nationality, address of residence, billing, delivery, payment data, information on any interactions with Calzaturificio Gal.men S.r.l. for pre- and post-sale services, returns, complaints, guarantees); 3) Data relating to the habits and preferences of the User (e.g. wishlist, history of purchases and type of products purchased);
Data relating to minors
Calzaturificio Gal.men S.r.l. does not accept registrations or orders made by persons under 18 (eighteen) years of age, nor will it intentionally collect or use their personal data. Minors are therefore advised not to register or not to proceed with the purchase through the Site.
Updating of data
The User is required to ensure that the personal data provided to Calzaturificio Gal.men S.r.l. are correct and, in case of changes, to update such data by writing to Calzaturificio Gal.men S.r.l. or using the options allowed within the personal area if the User is registered.

PURPOSES OF PROCESSING
Personal data will be collected and processed for the purposes and in the manner described below: 1) to provide the services requested by the User (e.g. manage the processes of registration and of access to the Site, manage the User’s account, provide assistance to the User and manage their possible complaints, process data for the provision of services requested by the User and manage the wishlist) and to manage online orders (e.g. perform the online operations necessary to manage the order, verify that the information provided for the transaction is complete, valid, correct and not fraudulent, process the order, deliver the products, provide pre- and post-sales support services, handle returns or repairs, manage legal guarantees, contact the User for any problem related to the management of the order or subsequent requests related to the order).
For these purposes, Calzaturificio Gal.men S.r.l. may process personal data without the User’s consent pursuant to art. 6 letter b) of EU Regulation n. 679 of 2016;
2) to comply with legal and/or regulatory obligations (e.g. invoicing, accounting, reporting obligations of security incidents).
For these purposes, Calzaturificio Gal.men S.r.l. may process personal data without the User’s consent pursuant to art. 6 letter c) of Regulation (EU) 2016/679;
3) to protect our rights, both in court and out of court.
For these purposes, Calzaturificio Gal.men S.r.l. may process personal data without the User’s consent pursuant to art. 6 letter f) of Regulation (EU) 2016/679;
4) to elaborate internal statistical analyses in order to improve the quality of the services offered, after data anonymization.
For these purposes, Calzaturificio Gal.men S.r.l. may freely use this information as anonymous and aggregated;
5) for marketing purposes by sending, by email or traditional mail, newsletters and commercial communications relating to products or services provided by Calzaturificio Gal.men S.r.l., as well as to carry out by email statistical analysis, surveys and market surveys, including online, relating to products and services offered by Calzaturificio Gal.men S.r.l.
For these purposes, Calzaturificio Gal.men S.r.l. may process personal data only with the User’s consent.
If the User has also consented to the profiling activity described below, Calzaturificio Gal.men S.r.l. may use the result of the analysis to send communications deemed by Calzaturificio Gal.men S.r.l. to be of interest to the User and to inform them about products and/or services of Calzaturificio Gal.men S.r.l. that may be of interest to them;
6) for profiling purposes, i.e. for the analysis by Calzaturificio Gal.men S.r.l. of the choices, preferences, interests and purchasing habits of the User obtained during the use of the services. Data may be used by the shoe factory Gal.men L.t.d. also through the creation of individual and/or aggregate profiles to elaborate market analysis and statistics aimed at identifying products and/or services of interest to its customers.
For these purposes, Calzaturificio Gal.men S.r.l. may process personal data only with the User’s consent.

NATURE OF DATA PROVISION
With regard to the purposes referred to in points 1 to 4 above, the provision of separate data as required during registration or in other circumstances in which the User is required to provide their data, is necessary to use the services. Any refusal to provide such data will make it impossible to use the services. For these purposes of treatment is not necessary to obtain the consent of the User.
The provision of any possible additional data other than those required is completely optional and free. Their refusal does not affect the possibility for the User to use the services. In this case, however, the User may not be able to fully enjoy some features of the Site that technically require the provision of certain information.
The provision of data that may be functional to the pursuit of the purposes referred to in paragraphs 6 and 7 is not required and their refusal does not affect the ability of the User to use the services. In this case, however, Calzaturificio Gal.men S.r.l. may not be able, for example, to send the User targeted promotional material on products that may be of interest to the User. It is understood that the processing of data for these purposes can only take place with the express and specific consent of the User.

COMMUNICATION AND DISSEMINATION OF DATA
For the correct performance of the activities connected with the purchase through the Site, the personal data indicated above may be accessed by employees and consultants appointed by the data controller who need to process data for the performance of their duties (e.g. administration and customer service).
Personal data may also be made available to third party companies that perform specific services on behalf of the owner as data Processors (such as providers of logistics and shipping services and IT services) or be disclosed to third parties (the list is available at the request of the User) who process data independently and in accordance with the law only to execute the purchase contract (such as the intermediary in payments or the credit institution for the execution of remote electronic payment services by credit card / debit card).
With regard to further processing activities, Calzaturificio Gal.men S.r.l. may make the data available to its employees and consultants appointed by the data controller. Such data may also be available to third party companies that carry out on behalf of Calzaturificio Gal.men S.r.l. specific services as data processors (e.g. providers of logistics and IT services, management of marketing activities and market analysis).
In accordance with Italian law and upon formal request by such parties, the data may be disclosed to the police or judicial authorities.
Personal data will not be disclosed or transferred to third parties for use for their own purposes.
It is understood that in the event of any extraordinary corporate operations (e.g. transfer or lease of business, merger, etc.) the data may be transferred or conferred to third party purchasers or tenants or entitled parties.

DATA TRANSFER ABROAD
Personal data will not normally be transferred abroad. Where, for the purposes of better and more efficient management of the Site, the data is transferred abroad, Calzaturificio Gal.men S.r.l. undertakes to guarantee adequate levels of protection and safeguarding, including of a contractual nature, in accordance with the rules applicable in Italy.

SAFETY MEASURES
Calzaturificio Gal.men S.r.l. recognizes the importance of protecting the personal data of its Customers and Users of the Site (for example, identification and financial data including credit card numbers). For this reason, Calzaturificio Gal.men S.r.l. adopts security policies and measures of a technical and organizational nature to protect, in compliance with the regulations in force in Italy, the personal data of the Users and the computer systems used to manage the Site. In particular, Calzaturificio Gal.men S.r.l. has implemented security measures to protect personal data against tampering, loss, destruction, disclosure or unauthorized access to data collected on the Site.
However, by the very nature of the Internet, such measures cannot limit or totally exclude the risk of unauthorized access or dissemination of data.
Therefore, it is recommended that you periodically update the software for the protection of network data transmission (e.g. anti-virus) and check that your electronic communications service provider has taken appropriate measures for the security of network data transmission (e.g. firewalls and spam filters). The User is also reminded that access to the personal account containing his personal data is only possible through the use of a username and password. In order to protect such data in the best possible way, it is therefore advisable not to communicate or make available such information to third parties.
With regard to payments made for purchases through the Site, Calzaturificio Gal.men S.r.l. informs that the Site uses systems designed to ensure maximum security through the use of the most advanced technology and encryption systems (SSL).

DATA RETENTION
Personal data will be kept for the time necessary to achieve the purposes described above. In particular, the data will be kept for the entire duration of the relationship and for the time required to comply with legal obligations in Italy (for example, in the case of purchases on the Site the keeping of accounts for 10 years, storage for billing purposes) or until revocation of consent or request for cancellation as far as data for marketing purposes is concerned (unsubscribe newsletters).
In case of consent to profiling the data will be kept for the maximum time identified by the Guarantor for the protection of personal data for profiling and personalized marketing and, in any case, no later than fifteen years from their collection.
Apart from these cases, personal data will be kept only to comply with the legal obligations in Italy and regulations imposed on Calzaturificio Gal.men S.r.l. or for purposes of proof relating to the exercise of the right of defense.

THE RIGHTS OF THE INTERESTED PARTY
In accordance with the provisions of Articles 15 to 22 of EU Regulation n. 679 of 2016, Users have the right at any time to obtain from Calzaturificio Gal.men S.r.l. to 1) to receive confirmation of the existence of their personal data and access their content and obtain a copy (right of access); 2) to update, modify and/or correct personal data (right of rectification); 3) to request the cancellation or the limitation of the processing in the cases provided for in the Regulation (right to cancellation and right to limitation); 4) to revoke consent, where given, at any time and without prejudice to the lawfulness of processing based on consent given before revocation (right of revocation of consent); 5) within the limits of what is provided for in EU Regulation n.  679 of 2016, to receive a copy of the data provided in a structured format, commonly used and readable by an automatic device and to request that such data be transmitted to another data controller if technically possible (right to data portability); 6) to object at any time to the processing of data for direct marketing purposes including profiling insofar as it is related to such direct marketing and in cases where the processing is based on legitimate interest (right of opposition).
The User also has the right to contact the Italian Data Protection Authority to protect his/her rights (www.garanteprivacy.it).
In order to exercise these rights, the User may send his request via email to info@primabase.it or contact Calzaturificio Gal.men S.r.l. at its registered office at 4/6, Via Fonte Giuliano, Montegranaro (FM) 63812, Italy.
If the User has consented to the use of his/her data by Calzaturificio Gal.men S.r.l. to receive advertising and promotional and informative material and wishes that his/her data be no longer used to receive advertising (or are used to receive advertising only through certain channels), it will be sufficient that he/she communicates this to Calzaturificio Gal.men S.r.l. by email to info@primabase.it or by ordinary mail to 63812 Montegranaro (FM), Via Fonte Giugliano, 4/6, Italy. The User may also follow the same procedure in the event that he intends to revoke his consent, if given, to the use of his data for profiling purposes.
Requests relating to the exercise of these rights will be processed without undue delay and, in any case, within 30 days of receipt of the request.

VARIATIONS
Calzaturificio Gal.men S.r.l. may modify or update this privacy policy, also to comply with new obligations imposed by the laws in force in Italy or for technical reasons. Changes and updates will be notified to the Users and will apply from the moment of their publication on the Site (in case of changes for which the applicable legislation requires the collection of consent, it will be allowed to the Users to express their choice freely). Users are therefore invited to periodically consult this page to check the updated version of the privacy policy of the Site.