This information is provided by THE MARKET PropCo S.r.l. to the visitors and other parties who may access San Marino Outlet. Personal data will only be used in accordance with:
• EU Regulation no. 2016/679 (hereafter “Regulation”);
• Law no. 171/2018 of the Republic of San Marino (hereafter “Law”);
• by the guidelines of the authorities appointed as Guarantors.
1. Data Controller, DPO and office responsible for processing personal data
The Data Controller is THE MARKET PropCo Srl (hereafter referred to also simply as “THE MARKET”), with registered office at Strada degli Angariari 41 – 47891 Falciano (RSM), C.O.E. 26567, in the person of its legal representative pro tempore, Email: privacy@themarket.sm.
The Data Controller has appointed a DPO, who can be reached by e-mail at dpo@themarket.sm or by writing to the address of the THE MARKET.
The Representative in the European Union for the processing and use of personal data is the company Promos Development Srl, with registered office at Via San Zeno no. 173, 25124 – Brescia, fiscal code and V.A.T. No. 04444270989, in the person of its legal representative pro tempore, Email: rappresentanteUEsanmarinoutlet@gmail.com;
The company responsible for processing personal data, in its role as business and marketing manager in charge of handling relations with the users of the outlet, is Promos S.r.l. — fiscal code and V.A.T. no.: 03123920179— San Zeno, 173— 25124 Brescia (BS), Phone: +39 030 2422862,- e-mail: privacy@promosgroup.it, with Stable Organization in San Marino in Falciano, Strada degli Angariari 41. The Data Processor also has its own DPO who can be reached at the email addressdpo@promosgroup.it , at the telephone number +39 030 242 2862 or by writing to the company offices.
1. Purposes and legal bases
The video surveillance system is installed exclusively in response to the need to protect the company’s property from possible attempts of theft and/or access by unauthorized persons who could commit criminal acts in areas belonging to the San Marino Outlet.
With regard to the organizations use of personal data by means of the video-surveillance system, the consent of the data subject is not required, as it is done on the basis of the legitimate interest of the data controller, pursuant to art. 6, par. 1, letter f) of the Regulation and art. 1, par. 1, letter f) of the Law, to ensure the security and protect the integrity of the company's assets.
2. Data subject to processing
Using its own systems of video surveillance installed at San Marino Outlet, THE MARKET processes personal data. The video cameras film and record images.
3. Methods of processing data and recipients
Regarding the above purposes, the data will be processed by THE MARKET in electronic format. Data will be processed in such a way as to guarantee their logical and physical security and confidentiality, and this may be done using digital and telematic tools to display and save said data.
The logics of processing will be strictly related to the purposes mentioned above.
In particular, the data collected will be filmed and recorded using digital procedures, and processed by personnel authorized or designated to perform the procedures, or system administrators.
The companies performing the activities of vigilance of assistance with the system and who may possibly have access to the recordings in case of criminal events, such as also Promos s.r.l. — as Manager in charge of processing personal data, in its role as the company appointed to manage San Marino Outlet — which can view the images, has appointed specific management personnel to handle this responsibility.
4. Term of conservation
Recorded images are kept for the time strictly necessary to pursue the purposes indicated, and in any case no longer than 72 hours after being recorded, except in case of the need to preserve them for a longer period due to closure of the offices and/or the occurrence of events that THE MARKET decides to send to the legal authorities, in case of a theft, for example, or other criminal action against its property, and/or at the request of the police or other legal authorities.
In case of illicit acts, the images will be downloaded to a special digital support and delivered to the aforementioned authorities.
On expiration of the terms of conservation indicated above, the recorded images will be automatically deleted. Recordings are processed using special software. Data are not indexed and will not be combined with others, and the system will not be interconnected with the law enforcement systems.
Currently the company does not foresee any application of automatic actions involving automated mechanisms or alarm systems. The images will not be duplicated unless charges are filed with the appropriate authorities. With the exceptions specified above, the data will not be communicated to third parties or made public in any way.
5. Transfers of data to other countries
The data processed reside on server located in San Marino. In any, if data should be sent outside the European Union, because the servers of certain suppliers of services are located there, the data controller will adopt adequate guarantees, as required by European Regulation and by the Law, to ensure protection of the personal data of the data subjects.
6. Rights of data subjects and how to exercise them
The articles from 15 to 22 of the Regulation and Law grant data subjects specific rights that they may exercise. Art. 15 of the Law and Regulation recognizes the right of data subjects to access their personal data and obtain a copy. The right to obtain a copy of their data shall not infringe on the rights and freedoms of others.
With the request of access, data subjects have the right to obtain from the data controller confirmation or denial of the fact that their data are being processed and to know the purposes and categories of data involved, the third parties to which they have been communicated and whether the data have been transferred to a country outside Europe with adequate guarantees. The data subjects also have the right to know for how long their personal data will be used, in respect of the aforementioned purposes.
With respect to their personal data, data subjects may request correction of incorrect data and completion of incomplete data, as well as deletion (right to oblivion) at the conditions indicated by art. 17 of the Regulation, and may request limitation of processing and portability of data.
To exercise the above right, it is necessary to contact one of the following parties:
- the Data Controller at the email address privacy@themarket.sm or the DPO at the address dpo@themarket.sm, or by writing to the address of the registered office of THE MARKET;
— the Representative in the European Union at the email address:rappresentanteUEsanmarinoutlet@gmail.com or by writing to the address of its registered office at Via San Zeno n. 173, 25124 – Brescia.
Before responding, it may be necessary to identify the data subjects by asking them to supply a copy of their identity document. The data controller will provide a written answer without undue delay and, in any case, no later than one month after receipt of the request.
7. Claims with the Guarantor for the protection of personal data
Data subjects who believe that use of their personal data violates the provisions of the Law, the Regulation or, more in general, the norms on the subjects of the protection of personal data, may file a claim:
— if they reside or work in the Republic of San Marino, or the violation occurs there, to the Guarantor for the Protection of Personal Data (www.garanteprivacy.sm), as provided by art. 66 of the Law, or to apply to the appropriate judicial authorities (art. 70 of the Law);
— if they reside or work in the European Union, or the violation occurs there, to the Italian Guarantor for the Protection of Personal Data (www.gpdp.it), as provided by art. 77 of the Regulation, or to apply to the appropriate judicial authorities (art. 79 of the Regulation).