This information is provided by THE MARKET PropCo S.r.l. to its suppliers and other parties acting on their behalf. 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”);
• the guidelines of the relative Guarantor.
1. Data Controller, DPO and office responsible for the 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 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 at Falciano, Strada degli Angariari 41. The data processing company has its own DPO who can be reached by e-mail at dpo@promosgroup.it , and by phone at +39 030 242 2862 or by writing to the company’s main office.
2. Data subject to processing — Purposes and legal bases
The personal data provided by suppliers and other persons acting on their behalf (first and last name, telephone number, company, address, fiscal data, banking data) will be process for the following reasons:
1. to fulfill the obligations stipulated in the contract: (legal basis) the need to execute the terms of the contract with the data subject;
2. to perform administrative, fiscal and accounting activities: (legal basis) fulfilment of legal provisions;
3. to ascertain, exercise or defend a right of the Data Controller in lawsuits: (legal basis) legitimate interest of the Data Controller.
The provision of data for purposes of assistance, building fidelity and administrative uses is necessary to engage in the relationship with the Data Controller. The contracting company or personal enterprise guarantees to supply this information to those of its employees who act on its behalf and whose data its communicates to THE MARKET, pursuant to articles 13 and 14 of the Regulation and Law.
2. Processing methods and term of data conservation
Data will be processed both manually and digitally, and only for the time necessary to achieve the purposes of the Data Controller. Having fulfilled these requirements, the data will be preserved for a period of 10 years (term of conservation for data used in accounting and fiscal activities and to exercise the rights of the data controller) and will then be deleted. In case of any legal disputes, the data will be maintained for the duration, until the term for filing of claims or appeals has expired. Fully automated decisional processes that produce legal effects for the data subjects or affect them in significant ways are not used.
3. Recipients of personal data
Personal data may be communicated to third parties for the purposes indicated above, and processed by them as data processors or independent data controllers.
4. Transfers of data to other countries
Some of the personal data of users are shared with recipients that may be located outside of the Republic of San Marino and the European Economic Community (EEC). The Data Controller guarantees that any processing of personal data by these recipients is done in respect of the Law and Regulation and, in any case, with full application of adequate security. Indeed, such transfers are based on a decision of adequacy or on the Standard Contractual Clauses approved by the European Commission.
5. Rights of suppliers and how to exercise them
The articles from 15 to 22 of the Law and Regulation 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.
6. 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).