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This information is provided to persons interacting with the services of the website https://www.sanmarinooutlet.com/  (hereafter, “Website”).

This information does not concern other websites, pages or online services that may be reached via any hypertextual links published on the website but referring to resources external to the domain https://www.sanmarinooutlet.com/. 

Personal data will only be used in accordance with:

• EU Regulation no. 679/2016 (hereafter “Regulation”);

• Law no. 171/2018 of the Republic of San Marino (hereafter “Law”);

• the guidelines of the relative Guarantor.

1. DATA CONTROLLER, OFFICE RESPONSIBLE FOR USE AND PROCESSING OF PERSONAL DATA and EU REPRESENTATIVE

The  Data Controller  is the owner of San Marino Outlet  (hereafter, “SMO”) i.e. The company identified as 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 an officer responsible for Data Protection (DPO), who can be reached at the address dpo@themarket.sm or by writing to the registered office 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;

Finally, the Processor of Personal Data, in its role as business and marketing manager in charge of handling relations with the users, is Promos S.r.l. – fiscal code and V.A.T. no.: 03123920179 – Via San Zeno, 173- 25124 Brescia (BS), Phone: +39 030 2422862- Fax: +39 030 2422870, Email: privacy@promosgroup.it, with Stable Organization in San Marino in Falciano, Strada degli Angariari 41. 

The company responsible for the processing and use of personal data has also appointed an officer responsible for Data Protection (DPO), who can be reached at the address dpo@promosgroup.it or by writing to the registered office of Promos S.r.l..

2. PRINCIPLES OF DATA USAGE

In processing the personal data of the users, THE MARKET will apply the principles of legitimacy, correctness and transparency. Personal data will be collected for specific, explicit and legitimate  purposes (limitation of purpose) and will be adequate, pertinent and limited with respect to the purposes for which they are used (minimization of data). Data will always be updated and exact, and will be saved for a period of time no longer than necessary for the pursuit of the Data Controller’s purposes (limitation of conservation), after which they will be deleted. Finally, the data will be processed applying all the most adequate safety measures to ensure integrity and inaccessibility by unauthorized third parties (integrity, confidentiality and unavailability).

3. DATA PROCESSED

a) Data acquired during navigation

The systems and applications dedicated to the operation of this website collect, during their normal operation, data whose transmission is implicit in the use of the communication protocols typical of the Internet. 

The data in this case are not collected in order to be associated with identified data subjects, but by their nature could be processed and associated with data controlled by others so as to identify the users. This category of data would include the IP addresses or domain names of the computers used by users who connect to the website, the addresses in URI (Uniform Resource Identifier) notation of the resources requested, the time of the request, the method used in submitting the request to the server, the dimensions of the file obtained in reply, the numerical code indicating the status of the response given by the server (successful outcome, error, etc.) and other parameters relative to the operating system and digital environment of the user. These data are used for the sole purpose of obtaining anonymous and aggregate statistical information about use of the website and to control its correct function. The data may also be used for ascertaining liability  in case of hypothetical cybercrimes against the website.

b) Data provided voluntarily by the users

THE MARKET also collects personal data provided voluntarily by users when they interact with services on the website or when they fill out data collection forms. This may occur when subscribing to the newsletter or when participating in other initiatives on the Website involving information and the exchange of messages. 

In the sections of the website where user data are collected, there is always a link to this Privacy Policy or other specific information about the uses made of personal data.

If users, when accessing the services of the website, supply third party data, they guarantee that these are provided with the consent to communication thereof, if necessary.

c) Cookies

Users are invited to read the specific Cookie Policy of the Website to obtain detailed information about the type and mode of use of cookies and similar tracing tools.

4. PURPOSES AND LEGAL BASIS FOR PROCESSING DATA. 

The data will be processed for the following purposes:

a) Navigation of the website.

PURPOSE: to enable users to navigate the website.

LEGAL BASIS: need to respond to specific requests of data subjects and perform the contracts stipulated with them.

NATURE OF SUPPLY: necessary for anyone who wishes to navigate the website and use the relative services.

b) Newsletter and other marketing activities.

PURPOSE: to enable users who subscribe to the newsletter and other communications of the Data Controller to receive information about promotions, offers, initiatives, etc., via e-mail, text and video messages and other types of instantaneous messaging, in addition to the traditional advertising methods (telephone calls, regular mail.) 

LEGAL BASIS: consent of the data subjects. After consenting, data subjects can revoke or withdraw their consent at any time. To do so, it is sufficient to use the “Unsubscribe” option provided in every e-mail sent, or to contact the data controller.

FORM OF CONSENT: consenting to the use of personal data to subscribe to the newsletter or receive other advertising material from the Data Controller is optional. In case of non-consent, it will still be possible to navigate all the sections of the website. 

c) Collection of data from users of “Open Positions – Spontaneous Application” forms or other forms available on the website. 

PURPOSE: The data provided in sending your resume or by filling out the application form on the website will be processed exclusively for the purpose of recruiting and selecting personnel and/or other contact purposes of San Marino Outlet. With regard to the form “Open Positions – Spontaneous Applications” full information will be provided at the time of a possible interview with the applicant. In all other cases, specific information will be provided by THE MARKET to the users if necessary.

LEGAL BASIS: performance of precontractual measures applied at the request of the data subject, and any consent of the user in case of communication of the resume to the brands that have stores at the San Marino Outlet.

FORM OF CONSENT: provision of the data is necessary when applying for a position with the Company or with any of the brands that have stores at the San Marino Outlet and/or in any case in which users want to contact or participate in initiatives of the San Marino Outlet.

5. MODE AND DURATION OF USE 

The personal information of data subjects will be collected and processed with electronic devices and, to a lesser degree, using manual devices, only for the time necessary to fulfill the purposes of the data controller. The logics and procedures of processing are related to the purposes specified in this informative document. Depending on the specific purpose of their use, personal data are accessible for processing by authorized personnel, and by management-level personnel in charge of data processing. 

Automated decisional processes that produce legal effects for the data subjects or affect them in significant ways are not used.

The personal data of users will be processed for the time necessary to manage their interaction with the Website and to secure their use of the relative goods and/or services. Once these purposes have been achieved, the data will be conserved for the time required by law for administrative, accounting and fiscal purposes and to validate any rights and interests of a contractual nature. 

Data processed for subscription to the newsletter or participation in other marketing activities are maintained until such consent is revoked or withdrawn by the user.

6. RECIPIENTS OF PERSONAL DATA

Personal data may be communicated to third parties who perform activities necessary for the provision of the services offered by the website, who process the data as data processors or independent data controllers. Specifically, the data will be processed by the following parties or categories of parties:

• business partners engaged in the supply of IT services;
• suppliers of services that operate on behalf of the Data Controller, on the basis of contractual agreements, to perform activities connected with the administrative, commercial and advertising management of San Marino Outlet; 
• companies and consultants, engaged in assistance and consulting services on legal, accounting and fiscal matters;
• suppliers of services for the management of the information system and telecommunications networks, including email; 
• government authorities ensuring compliance with legal obligations;
• participating stores and food service providers at San Marino Outlet.

Through the icons of the social networks present on the website, some user data may also be conveyed to social networks. With respect to these uses, which are made externally to this website, you are referred to their specific privacy policies.

All the parties listed above are required to use the information received only for the purposes of processing as indicated above, and to keep the data confidential, intact and inaccessible to unauthorized third parties. The data of our users are not made public.

7. TRANSFERRAL OF PERSONAL DATA

Some personal data 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. 

8. RIGHTS OF DATA SUBJECTS

The articles from 15 to 22 of the Law and Regulation grant data subjects specific rights that they can exercise. Art. 15 recognizes the right of data subjects to access their personal data and obtain copies of them. The right to obtain a copy of their data shall not infringe on the rights and freedoms of others.

With the request of access, the 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 whom they have been communicated and whether the data have been transferred to a country outside Europe with adequate guarantees. 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.

The data controller will issue a statement to the data subject certifying that the operations mentioned above have been notified to those to whom the data had been notified and disclosed, unless this should be found to be impossible or imply the use of means clearly disproportionate to the right protected.

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 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. 

9. 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 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 apply to the appropriate judicial authorities (art. 79 of the Regulation). 

9. UPDATES

This privacy policy may undergo changes and/or additions following possible subsequent amendments and/additions to the regulations, updates or the provision of new services, as well as in response to technological innovations. Any changes will be published on the website and, if necessary, communicated to the data subjects via email.

Version dated March 19, 2026