PRIVACY

PRIVACY AND USE OF PERSONAL DATA:

I - INFORMATION RELATING TO THE SITE'S PRIVACY POLICY

1. This section contains information relating to Shoebuya's management methods in relation to the processing of Shoebuya user data.

2. This information is also valid for the purposes of article 13 of EU Regulation no. 2016/679, relating to the protection of natural persons with regard to the processing of personal data as well as the free circulation of such data, for subjects who interact with Shoebuya and can be reached at the address corresponding to the home page:

www.shoebuya.com

3. The information is provided only for Shoebuya and not for other websites that may be consulted by the user via links contained therein.

4. The purpose of this document is to provide information on the methods, times and nature of the information that the data controllers must provide to users when connecting to the Shoebuya web pages, regardless of the purposes of the connection itself, according to Italian legislation and European.

5. The information may undergo changes due to the introduction of new regulations in this regard, the user is therefore invited to periodically check this page.

6. If the user is under 14 years old, pursuant to art.8, c.1 EU regulation 2016/679, and Art. 2 - Quinquies of Legislative Decree 196/2003, as amended by Legislative Decree 181/18, must legitimize his consent through the authorization of his parents or legal guardian.

II - DATA PROCESSING

1 - Data Controller

1. The data controller is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. It also takes care of security profiles.

2. In relation to this website, the data controller is: Sara Valenti, and for any clarification or exercise of the user's rights you can contact him at the following email address: sara@shoebuya.com.

2 - Data processing manager

1. The data controller is the natural or legal person, public authority, agency or other body which processes personal data on behalf of the data controller.

2. Pursuant to article 28 of EU regulation no. 2016/679, upon appointment of the data owner, the person responsible for data processing of the Shoebuya site is: Sara Valenti.

3 - Place of data processing

1. The processing of data generated by the use of Shoebuya takes place at Via Padre Marcolini 14, 25030, Roncadelle (BS).

2. If necessary, the data connected to the newsletter service may be processed by the data controller or persons appointed by it for this purpose at the relevant office.

III - COOKIES

1 - Type of Cookies

1. The Shoebuya site uses cookies to make the user's browsing experience easier and more intuitive: cookies are small strings of text used to store some information that may concern the user, his preferences or the access device to Internet (computer, tablet or mobile phone) and are mainly used to adapt the functioning of the site to the user's expectations, offering a more personalized browsing experience and memorizing the choices made previously.

2. A cookie consists of a small set of data transferred to the user's browser by a web server and can only be read by the server that carried out the transfer. This is not executable code and does not transmit viruses.

3. Cookies do not record any personal information and any identifiable data will not be stored. If you wish, you can prevent the saving of some or all cookies. However, in this case the use of the site and the services offered could be compromised. To proceed without changing the options relating to cookies, simply continue browsing.

Below are the types of cookies that the site uses:

2 - Technical cookies

1. There are numerous technologies used to store information on your computer, which is then collected by the sites. Among these, the best known and most used are HTML cookies. They are used for navigation and to facilitate access and use of the site by the user. They are necessary for the transmission of communications over an electronic network or for the supplier to provide the service requested by the customer.

2. The settings to manage or disable cookies may vary depending on the internet browser used. In any case, the user can manage or request the general deactivation or deletion of cookies by changing the settings of their internet browser. This deactivation may slow down or prevent access to some parts of the site.

3. The use of technical cookies allows safe and efficient use of the site.

4. The cookies that are inserted in the browser and retransmitted through Google Analytics or through the blogger statistics service or similar are technical only if used for the purpose of optimizing the site directly by the owner of the site itself, who will be able to collect information in aggregate form on the number of users and how they visit the site. Under these conditions, the same rules apply to analytics cookies, in terms of information and consent, as provided for technical cookies.

5. From the point of view of duration, temporary session cookies can be distinguished which are automatically deleted at the end of the browsing session and are used to identify the user and therefore avoid logging in to each page visited and permanent ones which remain active on the PC until upon expiration or cancellation by the user.

6. Session cookies may be installed in order to allow access and permanence in the reserved area of ​​the portal as an authenticated user.

7. They are not stored permanently but exclusively for the duration of navigation until the browser is closed and disappear when the browser is closed. Their use is strictly limited to the transmission of session identifiers consisting of random numbers generated by the server necessary to allow safe and efficient exploration of the site.

3 - Third party cookies

1. In relation to their origin, a distinction is made between cookies sent to the browser directly from the site you are visiting and third-party cookies sent to your computer from other sites and not from the one you are visiting.

2. Permanent cookies are often third-party cookies.

3. Most third-party cookies are tracking cookies used to identify online behavior, understand interests and therefore personalize advertising offers for users.

4. Third-party analytical cookies may be installed. They are sent from the domains of the aforementioned third parties external to the site.

5. Third-party analytical cookies are used to detect information on user behavior on Shoebuya. The detection takes place anonymously, in order to monitor performance and improve the usability of the site. Third-party profiling cookies are used to create profiles relating to users, in order to propose advertising messages in line with the choices expressed by the users themselves.

6. The use of these cookies is governed by the rules established by the third parties themselves, therefore, users are invited to read the privacy information and the instructions for managing or disabling cookies published on the relevant web pages.

IV - DATA PROCESSED

1 - Data processing methods

1. Like all websites, this site also uses log files in which information collected automatically during user visits is stored. The information collected could be the following:

- internet protocol (IP) address;
- type of browser and parameters of the device used to connect to the site; - name of the internet service provider (ISP);
- date and time of visit;
- web page of origin of the visitor (referral) and exit;
- possibly the number of clicks.

2. The aforementioned information is processed in an automated form and collected in an exclusively aggregated form in order to verify the correct functioning of the site, and for security reasons. This information will be processed based on the legitimate interests of the owner.

3. For security purposes (anti-spam filters, firewalls, virus detection), the automatically recorded data may possibly also include personal data such as the IP address, which could be used, in accordance with the laws in force on the subject, in order to block attempts at damage to the site itself or to cause harm to other users, or in any case activities that are harmful or constitute a crime. Such data is never used to identify or profile the user, but only for the purposes of protecting the site and its users, such information will be processed based on the legitimate interests of the owner.

4. If the site allows the insertion of comments, or in the case of specific services requested by the user, including the possibility of sending the Curriculum Vitae for a possible working relationship, the site automatically detects and records some identifying data of the user , including the email address. Such data is intended to be voluntarily provided by the user at the time of requesting the provision of the service. By inserting a comment or other information, the user expressly accepts the privacy policy, and in particular agrees that the contents inserted are freely disseminated to third parties. The data received will be used exclusively for the provision of the requested service and only for the time necessary to provide the service.

5. The information that users of the site decide to make public through the services and tools made available to them are provided by the user knowingly and voluntarily, exempting this site from any liability regarding any violations of the law. It is up to the user to verify that they have permission to enter personal data of third parties or content protected by national and international regulations.

2 - Purpose of data processing

1. The data collected by the site during its operation are used exclusively for the purposes indicated above and kept for the time strictly necessary to carry out the specified activities, and in any case no longer than 10 years.

2. The data used for security purposes (blocking attempts to damage the site) are kept for the time strictly necessary to achieve the previously indicated purpose.

3 - Data provided by the user

1. As indicated above, the optional, explicit and voluntary sending of electronic mail to the addresses indicated on this site entails the subsequent acquisition of the sender's address, necessary to respond to requests, as well as any other personal data included in the message.

2. Specific summary information will be progressively reported or displayed on the pages of the site set up for particular services on request.

4 - Support in configuring your browser

1. The user can also manage cookies through his browser settings. However, deleting cookies from your browser may remove the preferences you have set for the site.

2. For further information and support you can also visit the specific help page of the web browser you are using:

- Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies - Firefox: https://support.mozilla.org/en-us/kb/enable- and-disable-cookies-website-preferences - Safari: http://www.apple.com/legal/privacy/it/
- Chrome: https://support.google.com/accounts/answer/61416?hl=it

- Opera: http://www.opera.com/help/tutorials/security/cookies/

5 - Social Network Plugins

1. This site also incorporates plugins and/or buttons for social networks, in order to allow easy sharing of content on your favorite social networks. These plugins are programmed so as not to set any cookies when accessing the page, to safeguard user privacy. Cookies are possibly set, if so provided by social networks, only when the user makes effective and voluntary use of the plugin. Please note that if the user browses while logged into the social network then he has already consented to the use of cookies conveyed through this site when registering on the social network.

2. The collection and use of information obtained through the plugin are governed by the respective privacy policies of the social networks, to which please refer:

Facebook: https://www.facebook.com/help/cookies

Twitter: https://support.twitter.com/articles/20170519-uso-dei-cookies-e-di-altre-tecnologie-similar-da-parte-di-twitter

Google+: http://www.google.com/policies/technologies/cookies Pinterest: https://about.pinterest.com/it/privacy-policy

AddThis: http://www.addthis.com/privacy/privacy-policy

Linkedin: https://www.linkedin.com/legal/cookie-policy

V. USER RIGHTS

1. The art. 13, c. 2 of EU Regulation 2016/679 lists the user's rights. 2. The Shoebuya site therefore intends to inform the user of the existence:

– of the right of the interested party to ask the owner for access to personal data (art. 15 EU Regulation), their updating (art. 7, co. 3, letter a) Legislative Decree 196/2003), the rectification (art. 16 EU Regulation), integration (art. 7, co. 3, letter a) Legislative Decree 196/2003) or limitation of the processing that concerns him (art. 18 EU Regulation) or object, for legitimate reasons, to their processing (art. 21 EU Regulation), in addition to the right to data portability (art. 20 EU Regulation);

- the right to request cancellation (art. 17 EU Regulation), transformation into anonymous form or blocking of data processed in violation of the law, including those whose retention is not necessary in relation to the purposes for which the data are have been collected or subsequently processed (art. 7, co. 3, letter b) Legislative Decree 196/2003);

– of the right to obtain certification that the updating, rectification, data integration, cancellation, data blocking and transformation operations have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or disseminated, except in the case in which such fulfillment proves impossible or involves the use of means manifestly disproportionate to the protected right (art. 7, co. 3, letter c) Legislative Decree. 196/2003);

3. Requests can be addressed to the data controller, without formalities or, alternatively, using the form provided by the Guarantor for the Protection of Personal Data, or by sending an email to the address: sara@shoebuya.com

4. If the processing is based on art. 6, paragraph 1, letter. a) – express consent to use – or on the art. 9, paragraph 2 letter. a) – express consent to the use of genetic, biometric, health-related data, which reveal religious or philosophical beliefs or trade union membership, which reveal racial or ethnic origin, political opinions – the user has the right to withdraw consent at any time without prejudice to the lawfulness of the processing based on the consent given before the revocation.

5. Likewise, in case of violation of the law, the user has the right to lodge a complaint with the Guarantor for the Protection of Personal Data, as the authority responsible for monitoring processing in the Italian State.

6. For a more in-depth examination of the rights you are entitled to, see the articles. 15 et seq. of EU Regulation 2016/679 and art. 7 of Legislative Decree 196/2003.

VI - DATA TRANSFER TO NON-EU COUNTRIES

1. This site may share some of the data collected with services located outside the European Union area. In particular with Google, Facebook and Microsoft (LinkedIn) through social plugins and the Google Analytics service. The transfer is authorized and strictly regulated by article 45, paragraph 1 of EU Regulation 2016/679, for which no further consent is required. The companies mentioned above guarantee their adherence to the Privacy Shield.

2. Data will never be transferred to third countries that do not comply with the conditions set out in Article 45 et seq. of the EU Regulation.

VII. SECURITY OF DATA PROVIDED

1. This site processes user data in a lawful and correct manner, adopting appropriate security measures aimed at preventing unauthorized access, disclosure, modification or unauthorized destruction of data. The processing is carried out using IT and/or telematic tools, with organizational methods and with logic strictly related to the purposes indicated.

2. In addition to the owner, in some cases, categories of persons in charge involved in the organization of the site (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third-party technical service providers, couriers) may have access to the data. postal services, hosting providers, IT companies, communication agencies).

VIII. CHANGES TO THIS DOCUMENT

1. This document, published at: https://shoebuya.com/pages/privacy

constitutes the privacy policy of this site.

2. It may be subject to changes or updates. If there are significant changes and updates, these will be reported with specific notifications to users.

3. Previous versions of the document will still be available for consultation on this page.

4. The document was updated on 01/09/2019 to comply with the relevant regulatory provisions, and in particular in compliance with EU Regulation 2016/679.