PRIVACY POLICY

Privacy Policy and Legal Notes

Preamble

This document, concerning the confidentiality policies for the personal data of “MICAM Milano”, a mark owned by A.N.C.I. Servizi s.r.l. with a single shareholder (hereinafter “ANCI”) which, through the company METHODOS s.n.c. manages the Website www.themicam.com (hereinafter the “Website”), and describes the procedures for the processing of the personal data of users and visitors of the Website, moreover, a specific part of this online space is dedicated to providing data subjects with the Legal Notes they should know and comply with when browsing the Website.

Therefore, 2 documents have been added to this online space:

  1. Privacy policy
  2. Legal Notes

Moreover, in the area “policy on the processing of personal data”, which was created specifically in the footer of the website and which can be accessed here, ANCI provides all the specific policies drafted on the basis of the purposes of the processing which data subjects are free to consult and which we refer to based on the specific type of processing and purpose.

Please note that the Website is constantly updated and adapted to changes in the law. Therefore, this document may be amended at the discretion of ANCI wherever it sees fit and a subsequent use of the Website implies acceptance by users of the any such variations. ANCI recommends that users check this document frequently; any updates and/or amendments will be published here.

 

  1. Privacy Policy

 

In accordance with Recommendation no. 2/2001 (recommendation of the European authorities for the protection of personal data to identify certain minimum requirements for the collection of personal data online, and, in particular, the procedures, timeframes and nature of the information that data controllers must provide to users when the latter connect to web pages, regardless of the purposes of the connection) and as required by art. 12 GDPR, in its capacity as Controller of the personal data pursuant to articles 4 and 24 GDPR (hereinafter referred to solely as Controller), A.N.C.I. Servizi s.r.l. with a single shareholder provides individuals browsing the website with the following policy information as a means for providing data subjects with the information in art 13 GDPR and the communications in articles 15 to 22 and 34 GDPR relating to the processing of personal data that is provided through browsing on the Website and/or to come into contact with the latter when the individual browsing the Website independently decides to interact directly with the addresses on the latter in order to come into contact with the Controller. The policy information below is not valid for other websites which may be accessible through our links.

Please note that you may contact the Controller by appearing at the registered offices (Milan, via Alberto Riva Villasanta 3) after making an appointment or by using the following contact information: Tel. 02-438291 | Fax. 02.48005833. The Controller has appointed a DPO, Atty. Laura Marretta, who may be contacted at the company telephone number 02.438291 and at the e-mail address privacy@assocalzaturifici.it.

On a preliminary basis we hereby inform you that your personal data are processed on the basis of the principles applicable to the processing of personal data as described in article 5 GDPR, i.e. principles of lawfulness, relevance, transparency, suitability, protection of confidentiality and rights, etc and that the processing is carried out on the basis of the conditions of lawfulness set forth in article 6 GDPR, for the purposes pertaining to the relationship established with the Controller and finally that, when users browse the website, the Controller does not collect the particular categories of data defined in article 9 GDPR. 

 

From visitors to our website, we only process data belonging to the type “Browsing Data, Cookies and Data communicated by the user and provided spontaneously, data from social media“, we therefore collect a limited quantity of data, which we use to improve your user experience on our website and manage the services we provide (e.g. answers to your requests) legal basis: article 6 paragraph 1 letter b and f. These data include the information relating to the procedures for the use of our website, the frequency of access to the website and the times at which our website is most popular. 

In relation to Browsing data: during normal operations, the computer systems and software procedures used to operate this Website acquire some personal data, the transmission of which is an inherent feature of Internet communication protocols. This category of data includes IP addresses or the domain names of computers and terminals adopted by users, the URI/URL (Uniform Resource Identifier/Locator) addresses of the requested resources, the time of the request, the method used to submit a request to the server, the size of the file obtained in response, the numerical code detailing the status of the response provided by the server (successful outcome, error, etc) and other parameters relating to the operational system and IT environment of the user. These data are only used to obtain anonymous statistical information on use of the Website and to check its correct functioning. The data may be used to ascertain responsibility in the event of hypothetical computer crimes. Browsing data do not persist for more than 30 days and are deleted after being processed (without prejudice to any requirements by the judicial authorities to investigate crimes). Moreover, we will be informed of all accesses made by logging onto this website for pages with reserved access.

In relation to Cookies on the website, we refer in full to the provisions of the cookies policy that is available here.

In relation to Data communicated by users and spontaneously provided please note that in the event of you sending messages to the Controller’s contact addresses (data supplied spontaneously) we will acquire both the sender’s contact data, which are necessary for responding, and all the personal data included in the communications. We therefore request that you only provide in these communications the information that is strictly necessary for us to provide you with a response.

In relation to the processing of personal data made by the managers of the Social Media platforms used by the Controller, please refer to the information provided by the former through their respective privacy policies when browsing on the respective social media platform. The Controller processes the personal data provided by users through the pages of the Social Media platforms dedicated to MICAM Milano, within the scope of its communication and promotion purposes in the footwear, fashion and Italian manufacturing sectors in order to manage, improve and increase interactions with users (comments, public posts, etc) in accordance with the prevailing legislation.

The provision of data is optional, with the exception of those acquired automatically by the system.

It remains understood by the parties that the data shall also be processed to defend a legitimate right.

Data will be processed in paper form and/or electronically by parties specially authorised to do so.

The Data Controller does not process data on the basis of automated decision-making processes. The data will be stored for the amount of time necessary to fulfil the purpose the data was collected for.

The data may be communicated to the company that carries out the activities associated with the maintenance of the technological part of the website. The data may be communicated to specifically appointed representatives of the Data Controller (pursuant to art. 27 of the GDPR) and to its Data Processors (pursuant to art. 28 of the GDPR).

Data breach: If the Data Controller should suffer a violation of the type described in articles 33 and 34 involving a risk to the rights and freedoms of individuals (a data breach), the Data Controller will, if necessary, notify the Authority and inform all data subjects of the breach.

The Controller informs data subjects that they are granted the following rights:

– art. 15 – right of access, i.e. the data subject/user has the right to obtain information on which of his/her data are processed by the Controller, the purposes being pursued, the time for which said data will be retained and the procedures with which they are processed.

– art. 16 – right of rectification, i.e. the data subject/user has the right to verify the correctness of his/her data and to request any amendments/integrations.

– art. 17 – right to erasure, i.e. the data subject/user may request the erasure of his/her data if specific conditions are satisfied, such as, for example, the personal data is no longer necessary for the purposes it was collected for.

– art. 18 – right to restriction of processing, i.e. the data subject/user may request a restriction in the processing that can be carried out on his/her data in the event of specific conditions, such as, for example data for a specific purpose was acquired from the data subject in an unlawful manner.

– art. 20 – right to data portability, i.e. the user/data subject has the right to receive his/her data in a structured, commonly used and machine readable format and, where technically feasible, to obtain the transfer of these data to another controller without hindrance when data are processed with automated instruments and the processing is based on the consent of the User, a contract the User is a party to or to contractual measures connected thereto.

– art. 21 – right to object, i.e. the user/data subject has the right to oppose to the processing of his/her data when this takes place on a legal basis other than consent for reasons connected to his/her specific situation; when, however, the legal basis is consent, the data subject/user can object at any time, but the processing that has been carried out until that time remains lawful.

– art. 22 – Automated individual decision-making, including profiling: without prejudice to specific derogations that are expressly set forth by the above article, the data subject/user has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him/her or which similarly significantly affects him/her.

To exercise the rights listed above or for more information, simply send an email to the DPO at the email address privacy@assocalzaturifici.it stating the wording “exercising of rights under the GDPR” in the subject line and specifying the right that you wish to exercise in the body of the email.

The Data Controller will respond to requests to exercise rights in accordance with the deadlines set forth in article 12 paragraph 3 GDPR. Please note that it is your right to present a complaint to a supervisory authority (the Italian supervisory authority for the protection of personal data www.garanteprivacy.it).

Should the Data Controller intend to process personal data for a purpose other than that for which it was collected, the data subject will be provided in advance with information on this new purpose and all other pertinent information, and the Data Controller will seek his or her prior consent.

 

  1. Legal notes for browsing the Website

 

The website is the property of A.N.C.I., it is managed through the company METHODOS s.n.c. and is hosted by Siteground (www.siteground.com).

The Website is open to all users but the services provided through it may be used solely by individuals of full legal age and, in certain cases by registered users.

By accessing the Website users confirm, under their full and exclusive personal responsibility, to have reached 18 years of age or to have the consent of their parents or guardians and to have full power of judgement.

 

 

Property and copyrights

ANCI is the sole exclusive proprietor of all the rights and interests for the Website and any intellectual property connected to the latter, including the source codes of the Website and the software as well as developments deriving from this. The Website and the information contained therein are the property of ANCI or are licensed for use to ANCI. Unauthorised copying and circulation in breach of intellectual property rights is prohibited.

Access and use through sub-licensing by users of the contents of the Website is prohibited. Users will be deemed solely responsible for compliance with the provisions and obligations set forth herein given the lack of any direct relationship between ANCI and third parties.

All the contents of the Website are protected by the provisions of law relating to copyright. Any reproduction thereof, even in part, is forbidden.

The breach by a user of the conditions of use will result in access to the Website being denied, without prejudice to any greater damage. These rights may be exercised at any time.

Liability

The Controller shall not be held liable for either the content of the information published on the Website or the use third parties may make of same, due to any contamination deriving from website access, interconnection, or downloading of material or software from this website.

Consequently, the Controller shall not be held liable or in any way obliged to answer for any damage, loss or harm that third parties may suffer as a result of coming into contact with the Website or as a result of its use and reliance of the information published on the Website or of any connected software.

This liability exclusion also extends to the compatibility or otherwise of the Website with users’ hardware and software.

Any liability for the Controller is expressly excluded with regard to any damages deriving from the use of the Website, including the loss of data or infection with viruses, any attacks or unlawful actions which may be carried out by third parties through this Website. In this regard, users shall adopt the protective measures they deem appropriate before they begin or continue to browse on the Website or download information or images.

Users shall not use the Website in any way to carry out cyberattacks or any unlawful operations against the Controller or third parties.

The material and information available on the website may be changed or updated without notice.

Although the Controller uses the utmost care when uploading information on the Website, it takes no responsibility regarding the accuracy and completeness of the information provided, the use of which is at the sole risk of users. Placing said information at the disposal of users, the Controller does not grant any licenses on copyrights, patents or any other intellectual property right.

The presence of any links to third-party websites does not imply any responsibility for the Controller and it remains the exclusive responsibility of users to verify the conditions and terms of use of these websites at the time they access them.

Users of the Website are prohibited from conducting operations on the latter such as the insertion of links, the creation of frames, the insertion of texts, images or videos or make any amendment to the Website.

Users are not authorised in any way, including indirectly, to insert links to pages of the Website from their own website or third-party website. This limit applies to hypertext links as well as any additional form of links, including deep-linking, farming, and any other electronic procedure, without the prior written consent of the Controller, which shall be provided on an entirely discretionary basis.

ANCI shall not be deemed responsible in any way for the malfunctioning of the Website or the impossibility or difficulty to carry out ancillary services deriving from the responsibilities of the managers of telephone and electrical lines, as well as global and national grids, by way of example but not of limitation, following faults, overloading, interruptions, etc or by causes beyond its reasonable sphere of control or causes of force majeure or accidents, such as, by way of example and not of limitation, civil commotion, acts of terrorism and war, strikes, riots, tornadoes, hurricanes, floods, fires, epidemics, landslides and mudslides.

A.N.C.I. undertakes to maintain the efficiency and functionality of the Website; in the event of it being forced to suspend the use of the Website for exceptional events or for maintenance purposes, these suspensions or interruptions will be limited to the shortest period of time possible.

A.N.C.I.  shall also not be responsible for the conduct or omissions of third parties which affect the functioning of the Website, including by way of example and not of limitations, reductions in speed or the non-operation of telephone lines and the computers managing the internet traffic between users and the Website.

 

USE OF IMAGES acquired from photos and/or videos

During our shows, fairs, collective shows, parties, assemblies or public events, shootings and/or photographs will be taken inside the corresponding location for the single occasion to document these events and promote them. Such images and videos will be posted both on the website and our social network profiles and will never damage the data subject’s honour and decorum; the Data Controller will not provide compensation therefor. Please note that your images, drawn from photographs and/or videos during public events, do not require the express consent of the depicted person. In any case, the Data Controller undertakes to act on this point in accordance with the instructions given by the Data Protection Authority with respect to images/videos acquired during public events. It remains understood that, if anyone wishes a picture of theirs to be removed or deleted, they may contact the address privacy@assocalzaturifici.com specifying in the subject “Processing of images” and, following an assessment, we shall proceed accordingly. Should photos/videos be taken during private events and/or including close-ups of children or disabled individuals, the Data Controller will provide a suitable privacy policy and collect the corresponding consents from the persons concerned.

Application of the legislation

By accessing the Website and browsing in the respective web pages, Users declare that they accept to be bound by the applicable Italian legislation.

We respond to all users who lodge a formal written complaint to the email address privacy@assocalzaturifici.it in order to get to the bottom of the problem reported. We undertake to cooperate with the competent authorities to resolve any complaints regarding the processing of personal data that should not be resolved directly between the Data Controller and private individuals.

These Conditions of Use are governed by Italian law. Any dispute relating to compliance with these conditions of use which is connected to the latter in any way is subject on a non-exclusive basis to Italian jurisdiction, and the specific jurisdiction of the Court of Milan.