We at Smooderbrand.com pay particular attention to the protection of your privacy and we want visitors to our site, as you can do it in total safety, both during simple navigation, and if they decide to provide their personal data to use specific services or features offered on our site.
Pursuant to and in compliance with current legislation on the protection of personal data, in particular with Legislative Decree 196/2003 and subsequent mod., including the Legislative Decree No. 101/2018 and Articles 4, 12, 13 and 24 and of the European Regulation on the Protection of Personal Data No. 679/2016 (GDPR), and in relation to the personal data of which Weby S.r.l. based in Viale Giulio Cesare 47, 00192 Roma, VAT number n ° 02153450560, as Data Controller, will come into possession, we therefore inform you of the following.

1. Data Controller
The Data Controller (hereinafter also "the Controller") is Weby S.r.l. with headquarters in the Viale Giulio Cesare 47, 00192 Roma, VAT number 02153450560.

1.1 Data Processor
The Data Processor is Shopify International Ltd. with headquarters at Intertrust Ireland, 2nd Floor 1–2 Victoria Buildings, Haddington Road, Dublin 4, D04 XN32, Ireland, Tel. +1 571 409 6451, email: privacy@shopify.com.
We also inform you that the updated list of Managers is available on request at the email address info@smooderbrand.com

2. Purpose and legal basis of the Treatment
The GDPR (art. 4, par.1) defines personal data as "any information concerning an identified or identifiable (" interested ") natural person; the natural person who can be identified, directly or indirectly, with particular reference to an identifier such as the name, an identification number, location data, an online identifier or one or more characteristic elements of his physical identity is considered identifiable, physiological, genetic, psychic, economic, cultural or social".
By processing of personal data (GDPR, Art.4, par. 2) we mean any operation or set of operations, carried out with or without the aid of automated processes and applied to personal data or sets of personal data, such as collection, registration, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or l interconnection, limitation, cancellation or destruction.
Access to this site, the display of the content hosted on it and the use of the services available on it may involve the collection, by the owner of this site or third parties (as better specified later in this information), of your personal data, provided by you, and in particular for the following processing purposes.
We may use the personal information provided, without your explicit consent, for the following purposes:

a) For the provision of the services provided through our website www.smooderbrand.com, in particular for the creation, management and maintenance, also in terms of security, of your account in our area reserved for members;

b) for the provision of e-commerce services offered by the owner to users of our website www.smooderbrand.com;

c) to collect and manage customer feedback on the services provided, as well as by the related commercial partners in the context of providing the service;

d) to provide our customer support services, both by e-mail and by telephone, also extended over time in relation to your individual needs and to your request relating to the above services;

e) to respond to comments and reports sent by customers;

f) for the administrative management of relations, including commercial ones, between the owner and the third parties indicated in the previous points;

g) for the monitoring and prevention of fraud and unauthorized use of the service.

The legal basis of the processing for the purposes referred to in points a) to f) the execution of a contract of which the interested party is a part or the execution of pre-contractual measures adopted at the request of the same (Art.6, par.1 , letter b), while for the purposes referred to in point g the legal basis of the processing is the fulfillment of a legal obligation to which the data controller is subject (Article 6, paragraph 1, letter c). We inform you that the communication of personal data necessary for
the achievement of the purposes indicated in points a) to f) is mandatory and any refusal to provide your data is not
will allow to provide the requested services.
Furthermore, we may use your personal data, subject to your explicit consent, for the following purposes:

h) to periodically update it on offers, promotions and discounts for the products on our website www.smooderbrand.com, in particular through the use of the e-mail newsletter service;

i) for the sending of promotional communications and advertising material, the offer of own and / or third party products and / or services, the carrying out of surveys and market research, through the use of telephone with operator and / or automated systems ( e.g. SMS, MMS, fax);

j) for the purpose of user profiling for commercial and marketing purposes based on the methods of use of our site www.smooderbrand.com, the interest shown for the various products / services and the exposure to advertising communication;

The legal basis for these treatments is your consent to the processing of your personal data, for one or more specific purposes (Art.6, par.1, letter a);
We remind you that, in any case, the consent you may have given may be revoked at any time
moment, writing to Weby S.r.l. to the addresses and in the manner indicated below:
Weby S.r.l. with headquarters in Viale Giulio Cesare 47, 00192 Roma, VAT number n ° 02153450560, by PEC at webysnc@pec.com or by email at info@smooderbrand.com

3. Source of Personal Data and Categories of Personal Data
To pursue the purposes referred to in the previous paragraph, the Data Controller may process the information exclusively provided by you and relating to cookies, as described in the specific Cookie Policy, both through automated communication channels and through traditional communication channels as described above.

4. Methods and duration of treatment
The use of your personal data will take place in compliance with the methods and requirements of the data provided by the so-called Privacy Code (Legislative Decree No. 196/2003) and ss. mod. and EU Regulation No. 679/16 (GDPR), with the support of paper, computerized or telematic, manual and automated means, for the purposes indicated in paragraph 2 of this statement, in compliance with the provisions relating to the protection of personal data , both by the Data Controller and any Data Processors, i.e. subjects who process personal data on behalf of the Data Controller, if necessary identified with a specific appointment deed. We also inform you that no disclosure of the personal data in question is made to third parties; however, the same data could be communicated and processed, for the aforementioned purposes, as well as to persons authorized to process personal data, under the direct authority of the owner or manager and / or managers of the treatment, to subjects who process the personal data on behalf of the Data Controller, identified with a specific appointment deed such as: 1. Private and public subjects for the performance of administrative and legal practices in compliance with the provisions of EU Reg. No. 679/2016; 2. Consultants and companies that assist the company from an IT and infrastructure point of view; 3. Professionals, consortia of services and consultants who assist the company from a tax, accounting, commercial and legal point of view; 4. Subsidiaries, investee companies or associates; 5. Client companies for the purpose of carrying out the collaboration established with the Data Controller; 6. Detection company about: quality of services provided, customer satisfaction, etc .; 7. companies that perform services related to the provision, monitoring, analysis of navigation, measurement and optimization of websites; companies specializing in marketing, re-marketing, social media, operational management of communication campaigns via the Internet, e-mail and / or telephone systems; 8. companies specializing in the provision of data processing, storage and / or analysis services, 9. Authorities and third parties if specifically identified for compliance with specific legislative obligations.
We also inform you right now that, if you have given consent for one or more specific purposes, you have the right to withdraw this consent at any time.
The Data Controller will keep the data collected for the time strictly necessary to pursue the purposes explained above, according to the principles of lawfulness, relevance and not excess; in the case of cookies, the storage time is explicit, if disclosed by the manufacturer of the publishing, management and editing software of this Shopify.com site, in the table included in the information relating to them, available https://en.smooderbrand.com/pages/cookies
In the event of a specific request, the personal data you provide may also be disclosed to the police, the judicial authority or other entities, in order to fulfill legal obligations and / or regulations, including of a fiscal nature.

5. Rights of the interested party and contact details of the Data Controller
We inform you that at any time you can exercise your rights towards the treatment, pursuant to Legislative Decree No. 196/2003 and ss. mod. as well as Articles 12-23 of the European Regulation on the Protection of Personal Data No. 679/2016 (GDPR).
In particular, we inform you that you have the right to ask the Owner for access to your personal data and thus obtain confirmation of the existence or not of personal data concerning you, know its content and origin, verify its accuracy or request its integration, updating and / or correction. We inform you that you have the right to lodge a complaint with a supervisory authority if you believe that the processing of personal data is unlawful, illicit or does not comply with the legislation in force. privacy matters, pursuant to art.13, par. 2, lett. d) GDPR.
Pursuant to the same legislation, you also have the right to ask the same owner for the limitation, transformation into anonymous form or blocking of personal data concerning you, if processed in violation of the law, and to receive in a structured format, of common use and data readable by automatic device
personal data concerning you and has the right to transmit such data to another data controller without hindrance by the data controller to whom you have provided them; you may also object at any time, for legitimate reasons, to the processing of the same personal data concerning you.
For the exercise of these rights, or to obtain any other information in this regard, requests must be sent by ordinary mail to the Data Controller, Weby S.r.l. with headquarters in Viale Giulio Cesare 47, 00192 Roma, VAT number n ° 02153450560, by PEC at webysnc@pec.com or by email at info@smooderbrand.com

We also inform you that no disclosure of the personal data in question is made to third parties; however, the same data could be communicated and processed, for the aforementioned purposes, as well as to persons authorized to process personal data, under the direct authority of the owner or manager and / or managers of the treatment, to subjects who process the personal data on behalf of the Data Controller, identified with a specific appointment deed such as: 1. Private and public subjects for the performance of administrative and legal practices in compliance with the provisions of EU Reg. No. 679/2016; 2. Consultants and companies that assist the company from an IT and infrastructure point of view; 3. Professionals, consortia of services and consultants who assist the company from a tax, accounting, commercial and legal point of view; 4. Subsidiaries, investee companies or associates; 5. Client companies for the purpose of carrying out the collaboration established with the Data Controller; 6. Detection company about: quality of services provided, customer satisfaction, etc .; 7. companies that perform services related to the provision, monitoring, analysis of navigation, measurement and optimization of websites; companies specializing in marketing, re-marketing, social media, operational management of communication campaigns via the Internet, e-mail and / or telephone systems; 8. companies specializing in the provision of data processing, storage and / or analysis services, 9. Authorities and third parties if specifically identified for compliance with obligations
specific legislation.
We also inform you right now that, if you have given consent for one or more specific purposes, you have the right to withdraw this consent at any time.
The Data Controller will keep the data collected for the time strictly necessary to pursue the purposes explained above, according to the principles of lawfulness, relevance and not excess; in the case of cookies, the storage time is explicit, if disclosed by the manufacturer of the publishing, management and editing software of this Shopify.com site, in the table included in the information relating to them, available https://en.smooderbrand.com/pages/cookies
In the event of a specific request, the personal data you provide may also be disclosed to the police, the judicial authority or other entities, in order to fulfill legal obligations and / or regulations, including of a fiscal nature. Finally, if you wish to further investigate the subject of the rights that concern you as an interested party, we invite you to visit the website of the Guarantor Authority for the Protection of Personal Data at the address https://www.garanteprivacy.com/Regolamentoue/diritti-degli-interessati.