In accordance with GDPR 2016/679

Subject: Informative disclosure and consent for the treatment of data – Customers

The company Confort spa, in the person of Mr Morelli Ilario and the Responsible of Data Treatment, Mr Morelli Cristian provide the details concerning handling procedures of your personal data treatment, in accordance with GDPR 2016/679. It should be noted that this information will be updated whenever, due to the provision of the law and/or company procedure, changes will be implemented to the current management of your personal data.


  • 1 Data Controller and Data Processor

The Table (Tab_1) shows the references of the Data Controller and the Data Processor



Data Controller 
Legal company name Confort spaStrada Provinciale Maceratese, 12862012 – Civitanova Marche (Mc)

P.I. 01592920431



Data Processor
Name and Surname and Role Morelli Cristian


The updated list of sub- managers and of the data processors is kept at the headquarters of the Data Controller.


  • 2 Typology of treated data

In accordance with Art. 4 of the UE Regulation 2016/679, the data object of this document are qualified as ”personal data”, in other words as any information concerning a natural person identified or identifiable directly or indirectly.

Please note that your data personal data, subject to our treatment, are the following:

  • Name and Surname
  • Residence address
  • Fiscal code
  • VAT Number
  • Email
  • Mobile Phone Number
  • IBAN code


  • 3 Purposes of Processing

The data are processed and stored for the management of commercial and administrative relations relating to shoes manufacturing. Furthermore, your personal data may be processed for marketing and commercial information purposes carried out by our Company following your consent.


  • 4 Retention period

Data is maintained both in electronically and in paper format. The original documentation is kept at:

–  adiministrative office

–  delegate to conservation

The data are kept for the entire duration of the commercial relationship; while at the end of the same, only those personal data contained in the tax documents will be kept to comply with the provisions of the law. The data are stored in external providers and / or companies located in EU countries.


  • 5 Methods of treatment

With the term treatment modality in the present context, we describe the technical and organizational methodologies implemented by Confort spa to guarantee an adequate and safe management and conservation of data.

The data are processed in electronic and paper format and are accessible only by authorized personnel, by specific assignments and individual access permissions.


  • 6 Communication and dissemination

Your data is transmitted both electronically via company email or pec and through paper format to the following subjects:

  • to credit institutes for aspects related to payment processing;
  • to Tax Consultant Agencies for related obligations;
  • to the business consultants indicated in the previous art. 4;
  • to judicial or inspection authorities, in case of their requests;
  • to the delegation of digital preservation;

Your data will not be disclosed.


  • 7 Rights of the interested party

The interested party has the right to receive clear information regarding methods and purposes of processing his / her data. He is obliged to release his explicit consent that he can revoke at any time. However, it is specified that such revocation does not affect the lawfulness of the treatment based on the consent issued prior to the revocation.

The interested party has the right to access his data together with the right to obtain the correction of any inaccurate information concerning him; in the case of opposition to processing, our Company will restrict the use of its data.

Upon the termination of the conditions referred to in Article 3 above, our Company will delete its data deemed no longer necessary. Furthermore, pursuant to the 2016/679 EU Regulation, the interested party has the right  known as the “right to be forgotten  , to the cancellation and deindexing in the internet and in the virtual world; in this case the data will be deleted in compliance with the conditions established by law.

For the method of exercising your rights you can contact the Data Processor.


  • 8 The right to data portability

Each interested party has the right to the portability of its data, i.e the right to transfer his own data a from an electronic system to another. This situation occurs in the case of processing of the original data in digital preservation.


  • 9 The right to opposition and profiling

Pursuant to European Regulation 201 6/679 each interested party has the right to oppose the data processing for excessive purposes and different from those indicated and the subject of this disclosure, and the right not to be subjected to profiling measures. The company does not perform any profiling activity.


  • 10 Data security

The Data Controller, Data Processor and each person in charge carry out the most suitable safety measures to guarantee security in data processing and storage activities.


The Data Controller

Confort spa