CROMIA CARD GUIDELINE

Promoter:
The promoting company is La.i.pe. s.p.a. with its legal head office in Tolentino (MC) VAT  00334670437, registered  with the Macerata  Chamber of Commerce, REA MC83342

Type:
The Fidelity Program includes a Fidelity card. For every purchase, the owner of the card will receive a discount of 10% on the purchased items both from the CROMIA boutiques and/or on the internet website www.cromia.it.
The discount is not cumulative, for this reason it can not be applied to items subjected to other promotions, discounts and/or seasonal sales in the boutiques and/or on the internet website www.cromia.it.

Name of the Program:
CROMIA CARD Fidelity Program

Purpose:
Sales Promotion through loyalty rewards

Geographical areas:
The promotion is valid in all the Italian CROMIA boutiques indicated both in the list and/or on the internet website www.cromia.it. For a detailed list of CROMIA boutiques, please refer to attachment A at the end of this document.

Promotion period:
The campaign will be held according to the following terms:
- Valid from 01/07/2015 to 31/12/2023
- Deadline for using voucher: 28/02/2024

Conditions:
The customer can join the CROMIA CARD Fidelity Program by subscribing for free. The subscription request can be done by filling in and submitting the specific application form either in person at the CROMIA boutiques and/or on the internet website www.cromia.it.
After joining the Fidelity Program, the Customer will receive a fidelity card called CROMIA CARD. Using the CROMIA CARD the Customer will accumulate loyalty points and will have a 10% discount that can be used for any single purchase on regularly priced items in the CROMIA boutiques and/or on the internet website www.cromia.it.

Recipients:
The CROMIA CARD can be issued by every CROMIA boutique in Italy and/or on the internet website www.cromia.it and is reserved to all retail  and online customers of legal age who have previously purchased products in the Cromia stores or webshop and joined the Fidelity Program by filling in and submitting the specific application form.
The holder of the card guarantees the accuracy of all the information given and represents the sole responsible.
The holder of the CROMIA CARD can take advantages of all promotional operations and special initiatives.
The CROMIA CARD belongs to La.i.pe. s.p.a and is given free of charge after subscribing the specific form.
The full guideline is available both in Cromia boutiques and/or on the internet website www.cromia.it. It can be also requested at info@cromia.it.
Each customer can have only one CROMIA CARD. It is not possible to activate more than one card at the same time with the same name.
In case of loss or theft, the holder of the CROMIA CARD must immediately report it by sending an e-mail to info@cromia.it or by contacting the boutique where the card was issued. The company accepts no liability for any misuse if not communicated previously mentioned.
In case of loss or theft, the holder can ask for a replacement card. The fidelity points will be recovered and transferred to the new one.

Moreover, the CROMIA CARD Fidelity Program promoted by La.i.pe. s.p.a. allows the customers to benefit from other promotional operations and special initiatives as for example THE BIRTHDAY VOUCHER.
Each Customer will have a free birthday gift: a € 20,00 (twenty) discount voucher the customer can use within 30 days from the date of birthday, to purchase regularly priced items in any CROMIA boutique and/or on the internet website www.cromia.it. The birthday voucher cannot be combined with any other offer, promotion, discount or seasonal sale, and should be used for a purchase with a total net amount not under € 80.00 (eighty).

Products under promotion:
The promotion is applied to all products of any amount sold in the CROMIA boutiques and on the website www.cromia.it but it cannot be combined with any other offer, promotion, discount or seasonal sale.

CROMIA CARD contents:
During the CROMIA CARD Fidelity Program, customers with a CROMIA CARD buying Cromia products for any amount in the CROMIA Stores or on the website www.cromia.it will receive a 10% discount and will accumulate fidelity points (1 point per euro).

Points collection and benefits:
By showing the CROMIA CARD, customers will receive 1 (one) point per euro calculated on the amount spent to purchase items in CROMIA boutiques or on the website www.cromia.it. The discount cannot be combined with any other offer, promotion, discount or seasonal sale.
Failure to present the CROMIA CARD at the time of purchase won’t allow points collection and discount benefits.
Points will be directly accumulated in the Customer’s CROMIA CARD.
Points cannot be traded or turned into money.
For the points calculation it will be considered the total net amount paid by the Customer after discounts, voucher or similar promotions.
The owner of the CROMIA CARD will receive another discount voucher of € 15,00 (fifteen) the customer can use to purchase regularly priced items in any CROMIA boutique or on the website www.cromia.it. The voucher cannot be combined with any other offer, promotion, discount or seasonal sale, and should be used for a purchase with a total net amount not under € 80.00 (eighty).

How to refer to the point balance:
To know the point balance, please check you personal website area or refer to the CROMIA boutiques’ staff or write an e-mail to info@cromia.it.

Guideline amendment:
The company reserves the right to modify, even partially, or suspend, at any time, the terms and other provisions of this Fidelity Program, by communicating the contents of this modification on the website www.cromia.it and/or in the CROMIA boutiques.

Privacy:
Under Article 13 of Legislative Decree n. 196 of 30 June 2003, (the "Code on Personal Data Protection"), Article 13 of the European Regulation n. 679 of 2016 (“GDPR” - General Data Protection Regulation) and also Recommendation n. 2 of 2011 adopted pursuant Article 29 of Directive n. 95/46/CE, the company LA.I.PE. S.P.A. wants to inform you and all the other customers that require a CROMIA CARD, about the uses  of the collected personal data.
Data Controller ad Managers:
The controller of the processing of data collected and processed is La.i.pe. S.p.a. located in Tolentino, Via Walter Tobagi 2, VAT number 0334670437, registration number in the Register of Companies of the Chamber of Commerce of Macerata MC – 83342, e-mail: privacy@laipespa.com.
The updated list of the chosen Managers of the personal data can be provided upon the request of the interested parties.
The Data Protection Officer is Avv. Gianluca Rocchetti with office in Porto Sant'Elpidio (FM - Italy), via Siracusa 25, vat 01891090449 - pec: gianluca.rocchetti@ordineavvocatifermopec.it, email: rocchetti.gianluca@gmail.com, tphone number +39 0734 902540
Your personal information are used to enable you, throught the use of the CROMIA CARD, to activate and manage the CROMIA CARD itself, using the related services, discounts and promotions.
Your personal data are processed in order to:
a) carry out “loyalty” activities connected to the issue and the management of the CROMIA CARD which cannot be used anonymously and which are necessary for the attribution of the advantages which are related to its use including the earning of points and/ or offers, discounts, etc…
b) inform you about our sales or direct marketing promotions by forwarding advertising material with electronic tools and/ or by contacting you in a traditional method, for example through push notifications, e-mails (newsletter) and/ or 
c) by sending to you sms and mms (Marketing Services).

The management of the collected data for the aforementioned purposes will be carried out in accordance with the Privacy Code, the GDPR and all the specific sector regulations including what is stipulated in the "Guarantor Rules for loyalty programs" of February 24, 2005 and the "Guidelines on the processing of personal data for the online profiling" of March 19, 2015.
In accordance with what is stipulated in “Guidelines of promotional activities and fight against spam" of July 4, 2013, we highlight that the consent you may provide for the dispatch of commercial, promotional and marketing communications through automated tools will also extend to the traditional methods of contact. 
The provided data will be processed mainly with IT tools under the authority of the Data Controller, by a specific appointed staff, authorized and instructed to process data in accordance with Article 30 of the Privacy Code and Articles 28 and 29 of the GDPR. In order to prevent data loss, illicit or incorrect use and unauthorized access, we inform you that appropriate security measures will be observed also pursuant to art. 5 and 32 of the GDPR.
For the purposes of point a) the provision of your personal data is mandatory because in absence of these information you won’t be able to obtain and/ or use the CROMIA CARD, taking advantages of the card itself, including the earning of points and/ or offers, discounts, etc…
The provision of your personal data instead, is not mandatory but optional for the purposes of point b). The missing transmission of the data for the aforementioned purposes  won’t allow us to send to you any newsletter or to provide you any Marketing Service. You can freely choose to give your consent also for these purposes. This will not prevent the possibility to obtain and/or to use the CROMIA CARD with all its benefits. Please remember that, in any case and at any time, you can request to the Data Controller to delete your data:  you can do it with a simple written communication, without any particular formalities, to the above addresses.
With reference to the purposes of point a), the legal basis of the processing is in fact the execution of the provided services of the CROMIA CARD, requested by you (pursuant to article 6, paragraph 1, letter b of the GDPR and article 24, paragraph 1, letter b of the Privacy Code); instead, with reference to the purposes of points b) and c), the legal basis of the processing is your possible consent freely expressed (pursuant to article 6, paragraph 1, letter a of the GDPR and article 23 of the Privacy Code ).
Your personal data may be communicated, within the EU, in full compliance with what is stipulated in the  Privacy Code and in the GDPR, to the following parties:
(i) to the financial administration and/ or other public authorities, in case this is required by law or at their request;
(ii) to the organizations, parties and external companies that the Controller uses in order to carry out the connected activities which can be instrumental or consequent to the Newsletter and to the provision of the Marketing Services,and to the release and the management of the CROMIA CARD;
(iii) external consultants (for example, for the management of tax obligations), if not designated Data Processors in writing.
The collected information and some anonymous data relating to the number and the type of interactions on gaming services combined with the purpose of loyalty in the strict sense, may also be transferred to the Extra EU cloud server because such processing may result necessary for the Site Services requested by  you. The legal basis for this processing is therefore art. 49, paragraph 1, lett. b of the GDPR and Article 43, paragraph 1, lett. b Privacy Code.
Please remember that, at any time, you can exercise your rights referred to art. 7 of the GDPR and referred to Articles 15, 16, 17, 18, 20 and 21 of the Privacy Regulation, by sending a written communication to the address of the Controller we referred to in the previous art. 1 in order to obtain:
* the confirmation of the existence of your personal data with information of its origin. You can verify as well its accuracy or you can request its updating, correction and/or integration;
* the access, correction, cancellation of the data or the limitation of processing;
* the cancellation, transformation into anonymous form or blocking of data processed in violation of the law.

You can request the revocation of consent for the processing of your personal data through this LINK: https://mediastudio.biz/Revoca_Consenso.aspx?target=revoca&u=CROMIA&action=generic&lang=en

You can also oppose to the processing of your personal data.
With reference to the Newsletter and to the Marketing Services, we would like to point out that your right to request the termination of processing carried out through automated contact methods is also possible through traditional ways. 
Furthermore, you have the possibility to exercise this right only in part, that’s to say, you can require, for example, the interruption of sending promotional communications through one or some of the contact tools for which you gave consent.
Except for legal obligations, personal data will be stored for a specified period, based on criteria linked on the nature of the services which are provided.
Your data are processed in compliance with the applicable law and using appropriate security measures in compliance with the legislation in force, also pursuant to art. 5 and 32 GDPR.
The Data Controller reserves the right to make changes to the Privacy Notice. In this case you will be promptly informed.

ATTACHMENT A

BOUTIQUE MILANO
Corso Venezia 3 - 20121 Milano
tel: + 39 02 76004390
e-mail: cromia.milano@laipespa.com

BOUTIQUE VENEZIA

San Marco Mercerie 787 - 30124 Venezia
tel: +39 041 5223310
e-mail: cromia.venezia@laipespa.com

BOUTIQUE ROMA

Piazza di Spagna 42/A - 00187 Roma

tel: +39 06 6788402
e-mail: cromia.roma@laipespa.com

BOUTIQUE SENIGALLIA
Corso II Giugno 11 – 60019 Senigallia
tel: +39 071 7924152
email : cromia.senigallia@laipespa.com