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PRIVACY POLICY

2G-STUDIO DI GOBBI GIOELE VAT Number: 03532990987 | Via Indro Montanelli, 9 – Rovato (BS)

PRIVACY POLICY Information on the processing of personal data pursuant to EU Reg. 679/2016 (GDPR) Version 2.0 – June 2025

INFORMATION ON THE PROCESSING OF PERSONAL DATA pursuant to articles 13-14 of Regulation (EU) 2016/679 (GDPR) and Legislative Decree 196/2003 as modified by Legislative Decree 101/2018

LEGAL DOCUMENT – READ CAREFULLY This policy describes how 2G-Studio di Gobbi Gioele collects, uses, and protects the personal data of website users and photography service clients. Last update: June 2025

Art. 1 – Data Controller The Data Controller of personal data is: 2G-Studio di Gobbi Gioele Via Indro Montanelli, 9 – 25038 Rovato (BS) – Italy VAT: 03532990987 Email: gioelegobbi@gmail.com DPO/Privacy Contact: not mandatory due to the controller’s size (art. 37 GDPR)

Art. 2 – Types of Data Collected 2.1 Data provided voluntarily by the user • Identification data: first and last name • Contact data: email address, telephone number • Billing data: full address, tax code, or VAT number • Shipping data: delivery address • Order data: products purchased, preferences, customer service communications • Account access data: username and encrypted password

2.2 Automatically collected data • IP address and browsing data (access logs, browser, operating system) • Technical and analytical cookies • Session data and interaction with the site

2.3 Payment data IMPORTANT – Payment Data: Data related to credit cards or bank details are NEVER transmitted to or stored by 2G-Studio. Processing occurs exclusively through PCI-DSS certified providers (e.g., Stripe, PayPal).

Art. 3 – Purposes and Legal Bases for Processing Processing is lawful only under the following legal bases: • Order and contract management: Art. 6(1)(b) – Contract execution. • Tax and accounting obligations: Art. 6(1)(c) – Legal obligation. • WooCommerce account management: Art. 6(1)(b) – Contract execution. • Site security: Art. 6(1)(f) – Legitimate interest. • Direct marketing: Art. 6(1)(a) – Consent. • Publication of event photos: Art. 6(1)(f) – Legitimate interest / Consent.

Art. 4 – Processing Methods Processing is carried out using IT tools and, where necessary, paper. Adequate technical and organizational measures are adopted according to Art. 32 GDPR (encryption, access control, backup).

Art. 5 – Retention Periods Personal data is stored for the strictly necessary time: • Tax and accounting data: 10 years from registration. • WooCommerce account data: Until account deletion + 30 days. • Marketing data (newsletter): Until consent withdrawal. • Event photos: Unlimited or until consent withdrawal.

Art. 6 – Recipients and Data Processors Data may be communicated to: Hosting providers, couriers, tax consultants, and payment providers (Stripe, PayPal) as independent controllers. Data is not sold or transferred to third parties for commercial purposes.

Art. 7 – Transfer of Data Outside the EU Some services (e.g., Stripe, Google) involve data transfer to third countries. These transfers comply with Chapter V of the GDPR (Standard Contractual Clauses or Data Privacy Framework).

Art. 8 – Rights of the Data Subject The data subject may exercise the rights provided by Articles 15-22 of the GDPR (Access, rectification, erasure, objection, portability). Requests must be sent to: gioelegobbi@gmail.com. You also have the right to lodge a complaint with the Privacy Authority (Garante).

Art. 9 – Specific Provisions for WooCommerce WooCommerce collects registration, checkout, and order history data. It uses essential technical cookies for the cart and session. Users can request account deletion, except for data subject to mandatory tax retention.

Art. 10 – Data Processing in Photography Activity Photography activity is based on the legitimate interest in documenting sporting events (Art. 6.1.f GDPR) or explicit consent for commercial uses. Anyone portrayed can request image removal for legitimate reasons by writing to gioelegobbi@gmail.com. Special provisions apply for the protection of minors.

Art. 11 – Amendments to this Policy The Controller reserves the right to modify the policy in case of regulatory changes. Updates are published on the site with the revision date.

Art. 12 – Applicable Law and Jurisdiction Policy compliant with Italian and European law. Competent court: Brescia.

Date of drafting: June 2025 Data Controller: Gobbi Gioele – 2G-Studio

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