Privacy Policy

Information document pursuant to Article 13 of EU Regulation 2016/679 (GDPR)

This page describes how personal data of users interacting with the Bruno Premi brand website is processed. The domain www.brunopremi.com is owned by Awards Shoes S.r.l., which also holds the brand.

This information notice is provided exclusively for the aforementioned website and not for other websites that may be consulted by the user via links. Awards Shoes S.r.l. is not responsible in any way for third-party websites.

This information notice is drafted pursuant to Article 13 of EU Regulation 2016/679 (hereinafter "GDPR") and is also inspired by the provisions of Directive 2002/58/CE, as updated by Directive 2009/136/CE, concerning cookies, as well as the provisions of the Italian Data Protection Authority regarding cookies and online tracking (in particular the Guidelines of 10 June 2021 and Provision no. 284 of 17 April 2026 on the use of tracking pixels in emails).

1. DATA CONTROLLER

Pursuant to Articles 4 and 24 of the GDPR, the Data Controller is:

Awards Shoes S.r.l. Registered office: Via dell'Industria 14, 35020 Brugine (PD) Operational office: Via Magellano 7, 25024 Leno (BS) VAT number and Tax Code: 05539300284 Email: info@awards-shoes.com Certified Email (PEC): awardsshoes@lamiapec.it

For any request related to the processing of their personal data, the data subject can contact the Controller at the addresses listed above or at the dedicated address info@awards-shoes.com.

2. TYPES OF DATA PROCESSED

Depending on the user's interaction with the website and the services offered, the Controller may process the following categories of personal data:

Identification and contact data: name, surname, email address, telephone number, shipping and billing address. Purchase-related data: order history, amounts, payment methods used, products purchased, sizes, and preferences. Payment data: managed directly by payment service providers (Shopify Payments, PayPal, Klarna), who act as independent data controllers. The Controller does not store full credit card numbers. Navigation data: IP address, browser type, operating system, pages visited, time spent, device used, website interaction data. Behavioral and profiling data: purchasing habits, preferences, interests, segmentation by product categories, interactions with commercial communications. Data provided via chat, contact forms, or reviews.

3. PURPOSES AND LEGAL BASIS OF PROCESSING

3.1 Execution of the purchase contract

Order management, shipping, invoicing, returns and refund management, after-sales assistance, sending transactional communications (order confirmation, shipping notifications, return instructions) via Shopify Email.

Legal basis: performance of a contract to which the data subject is a party (Art. 6 par. 1 lit. b GDPR).

3.2 Fulfilment of legal obligations

Retention of tax and accounting documents, handling requests from judicial or public security authorities.

Legal basis: legal obligation (Art. 6 par. 1 lit. c GDPR).

3.3 Website navigation and technical cookies

Ensuring the correct functioning of the website, session maintenance, shopping cart, language and currency preferences.

Legal basis: legitimate interest of the Controller to ensure the functioning of the service (Art. 6 par. 1 lit. f GDPR).

3.4 Response to contact and assistance requests

Management of requests sent via contact forms, emails to info@awards-shoes.com, support@brunopremi.com, returns@brunopremi.com, live chat service (provided via Gorgias Inc.).

Legal basis: legitimate interest of the Controller to provide assistance to customers and potential customers (Art. 6 par. 1 lit. f GDPR), or performance of pre-contractual measures at the request of the data subject (Art. 6 par. 1 lit. b GDPR).

3.5 Direct marketing via email, SMS, and WhatsApp

Sending newsletters, commercial communications, promotions, discounts, event invitations, new collection launches, abandoned cart recovery via email, SMS, and WhatsApp. These activities are managed through the Klaviyo Inc. platform (based in the United States).

Legal basis: explicit consent of the data subject (Art. 6 par. 1 lit. a GDPR). The data subject can withdraw consent at any time, with effect for the future, via the unsubscribe link present in each communication, by replying "STOP" to SMS or WhatsApp messages, or by writing to info@awards-shoes.com.

3.6 Profiling and segmentation for marketing purposes

Analysis of purchasing and browsing habits to create homogeneous customer segments and send personalized commercial communications (e.g., product recommendations, targeted offers based on purchase history, differentiated communications by purchase frequency or average order value). These activities are managed through Klaviyo Inc.

Legal basis: explicit consent of the data subject (Art. 6 par. 1 lit. a GDPR). Consent to profiling is distinct from direct marketing and can be withdrawn at any time by writing to info@awards-shoes.com.

3.7 Tracking pixels in email communications

Email communications sent via Klaviyo Inc. may contain tracking pixels: invisible 1x1 pixel images that, when the message is opened by the recipient, transmit information to the sender such as IP address, device type and email client used, date and time of opening, number of openings. This data is used to measure the open rate of communications, personalize the content of subsequent emails, and support commercial profiling activities.

Klaviyo uses internal non-sequential identifiers that are not directly traceable to the recipient's email address, in accordance with privacy by design principles.

For new subscribers, at the time of newsletter subscription, consent to receive commercial communications also covers the use of tracking pixels, provided that the information notice has been previously read and accepted. Consent to tracking can be revoked independently of unsubscribing from the newsletter.

For existing subscribers, in accordance with the transitional regime provided for by Provision no. 284/2026, subscribers prior to the entry into force of the provision have been or will be informed of the use of tracking pixels with the first useful email communication. In each email, there is a "Manage tracking preferences" link in the footer, which allows you to choose, at any time, between the following options: continue to receive emails with active tracking, continue to receive emails without tracking (emails will still be delivered), or completely unsubscribe from the list.

Refusal of tracking does not in any way affect the possibility of receiving commercial communications or making purchases on the website. The choices expressed by the data subject are recorded in the Klaviyo platform for accountability purposes, pursuant to Art. 5 par. 2 GDPR.

Legal basis: explicit consent of the data subject (Art. 6 par. 1 lit. a GDPR), pursuant to Art. 122 of Legislative Decree 196/2003 as interpreted by Garante Provision no. 284 of 17 April 2026.

3.8 Collection of product reviews

In the future, the Controller may invite customers who have made a purchase to leave a review via Klaviyo Inc. Reviews may be published on the website anonymously or with only the first name.

Legal basis: legitimate interest of the Controller to collect feedback on its products (Art. 6 par. 1 lit. f GDPR), upon prior information to the data subject.

3.9 Statistical analysis and website improvement

Use of web analytics and user behavior analysis tools to understand how the website is used, identify areas for improvement, and test interface changes. The tools used are: Google Analytics 4 (Google Ireland Ltd. / Google LLC), Hotjar (Hotjar Ltd., Malta), Microsoft Clarity (Microsoft Corporation).

Legal basis: consent of the data subject expressed through the cookie banner (Art. 6 par. 1 lit. a GDPR).

3.10 Online marketing, retargeting and measurement of advertising conversions

Use of tracking pixels and advertising tags to measure the effectiveness of advertising campaigns, create custom audiences and lookalike audiences, display targeted ads on social networks and search engines (dynamic retargeting). The tools used are: Meta Pixel (Meta Platforms Ireland Ltd., for Facebook and Instagram), Google Ads Conversion Tracking (Google Ireland Ltd. / Google LLC), TikTok Pixel (TikTok Technology Ltd., Ireland / ByteDance Ltd.), Pinterest Tag (Pinterest Europe Ltd., Ireland).

Legal basis: explicit consent of the data subject expressed through the cookie banner (Art. 6 par. 1 lit. a GDPR), in accordance with the Guidelines of the Privacy Guarantor of 10 June 2021.

Regarding activities carried out via Meta Pixel, the Controller and Meta Platforms Ireland Ltd. act as joint controllers for the collection and transmission of event data, pursuant to Art. 26 GDPR. The joint controllership agreement can be consulted on Meta's website.

4. RECIPIENTS OR CATEGORIES OF DATA RECIPIENTS

The personal data of the data subject may be communicated to the following categories of recipients, who will process them as data processors (Art. 28 GDPR) or as independent controllers or joint controllers:

E-commerce platform provider: Shopify International Ltd. (Ireland) / Shopify Inc. (Canada): website hosting, order management, payment management, cookie banner.

Logistics, shipping, and returns management service providers: third parties that handle storage, preparation, shipping of orders, returns management, and logistical customer service. Only the data necessary for the performance of these activities (name, address, telephone number, email, order content) are communicated to these parties.

Payment service providers: Shopify Payments (Stripe Payments Europe Ltd.), PayPal (Europe) S.à r.l. et Cie S.C.A., Klarna Bank AB. These parties operate as independent data controllers for payment data.

Email, SMS, and WhatsApp marketing service providers: Klaviyo Inc. (United States), as data processor.

Live chat and customer care service provider: Gorgias Inc. (United States), as data processor.

Analytics and advertising tracking service providers: Google Ireland Ltd. / Google LLC (United States), Meta Platforms Ireland Ltd. (Ireland) as joint controller for Meta Pixel, TikTok Technology Ltd. (Ireland), Pinterest Europe Ltd. (Ireland), Hotjar Ltd. (Malta), Microsoft Corporation (United States, for Clarity).

Other recipients: freelancers, consulting firms or companies (accountants, legal advisors, IT consultants) within the scope of assistance relationships; competent authorities, for the fulfilment of legal obligations or at the request of public bodies.

The updated list of data processors is available by writing to info@awards-shoes.com.

5. TRANSFER OF DATA OUTSIDE THE EUROPEAN ECONOMIC AREA

Some of the recipients indicated above are based or process data outside the European Economic Area, particularly in the United States. These include: Shopify, Klaviyo, Gorgias, Google, Meta, Microsoft, as well as parties indirectly involved in TikTok and Pinterest activities.

The transfer takes place in compliance with the guarantees provided for by Articles 44 et seq. of the GDPR, in particular by: adequacy decision of the European Commission for entities adhering to the EU-U.S. Data Privacy Framework (including Google LLC, Meta Platforms Inc. and Microsoft Corporation); Standard Contractual Clauses approved by the European Commission, supplemented where necessary by additional technical and organizational measures; case-by-case verification of the guaranteed level of protection.

The data subject can request a copy of the applied guarantees by writing to info@awards-shoes.com.

6. DATA RETENTION PERIOD

Personal data are stored for the time strictly necessary to achieve the purposes for which they were collected, in compliance with the principle of minimization (Art. 5 par. 1 lit. e GDPR). In particular:

Order and invoicing data: 10 years from the order date, as required by civil and tax regulations. Customer account data: until the account is deleted by the data subject, and subsequently for 24 months for documentation purposes. Data for email, SMS, and WhatsApp marketing: until consent is withdrawn and in any case no longer than 24 months of user inactivity, after which the data will be deleted or anonymized. Email tracking pixel data: until consent to tracking is withdrawn and in any case no longer than 24 months of inactivity. Profiling data: until consent is withdrawn and in any case no longer than 24 months of inactivity. Navigation data and cookies: as indicated in the Cookie Policy. Data relating to contact and assistance requests: 12 months from the conclusion of the request, unless there are ongoing disputes. Chat logs: 12 months from the conclusion of the conversation.

At the end of the retention periods, the data will be deleted or irreversibly anonymized.

7. NATURE OF DATA PROVISION AND CONSEQUENCES OF REFUSAL

The provision of data is mandatory for the purposes referred to in points 3.1, 3.2, 3.3 and 3.4 (contract execution, legal obligations, navigation, assistance). Failure to provide such data makes it impossible to complete an order or receive assistance.

The provision of data for the purposes referred to in points 3.5, 3.6, 3.7, 3.8, 3.9 and 3.10 (marketing, profiling, email tracking pixels, analytics, retargeting) is optional. Refusal to give consent or its subsequent withdrawal does not in any way affect the possibility of purchasing on the website or receiving assistance.

8. RIGHTS OF THE DATA SUBJECT

Pursuant to Articles 15-22 of the GDPR, the data subject has the right to: access their personal data (Art. 15); rectify inaccurate data or integrate incomplete data (Art. 16); erase their data ("right to be forgotten", Art. 17); restrict processing (Art. 18); data portability in a structured, commonly used and machine-readable format (Art. 20); object to processing, in particular for direct marketing and profiling purposes (Art. 21); not be subject to decisions based solely on automated processing, including profiling, which produce legal effects or similarly significant effects (Art. 22); withdraw consent given at any time, without affecting the lawfulness of processing carried out before the withdrawal; granularly withdraw only consent to pixel tracking in emails, without this leading to unsubscription from the newsletter.

To exercise these rights, the data subject can write at any time to info@awards-shoes.com or send a written request to the registered office of the Controller. The Controller will respond within one month of receiving the request, extendable by two further months in case of particular complexity.

Complaint to the Guarantor: the data subject also has the right to lodge a complaint with the competent supervisory authority: Garante per la protezione dei dati personali, Piazza Venezia 11, 00187 Rome, website: www.garanteprivacy.it, e-mail: protocollo@gpdp.it.

9. MANAGEMENT OF EMAIL TRACKING PREFERENCES

In accordance with Garante Provision no. 284 of 17 April 2026, every commercial email sent by Bruno Premi contains a "Manage tracking preferences" link in the footer, distinct from the unsubscribe link.

By clicking on this link, the user accesses a dedicated page where they can select one of the following options: receive emails with active tracking, receive emails without tracking (communications will still be delivered regularly), or completely unsubscribe from the list.

The choices are recorded in the Klaviyo platform and take immediate effect. Refusal of tracking does not in any way limit the use of the newsletter service or the possibility of purchasing on the website.

10. COOKIE POLICY

For specific information on cookies and other tracking tools used by the website, please refer to the dedicated Cookie Policy, accessible from the website footer, and the cookie banner available upon first access. Through the banner, the user can give, deny, or modify their consent to the installation of non-technical cookies at any time.

11. CHANGES TO THIS INFORMATION NOTICE

The Controller reserves the right to modify, integrate or update this information notice as a result of regulatory changes or changes in the processing carried out. Changes will be published on this page and, where appropriate, communicated to data subjects via email or notice on the website.

Last updated date: April 29, 2026