Privacy & Cookie Policy

Foreword

Pursuant to and in compliance with current legislation on the protection of personal data and in particular pursuant to Article 13 of Law No. 171 of December 21, 2018, headed "Protection of individuals with regard to the processing of personal data" (hereinafter "Law" for brevity) and pursuant to Art. 13 of EU Regulation 2016/679 (hereinafter "GDPR" for brevity), the Central Bank of the Republic of San Marino, as data controller (hereinafter "CBSM" or "Data Controller" for brevity), provides you with the following information regarding the processing of your personal data (hereinafter "Personal Data"). Personal Data means any information relating to an identified or identifiable natural person; an identifiable person is any natural person who can be identified, directly or indirectly, with particular reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more characteristic elements of his or her physical, physiological, genetic, mental, economic, cultural, or social identity.
This Privacy Policy (hereinafter "Policy") relates to the processing carried out by CBSM with respect to Personal Data of users of the Website https://www.bcsm.sm/. Certain types of personal data must be provided by users only when using certain services provided by this website, through access to a special restricted area.

 

Identity and contact details of the data controller

The Data Controller has appointed a "Data Protection Officer" ("DPO") pursuant to Chapter IV of the Act (hereinafter referred to as "DPO" or "DPO" for short). For all matters relating to the processing of your Personal Data and/or to exercise your rights under the Law itself, listed in the "Data Subject Rights" section of this Notice, you may contact the DPO at privacy.dpo@bcsm.sm.

 

Identity and contact details of the Data Protection Officer

The Data Controller has appointed "Data Protection Officer" pursuant to Chapter IV of the Law (hereinafter referred to as "DPO" or "DPO" for short), Lawyer Valentina Rabitti and Dr. Nathaniel Casadei. For all matters relating to the processing of your Personal Data and/or to exercise your rights under the Law itself, listed in the "Rights of the Data Subject" section of this Notice, you may contact the DPOs at the email address privacy.dpo@bcsm.sm.

 

Place of processing

Processing related to the web services of this site takes place in the country where the site is hosted, which, in this case, is Germany. Consequently, all the rules and protections of the EU Regulation 2016/679 (GDPR) apply. No data from the web service is disclosed or disseminated.

Further information can be found at the following addresses:

1 ) https://legal.hubspot.com/hubspot-regional-data-hosting-policy;

2) https://legal.hubspot.com/dpa.

 

Type and source of personal data being processed

Browsing data

The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected in order to be associated with identified interested parties, necessary for browsing the Internet, but which, by its very nature, could allow users to be identified through processing and associations with data held by third parties. In particular, it is intended to refer to:
(a) IP addresses or domain names of computers used by users connecting to this site,
b) addresses in URI (Uniform Resource Identifier) notation of the requested resources,
(c) time of the request,
(d) method used in submitting the request to the server,
(e) size of the file obtained in response,
(f) numeric code indicating the status of the response given by the server (successful, error, etc.),
(g) other parameters related to the user's operating system and computer environment.
These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct functioning, and are deleted immediately after processing. The data could be used for possible liability in the event of computer crimes related to this site: subject to this possibility, at present the data on web contacts do not persist for more than seven days.
For more information, you can visit the page Data collected by the HubSpot tracking code

 

Data voluntarily provided by the user

To access certain services reserved for users, it is necessary to register and enter certain specific types of personal data. The provision of such identifying data is necessary in order to authenticate and verify the legitimacy of access in restricted areas, to the individuals who access them.
The optional, explicit and voluntary sending of electronic mail to the addresses indicated on this site involves the acquisition of the sender's address, which is necessary for responses, as well as any other personal data contained in the message. These data are processed to respond to the messages sent and to process any related requests. Failure to provide personal data for communications with CBSM or to send any requests prevents their processing.

Cookies

Cookies are short strings of code that visited sites send to the user's browser (i.e., browsing program such as, for example, Firefox or Chrome) where they are stored for later retransmission to the same sites during subsequent visits. Contextually, the user may also receive on his or her browser Cookies that are sent from other sites (so-called "third parties").
For information about cookies that are enabled or can be enabled on CBSM's website, you can visit https://knowledge.hubspot.com/privacy-and-consent/what-cookies-does-hubspot-set-in-a-visitor-s-browser

How to manage Cookies within your browser
You can manage your preferences regarding Cookies directly within your browser and prevent - for example - third parties from installing them. Through your browser preferences, you can delete previously installed Cookies. Should the user disable all Cookies the operation of this site may be impaired.

 

Third Party Websites
This site contains links to other Web sites (e.g., San Marino Rtv and Linkedln) that have their own privacy policies; these sites may install Cookies upon reaching them but are external to CBSM. These privacy policies may differ from the one adopted by the Owner, who is therefore not liable for third-party sites. Please read carefully the privacy policies of external platforms linked through CBSM's site before using them.
In case a social network interaction service is installed, it is possible that, even if Users do not use the service, it collects traffic data related to the pages where it is installed. To know what personal data is collected, where it is processed and all the details, Users are invited to consult the privacy policies of the social networks involved, always identifiable by specific logo or wording in the pages of the site.

 

Purpose and legal basis of the processing

Your Personal Data will be processed for the following purposes:
To carry out the operations strictly necessary in order to proceed with the provision of the services that you may have requested, even implicitly (such as your navigation between the pages of the site). The acquisition of data necessary for the provision of services explicitly requested by you takes place exclusively in the restricted area of the site. The site has a purely informative function and nowhere else on it, apart from the restricted areas, is the acquisition of your Personal Data required (with the exception of the cookies indicated in the previous paragraph, which may indirectly identify you);
provide members with the institutional services rendered by the Central Bank, as well as the management of the restricted area of the Site, etc.; and
carry out the activities imposed by laws, regulations or measures and acquire any information flows required by them;
provide registered users with personalized information in the restricted area.
As for the processing carried out for the purposes mentioned in the above list, these have as their legal basis - with regard to points a., b. and d. - Article 5, paragraph 1, letter b) of Law no.171/2018 and subsequent amendments, connected with the need to execute your express requests to receive a service directly available through the site; with regard to point c. above, the legal basis is to be found in Article 5, paragraph 1, letters c) and e) of Law no.171/2018 and subsequent amendments, connected with the public services that CBSM provides.

 

Modalities of processing

Your Personal Data may be processed in the following ways:

• by means of electronic processors using software systems operated by Third Parties;

• temporary processing in Anonymous Form.

All processing is carried out in accordance with the methods set out in Articles 5 (Lawfulness of Processing) and 33 (Security of Processing) of the Law and, in particular, the data of visitors/users are processed lawfully and correctly, taking appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of data. Information about the site's security protocols can be found at this link https://www.hubspot.com/reliability.
In this sense, on the basis of the roles and work duties performed, the workers have been legitimized to process Personal Data, within the limits of their competence and in accordance with the instructions given to them by the Data Controller.
In addition, any communication of Personal Data to External Data Processors, professionals, consulting firms, etc., will take place through the stipulation of an appropriate contract of appointment to ensure compliance with the principles of the Law and regulations as they come into force. CBSM is available to provide, at any time, upon request, the list of subjects to whom it communicates Personal Data and the limits of their use.
CBSM does not adopt any automated decision-making process, including profiling as referred to in Article 22 of the Law.

 

Retention period

We inform you that, in compliance with the principles of lawfulness, purpose limitation and minimization of Personal Data, in accordance with Article 5 of the Law, the retention period of your Personal Data is established for a period of time not exceeding the performance of the services provided and the achievement of the purposes for which they are collected and processed, in compliance with the mandatory time limits prescribed by law.

 

Transfer of data abroad

The Data Controller does not transfer Personal Data collected through the website to third countries or to international organizations.

 

Rights of the data subject

The interested party may at any time exercise against CBSM the rights provided for by the Law listed below, which are recognized by the regulations on the protection of Personal Data, by sending an appropriate request in writing to Banca Centrale della Repubblica di San Marino S.p.A. according to one of the following methods:
- registered letter addressed to Banca Centrale della Repubblica di San Marino, Via del Voltone n. 120 - 47890 San Marino (RSM);
- by sending an e-mail to the e-mail address: privacy.titolare@bcsm.sm; or
- by fax to + 378 0549 981019.

 

Right of access

You may obtain from CBSM confirmation as to whether or not any processing of your Personal Data is taking place and, if so, obtain access to your personal data and to the information provided for in Article 15 of the Law by obtaining evidence, by way of example, of the purposes pursued by the Data Controller, the categories of data involved, the recipients to whom the data may be transmitted, the applicable retention period and the existence of automated decision-making processes.

 

Right of rectification

You may obtain from CBSM, without delay, the rectification of your Personal Data that are inaccurate as well as, taking into account the purposes of the processing, the integration of the same, if they are incomplete, by providing a supplementary statement.

 

Right to erasure

You may request from the Data Controller the deletion of your Personal Data if any of the reasons set forth in Article 17 of the Law exist, including, without limitation, if the Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed or if the consent on which the processing of your Personal Data is based has been revoked by you and there is no other legal basis for the processing. It is understood that withdrawal of consent will not affect the lawfulness of the processing carried out up to that point. We inform you that CBSM will not be able to proceed to the deletion of your Personal Data: if their processing is necessary, for example, for the fulfillment of a legal obligation, for reasons of public interest, for the establishment, exercise or defense of a right in court.

 

Right to limitation of processing

You may obtain the limitation of the processing of your Personal Data if one of the cases provided for in Article 18 of the Law occurs, including, for example: in the face of your dispute as to the accuracy of your Personal Data being processed or if your Personal Data is necessary for the establishment, exercise or defense of a right in court, although CBSM no longer needs it for the purposes of processing.

 

Right to object

You may object at any time to the processing of your Personal Data if the processing is carried out for the performance of an activity in the public interest or in pursuit of a legitimate interest of the Data Controller (including profiling activities), within the limits set out in Article 21 of the Law. Should you decide to exercise the right of objection described herein, CBSM will refrain from further processing your personal data unless there are compelling legitimate grounds for processing that override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of a legal claim.

 

Right to lodge a complaint with the Data Protection Authority

Without prejudice to your right of recourse in any other administrative or jurisdictional forum, if you believe that the processing of your Personal Data by the Data Controller occurs in violation of the Law and/or applicable regulations, you may lodge a complaint with the competent Data Protection Authority.