Version 1.0 of 19.01.2016
1. Data processing purposes
User’s personal data will be processed for the following processing purposes:
(i) allow the User to register on the Website and/or purchase online the products that are sold by the Company through the Website according to the sales conditions of the Company;
(ii) comply with the applicable law, including tax regulation;
(iii) administrative and accounting purposes;
(iv) exercise or defense of a legal claims, should the User violate the Company’s sale conditions or any applicable law.
Providing the personal data for the above-mentioned processing purposes is optional but necessary, since failure to provide such data will imply the impossibility for the User to register on the Website or shop online through the latter. The personal data noted with an asterisk * in the registration form on the Website are necessary. Any other data may be freely provided by the User.
The creation of an account on the Website is optional, as it is possible to shop online without creating a personal account. Should the User create a personal account on the Website, its personal data will be stored in order for him/her to easily and quickly purchases again through the Website.
2. Other processing purposes: marketing (sending advertising material, direct sale and commercial communication)
Subject to the User's optional consent, which can be given by selecting the relevant check-box on the registration form on the Website, some of the User's personal data (name, last name, ordinary mail address, email, telephone/mobile number) can be processed by the Company for marketing purposes (e.g. sending advertising material, direct sale, market research and commercial communication). Should the User provide his/her consent, the Company may contact the User by ordinary mail, email, SMS / MMS, telephone/mobile - either with or without operator - and WhatsApp in order to propose the purchase of products or services, offered by the Company itself or by third parties, submit offers, promotions or commercial opportunities or propose the User to participated to questionnaires, studies or market researches. By selecting the relevant checkbox, the User provides his/her consent for the above mentioned marketing purposes through the said means. The User's consent to the processing of his/her personal data for marketing purposes is optional and, failing to provide such consent, the possibility for the User to register on the Website and shop online through latter will not be jeopardized. Also in case where the User has given his/her consent, the User may opt-out at any time from receiving further promotional communications (also in relation to promotional communications made by ordinary mail, telephone/mobile, either with or without operator), by contacting the Company as indicated in paragraph 7 below. Moreover, the User can opt-out also in a selective manner, by way of example by opting out from receiving e-mail marketing communications but continuing to receive promotional communications via ordinary mail or by the other contact means, or vice versa. With reference to promotional communications sent via email, the User may easily object to the processing and decide not to receive any further communication via email, by clicking on the relevant link which will appear in each of those promotion emails.
3. Other processing purposes: profiling
Subject to the User's optional consent, which can be given by selecting the relevant check-box on the registration form of the Website, the User's personal data (i.e. both the personal data and contact details) may be processed by the Company also for profiling purposes, that is to infer the User's preferences and consumer habits, in order to send him/her commercial offers which are consistent with the identified consumer’s profile. The User's consent to the processing of his/her personal data for profiling purposes is optional and, failing to provide such data and the relevant consent, the possibility for the User to register on Website and shop online through the latter will not be jeopardized. Also in case where the User has given his/her consent, the User may opt-out at any time from the profiling of his/her, by contacting the Company as indicated in paragraph 7 below. The consent to the processing of personal data for profiling purposes is extended also to the detailed purchases made by the User on the Website or in the Frette stores; however, data relating to the details of the purchased goods will be stored by the Company for profiling purposes for a maximum of a 12-month period and, for marketing purposes, for a maximum of a 24-months period.
4. Processing methods
User's personal data is processed with electronic and non-electronic means, duly taking into account the relevant processing purposes, and in any case by ensuring the security and the confidentiality of the data.
5. Persons who may have access to the data
Company’s employees or collaborators entitled to manage the Website, provide customer care services, manage online purchases and, according to the potential optional consents expressed by the User, send promotional communications or perform profiling activities may have access to the User’s personal data. Such individuals, who have been formally appointed by the Company as persons in charge of the processing, will process the Users' personal data exclusively for the purposes indicated in this policy and in accordance with the provisions of the Privacy Code.
Furthermore, third parties appointed by the Company as external data processors, such as IT and logistic service providers for the operation of the Website, outsourcing and cloud computing service providers, professionals and advisors, marketing companies sending marketing communication, which process the Users' personal data on behalf of the Company, may have access to the Users' personal data. One of the data processor appointed by the Company is Mas Factory, with registered office in Via Copenhagen 26-28 – 20831 Seregno (MB), who manages and optimizes the database of the Company. Some of the data processors appointed by the Company are established in countries outside the European Economic Area and, therefore, in compliance with the relevant privacy provisions, Users’ personal data may be transferred to countries which do not offer the same level of protection as the one provided for under the Italian and European privacy law. In order to protect the rights of the Users, the Company and such data processor have entered into the model clauses approved by the European Commission with decision 2010/87/EU. Users have the right to obtain copies of the model clauses as well as a list of the data processor appointed by the Company by contacting the Company as indicated in paragraph 7 below.
6. Data communication and dissemination
User’s personal data will not be communicated to autonomous and independent third party data controllers and will not be disseminated in any manner whatsoever.
7. User’s rights
Pursuant to Section 7 of the Italian Privacy Code, the Company hereby informs the Users that they have the right be informed (i) of the source of the personal data; (ii) of the purposes and methods of the processing; (iii) of the logic applied to the processing, if the latter is carried out with the help of electronic means; (iv) of the identification data concerning data controller and data processors; (v) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may have access to said data in their capacity as data processor(s) or person(s) in charge of the processing. Furthermore, Users have the right to obtain a) updating, rectification or, where they have an implied interest, integration of the data; b) deletion, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected. Users have the right to object, in whole or in part, a) on legitimate grounds, to the processing of their personal data, even though they are relevant to the purpose of the collection; b) to the processing of their personal data, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys. The above-mentioned rights can be exercised by contacting the Company by (i) registered mail to: Frette s.r.l., Foro Buonaparte 51 – 20121 Milano (Italy), (ii) by email at firstname.lastname@example.org or (iii) fax to the number +39 039 6046365.