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Policy on the processing of personal data pursuant to Articles 13 and 14 of EU Regulation 679/2016 ("GDPR") and Italian Legislative Decree 196/2003 as amended ("Privacy Code").

Poltronesofà S.p.A. ("Data Controller" or "poltronesofà") processes the personal data belonging to the user ("User") and/or the purchaser of a poltronesofà product ("Customer") who (i) navigates on the website www.poltronesofa.com ("Website"), (ii) sends requests from the Website by means of contact forms, (iii) registers in the Customer Area of the Website.

With this policy, in its capacity as Data Controller of the aforementioned processing operations, poltronesofà informs the User and the Customer of the purposes and methods of the same in full compliance with the applicable regulation.

1. DATA CONTROLLER

The Data Controller is Poltronesofà S.p.A. with registered office in Via Lunga 16, 40053 Valsamoggia, Crespellano (BO) ITALY and administrative office in Via Raffaele Bendandi 14, 47122 Villanova di Forlì (FC) ITALY.

poltronesofà has appointed a data protection officer ("Data Protection Officer” or "DPO”). The Data Protection Officer can be contacted at [email protected] for any information on data processing.

2. TYPE OF DATA PROCESSED AND COLLECTION METHOD

The types of data processed by the Data Controller and the manner in which they are collected are as follows:

2.1. Data provided directly by the User and/or the Customer

The User and/or the Customer may benefit from the specific functionalities made available on the Website and set out below.

2.1.1. “Contacts” Section

In the “Contacts” section, there are various forms where the User and/or the Customer will be asked to provide some personal data, including but without being limited to name, surname and email address.

Such data is necessary in order to respond to specific requests from the User and/or the Customer, which, depending on the contact form selected, may relate to:

- Information on delivery, maintenance and care of the products purchased and/or, in general, information on the purchase made at the point of sale;

- Information on current promotions at the points of sale;

- Suggestions for improving the Website;

- Report on commercial properties for rent or sale.

2.1.2. “Customer Area” Section

When registering to the Customer Area, the User or the Customer will be asked to provide some personal data, including but without being limited to first name, last name, email address and mobile phone number, in order to generate the credentials for subsequent access to the Customer Area.

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Filling in the fields in the forms referred to in sections 2.1.1. and 2.1.2 above is optional. However, failure to fill in the fields marked with an asterisk (*) prevents the Data Controller from complying with the relevant request.

2.2. Navigation data

The computer systems and software procedures used to operate the Website acquire, in the course of their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.

Such information is not collected in order to be associated with identified individuals but, by its very nature, it could make it possible to identify users.

This category of data includes the IP addresses or domain names of the computers used by users who connect to the Website, the URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error) and other parameters relating to the user's operating system and computer environment.

Such data is used for the sole purpose of obtaining anonymous statistical information on the use of the Website and to check its correct operation, and is deleted immediately after processing.

2.3. User and/or Customer location data

In “Our Stores” section through the "detect location" function and subject to the express authorisation given by the User and/or the Customer, the Website processes data relating to their location in order to provide the service of finding the nearest stores on the map.

2.4. Cookies

Cookies collect information including data that can potentially identify a data subject. For data processing via cookies, please see the relevant policy, available at the following link.

3. PURPOSE AND LEGAL BASIS OF DATA PROCESSING - RETENTION PERIOD

The processing of personal data by the Data Controller for the purposes set out below is carried out by means of computerised tools with logics strictly related to these purposes and, in any case, in such a way as to guarantee data security and confidentiality in compliance with the law.

3.1. To reply to requests received by the Data Controller by filling in the forms in the “Contacts” section of the Website.

The legal basis for this processing is the performance of contractual obligations and the requests made by the data subject.

The retention period of such data is equal to the time required to process the request. This retention period may be longer if the data subject undergoes another specific processing.

3.2. To enable the Customer registered in the Customer Area to take advantage of the services available on the Website relating to the product purchased at poltronesofà's points of sale.

In particular, the Customer will be able to download the warranty for the product purchased, view the purchases already made, and follow the order cycle (e.g. follow the delivery process of orders being processed, or request information and assistance).

The legal basis for this processing is the performance of a contract to which the data subject is one of the parties.

The retention period for such data is 10 years from delivery of the product purchased.

3.3. For marketing and profiling purposes: Subject to the consent given by the User and/or the Customer, poltronesofà may send promotions, commercial communications or advertising on its products, services and events, also based on the profiling of the User and/or the Customer through the creation of group and/or individual profiles for personalised communications in line with the interests of the same, using the data processed to collect information relating to the preferences, habits, lifestyles of the User and/or the Customer, as well as details of the purchases made.

Marketing activities may also include the performance of market research and surveys to detect User and/or Customer satisfaction, or to carry out statistical analyses, also with anonymous data organised in aggregate form.

For sending newsletters, marketing communications and/or personalised offers, poltronesofà may use channels such as emails, operator telephone calls, SMS, MMS, chat, instant messaging, social networks and traditional mail, including sending invitations to organised events.

The legal basis for this processing is the consent of the data subject. At any time, the User and/or the Customer may revoke their consent by means of the "unsubscribe" or "disiscriviti" button at the bottom of the communications received, or by means of a request to the Data Controller.

The retention period of such data is until the User's and/or Customer's consent is revoked.

3.4. Soft Opt-in: poltronesofà may send by email promotions, commercial communications or advertising relating to offers on products and services similar to those purchased by the Customer, unless the latter refuses to receive such communications at any time.

The legal basis for this processing, which does not require the Customer's consent, is Article 130, paragraph 4 of the Italian Privacy Code, provided that it concerns communications on products or services similar to those purchased by the Customer and that the latter, after being adequately informed, does not refuse the use of his/her email address for this purpose, either initially or on the occasion of subsequent communications received.

As a general rule, the retention period of such data is until the Customer's consent is revoked.

3.5. To detect the location of the User and/or the Customer, with their consent, in order to indicate the nearest poltronesofà’s points of sale on the map.

The legal basis for this processing is the consent of the data subject. As a general rule, the retention period of such data is until the User's and/or the Customer's consent is revoked. The User and/or the Customer may deactivate the geolocation option at any time, even temporarily, via the browser settings or the settings of the device he/she uses.

3.6. To prevent or prosecute offences or infringements of rights (including those of third parties) or computer crimes or offences committed via telematic networks.

The legal basis for this processing is the legitimate interest of poltronesofà as data controller. The data retention period is equal to the time reasonably necessary to enforce poltronesofà's rights from the moment the latter becomes aware of the offence or its potential commission.

4. DATA SUBJECT’S RIGHTS

The User and the Customer may contact poltronesofà (at the above addresses or by sending an email to [email protected]) to exercise their rights under Articles 15 et subseq. of the GDPR, including in particular: (i) requesting access to their personal data, (ii) knowing the existence of their data, (iii) requesting its rectification, (iv) its deletion, (v) objecting to its processing, (vi) requesting the portability of their data, as well as (vii) requesting its restriction in the cases provided for by Article 18 of the GDPR.

In any event, the User and the Customer may lodge a complaint with the Personal Data Protection Authority if they consider that a breach of rights has occurred or is occurring with regard to the processing of their personal data.

5. DATA SHARING AND RECIPIENTS

Users’ and/or Customers’ personal data may be shared by the Data Controller, for the purposes set out in paragraph 3 above, with the third parties listed below.

5.1. Other companies belonging to poltronesofà group.

5.2. Persons who may become aware of the data in their capacity as "Data Processors": The User's and/or Customer's personal data may be communicated to third parties, to whom the Data Controller entrusts certain services and activities, who act as Data Processors in accordance with agreements pursuant to Article 28 of the GDPR. These parties only come into possession of the personal data necessary for the performance of their duties and may only use such data for the purpose of performing these services on behalf of poltronesofà or to comply with legal requirements. The up-to-date list of third-party providers, acting as data controllers within the meaning of Article 28 of the GDPR, can be obtained after sending a request to [email protected].

5.3. Judicial authorities and administrative bodies: Where permitted or required by law, poltronesofà may share data requested by a judicial authority, administrative body or government agency in order to protect or exercise the rights of poltronesofà or third parties, or to comply with legal obligations.

6. PLACE OF DATA PROCESSING - TRANSFER OF DATA

The User's and Customer's personal data are processed by poltronesofà in Italy.

The aforementioned personal data may also be processed in other countries of the European Union by poltronesofà’s providers to whom data are transmitted as data processors pursuant to the provisions of Article 28 of the GDPR, as well as by suppliers located outside the European Economic Area.

poltronesofà ensures in all cases that the processing of the User's and/or Customer's personal data by these providers is carried out in compliance with the GDPR.

7. AMENDMENTS TO THE POLICY

This policy may be amended from time to time to reflect changes in laws, technology, changes in data collection and use, or to allow poltronesofà to add new features to the Website. In the event of substantial amendments, which may have a significant impact on Users and/or Customers, the Data Controller shall notify the User and the Customer and take any action it deems appropriate. The User and the Customer are invited to consult the Website on a regular basis to check for updates. Any amendments made shall take effect from the time of their publication. Browsing and using the Website functionalities after that time shall be deemed as a full acceptance of those amendments.

Last updated 14/07/2023