PRIVACY POLICY

 Frette S.r.l. hereby provides you with the following privacy policy pursuant to Sections 13 and 14 of Regulation (EU) 2016/679 (hereinafter, the “Regulation” or “Reg.”).

1. Data Controller. The Data Controller is Frette s.r.l., a sole shareholder company, REA MI-1761936, Fiscal Code and VAT number. 04630610964, with office in Via Borgazzi, 23, 20900 Monza (MB) (hereinafter, “Frette”).

2. Personal data collected. - (for Frette website’s users) (A) Browsing Data: the IT systems and software procedures, that have been set up to operate www.frette.com website, collect personal data as part of their ordinary functioning; the transmission of such data is an inherent feature of Internet communication protocols. Such information is not collected in order to relate it to identified data subjects; however, in consideration of its nature, such information might allow the identification of the users, through processing and matching with data held by third parties. This category of data includes IP addresses and/or the domain names of the computers used by the users connecting with Website, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of such requests, the method used for submitting a given request to the server, returned file size, a numerical code relating to server response status (successfully performed, error, etc.), and other parameters related to the user's operating system and computer environment. These data are only used to obtain anonymous statistical information on the use of the website as well as to check its correct functioning; (B) name, surname and contact details filled in the contact forms on the Frette website; - (for Frette stores’s customers) name, surname, address, nationality, contact numbers, email, date of birth; - (for both, Frette store’s customers and web users) personal data sent by post/ e-mail / fax sent on a voluntary basis or communicated during a phone conversation.

3. Data processing purposes. The personal data which you may provide will be processed for the following purposes: (i) for the performance of a contract to which you are a part or in order to take steps at your request prior to entering into a contract (Section 6, par. 1, point b) of Reg.): we will process your personal data to allow you to make purchases and in order to take steps at your request prior to entering into a contract; during or after a purchase, it may be necessary to collect your personal data in order to provide service communications or to satisfy your special needs. Providing your personal data for the above-mentioned processing purposes is optional; however, failure to provide such data will imply the impossibility for Frette to send you service communications or to satisfy your special needs. You can freely select the preferred ways to be contacted; (ii) to speed up your future purchases, by registering you in our IT systems (Section 6, par. 1, point a) of Reg.): subject to your optional consent, you may freely choose whether ask Frette to register your personal data in Frette IT systems in order to record your data (including any invoicing details communicated verbally) and speed up your future purchases. Providing such a consent is optional; should you not consent to the recording of the data in our IT systems, the possibility to make purchases in Frette stores will not be jeopardized. You can give your consent by selecting the appropriate check-box in the footnote (if you buy at Frette stores) or by creating your account (if you buy at Frette website); (iii) for compliance with a legal obligation (Section 6, par. 1, point c) of Reg.): if you make purchases and you request the relevant invoice or if you exercise the legal warranty, we will process your personal data to comply with legal obligations in the field of taxation and consumers protection; (iv) for our legitimate interest (art.6, co.1, lett.f) del Reg.): (for Frette website’s users) (a) in order to pursue our legitimate interest to know how the Website is used by visitors and the relevant traffic, we emit, even through third parties, statistical data and aggregate data related to the number of pages viewed on our Website, number of visitors and, more in general, the ways the Website is used, without revealing your identity. To emit such statistical and aggregate data, our providers use the so-called cookies (please, note the following paragraph 14); (b) to ensure the website security, to control its functioning and to get statistic outcomes of its use; (c) in order to assess liability in case any computer crime is committed against the website or to comply with the requests of the judicial authority; (for both, Frette website’s users and Frette store’s customers)(d) to exercise or defend our right in judicial or in out-of-court procedures, including in case of breach of the Terms of Use or the Terms of Sale of the Website or in case of violation of the law. With your optional consent, we may process your personal data also for marketing and/or profiling purposes. In relation to said processing, please read paragraphs 4 and 5 which follow.

4. Will you process my data also for marketing purposes? Subject to your optional consent (Section 6, par. 1, point a) of Reg), which can be given selecting the appropriate check-box of this contact form, some of your personal data (e.g. name, surname, ordinary mail address, email, telephone/mobile number and other information provided during your visit in our store) can be processed by Frette for marketing purposes (e.g. sending advertising material, direct sale, market research and commercial communication). Should you consent to the processing, Frette may contact you by ordinary mail, email, SMS / MMS, telephone/mobile with operator and WhatsApp in order to propose you the purchase of products or services, offered by Frette itself or by third parties, submit offers, promotions and commercial opportunities or propose you to participate to questionnaires or market researches. By selecting the checkbox relating to the marketing purposes, you are giving your consent to be contacted by Frette for the abovementioned marketing purposes through all the said means, including by email, ordinary mail and telephone/mobile with operator. Your consent to the processing of your personal data for marketing purposes is completely optional and failure to provide such consent does not imply any consequences whatsoever on the possibility to make purchases at Frette. Even when you have given your consent, you may opt-out at any time by contacting Frette as indicated in the following paragraph 13. Moreover, you can opt-out also in a selective manner, by way of example, by opting out from receiving marketing communications through only one or few of the means indicated. With reference to promotional communications sent via e-mail, you may easily revoke your consent to processing of your e-mail address for marketing purposes, by clicking on the relevant link (opt-out) which will appear in each of those promotion emails.

5. Will you process my data also for profiling purposes? Subject to your optional consent (Section 6, par. 1, point a) of Reg.), which may be given selecting the appropriate check-box, your personal data (i.e. the personal data, contact details and information related to the products purchased in Frette stores or website) may be processed by Frette also for profiling purposes, that is to infer your preferences and consumer habits, identifying your customer profile, in order to send you commercial offers which are consistent with your profile. Your consent to the processing of your personal data for profiling purposes is completely optional and, failure to provide such consent does not imply any consequences whatsoever on the possibility to make purchases in Frette stores/website. Even when you have given your consent, you may opt-out at any time, by contacting Frette as indicated in paragraph 13.

6. Data communication to third parties and dissemination. Upon the request of a judicial authority or police, we may have to communicate the data of our clients. In such case, we may have to communicate your data also to the lawyers and to the legal law firms, when it is necessary to pursue our legitimate interest to exercise or defend judicial claims. Furthermore, your data may be communicated to banks, payment institutions and other intermediaries, to the extent it is required in order to receive a payment from you or to make a payment in your favor. If required under the law, your personal data related to a purchase made may be communicated to the Tax authority. Your data will not be disseminated.

7. Who may have access to my personal data? Frette employees and collaborators, involved in customer care or in marketing and profiling activities, may have access to your personal data. Furthermore, the following persons, providing us ancillary services as data processor, may have access to your personal data: IT and logistic service providers, outsourcing and cloud computing service providers, analytics services providers; professionals and advisors, other companies of our group providing services, marketing companies or shipping companies.

8. Is it mandatory or optional to provide personal data? The provision of your personal data is always optional; however, should you not provide your personal data, we may not be able to satisfy your needs, if any, or provide to you what you have requested. For purchases with invoice issuance, the provision of your personal data is necessary in order to comply with legal obligations under tax regulation.

9. Storage of personal data. In case of invoicing, your data related to the purchase made will be stored for 10 years, as provided for by the applicable tax regulation. If you have given your consent to processing of your personal data for marketing or profiling purposes, your personal data will be processed for 5 years from your consent, unless you revoke before your consent for marketing purposes in relation to all or any of the means of contact and unless the storage of your personal data is still required for other purposes described in this form.

10. Transfer of your personal data outside the European Economic Area (“EEA”). Some of our providers may be established in the US, that is a country which is not part to the EEA, or in turn entrust the processing of your personal data to sub-contractors based in such country. Data shall be transferred to such countries or, if necessary for the service to be carried out, other non-EEA countries in accordance with appropriate guarantees as specified by the Regulation.

11. Your rights. You are entitled at any moment, for free and without formalities, to exercise the rights pursuant to Sections from 15 to 22 of the Regulation: the right to access to the personal data, the rectification, the cancellation, the restriction to the processing and the right to data portability. Furthermore, you have the right to revoke your consent to processing at any moment. The revocation of consent does not affect the legality of processing based on consent until revocation. We remind you that you are always entitled to file a complaint with the Italian privacy authority (www.garanteprivacy.it) or with the different authority in the EU State where you live or work.

12. Right to object to processing under Regulation. You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on Section 6, paragraphs 1, points e) (performance of a task carried out in the public interest or in the exercise of official authority vested in the controller) or f) (legitimate interest) of Reg., including profiling based on those provisions. Where your personal data are processed for direct marketing purposes, you have the right at any time to object to processing of your personal data for such marketing, which includes profiling to the extent it is related to such direct marketing.

13. How to contact us. To exercise your rights, as above indicated, you may contact Frette S.r.l., to the attention of the Legal Department, by submitting a communication: (i) with registered letter, with return receipt, at Frette Srl, Via Borgazzi 23, Monza, 20900, (ii) by e-mail to customerservice@frette.com or (iii) by fax to the number +39 039 6046365.

14. Cookie policy. We invite the website’s users to read the cookie policy published on www.frette.com.