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Privacy policy for Businesses

B2B privacy policy

Version dated 8th October 2021

 

Club House Italia S.p.A., in its capacity of data controller, hereby wishes to inform its B2B clients, dealers, retailers and other contractual counterparties of the Controller, as part of a different commercial relationship, of the processing methods of their personal data, in conformity with Italian Legislative Decree No. 196/2003 as amended and supplemented, and the European General Data Protection Regulation No. 679/2016 (hereinafter, “European Regulation“).

 

  1. Controller and data protection officer

 

Club House Italia S.p.A. (“Club House” or “Controller“), VAT no. 06271501006 with registered office in via Balzella 56, 47122 Forlì (FC), which can be contacted at the email address privacy@poltronafraugroup.com, is the data controller in relation to the processing of personal data described in this privacy policy.

 

As described in this privacy policy, the Controller will collect and process the personal data through an innovative client relationship management system, “CRM”. The data will be collected directly from the Data Subject – if the Controller’s contractual counterparty is a natural person or sole proprietorship – or from the company/entity to which the Data Subject belongs on the occasion of registering for events, to the Club House interactive digital platform or during events, shows, work meetings and in the phase of negotiation and/or conclusion and/or execution and/or termination of the contract entered into with the Controller. The data collected will be entered into the central database of Club House, which will process them – in the capacity of autonomous controller – for marketing purposes (as described below), both for activities implemented in Italy and for activities carried out abroad. The data may also be collected by the associated and/or subsidiary companies and by the retailers or commercial partners of Club House that operate in Italy and abroad and in that case they will be appointed by the Controller as data processors.

With reference, on the other hand, solely to the management of sales and after-sales activities at some of our showrooms, the companies listed at the bottom of this privacy policy will collect and process the Data in the capacity of autonomous controllers, in accordance with what is indicated in this privacy policy, insofar as it applies.

 

The Controller has appointed a data protection officer (“DPO“), who can be contacted using the details indicated in paragraph 11) of this privacy policy.

 

  1. To whom does the Privacy Policy apply?

 

This privacy policy applies to the processing, by the Controller, of personal data of:

 

  1. B2B clients, dealers, retailers and other contractual counterparties of the Controller, in the case of natural persons or sole proprietorships; and
  2. legal representatives, shareholders (natural persons), directors, attorneys, members of the board of statutory auditors, members of the supervisory body, technical managers, other natural persons vested with powers of representation and/or management and/or control, as well as the employees and contract staff of B2B clients, dealers, retailers and other contractual counterparties;

 

(hereinafter jointly referred to as the “Data Subjects“).

 

  1. Which Data are processed?

 

The Controller collects the personal data relating to the Data Subject directly from the latter – if the Controller’s contractual counterparty is a natural person or sole proprietorship – or from the company/entity to which the data subject belongs for registration to the event in which the Data Subject intends to participate, for registration to the Club House interactive digital platform or during events, shows, work meetings and in the phase of negotiation and/or conclusion and/or execution and/or termination of the contract entered into with the Controller. Furthermore, the Controller may collect the personal data relating to the Data Subject from lists, registers and other publicly accessible sources – such as, for example, data contained in the chamber of commerce company report of the company to which the Data Subject belongs – as well as databases of organisations that provide information on the commercial reliability of entrepreneurs and managers.

 

Depending on the purposes and the time of collection, the Controller processes the following types of personal data relating to the Data Subject:

 

  1. personal details, contact data, identity document and role covered at the company/entity to which the Data Subject belongs;
  2. company name, address of the main office and any secondary offices, VAT number and/or tax code, details bank account or accounts of the Data Subject, if the latter is a natural person or sole proprietorship;
  3. data relating to the Data Subject’s economic-financial reliability – in the case of a sole proprietorship or single-member company – collected using databases of organisations that provide information on the commercial reliability of entrepreneurs and managers and that have adhered to the Code of Conduct for personal data processing in relation to commercial information approved by the Italian Data Protection Supervisory Authority. For further information, including with regard to the categories of data collected using those databases, the Data Subject may consult the privacy policy of the organisations that provide the information in question, which may be viewed on the website www.informativaprivacyancic.it;
  4. other personal data relating to the Data Subject that may be collected by the Controller during the phase of negotiation and/or conclusion and/or execution and/or termination of the contract entered into with the Controller;

 

(hereinafter, jointly, the “Data“).

 

The Data Subjects are advised not to provide to the Controller Data that are not necessary to pursue the purposes indicated in this Privacy Policy.

 

  1. For what purposes are the Data processed?

 

The Controller processes the Data of Data Subjects to:

 

  1. carry out negotiations and perform the contract of which the Data Subject is a party during an online purchase or at the showroom, for registration to one of the events organised by the Controller or for registration to the interactive digital platform of the Controller (hereafter “Contractual Purposes“);
  2. comply with obligations deriving from applicable legislation, therein including tax legislation (hereafter “Legal Purposes“); and
  3. if the Controller’s contractual counterparty is a company, pursue the legitimate interest of the Controller in holding negotiations and performing the contract of which the company/entity to which the Data Subject belongs is a party;
  4. pursue the legitimate interest of the Controller in verifying the commercial and financial security and reliability of its B2B clients, dealers, retailers and other contractual counterparties, to prevent fraud, to guarantee management solidity and the correct execution of commercial relationships between the Controller and its B2B clients, dealers, retailers and other contractual counterparties;
  5. exercise and defend its rights, also as part of credit recovery procedures, in relation to the Data Subject or third parties in any dispute;
  6. carry out activities functional to sales of businesses and business branches, acquisitions, mergers, demergers or other transformations and for performing those operations;
  7. send to potential professional purchasers of the Controller’s products and services communications of commercial nature on collections, exhibitions and events relating to the Controller. We will send these communications periodically, indicatively no more than twice a month or on the occasion of particular initiatives (e.g., Salone del Mobile Furniture Fair) by email to the addresses of the Data Subject indicated each time within the contractual relationship between the Controller and the company/entity to which the Data Subject belongs;
  8. communicate to other companies of the group to which the Controller belongs the contact information of potential professional purchasers of the products and services of the companies of the Controller’s group so that the same can send commercial information on collections, exhibitions and events, even by way of newsletters, in relation to their products and services (the group companies are: Poltrona Frau, Cappellini, Cassina, Ceccotti, Club House, DZine, Karakter, Janus et Cie, Luminaire, Luxury Living Group. The updated list of group companies can be requested to the Controller by sending an email to the address indicated in paragraph 11) below. The group companies will send these communications periodically, indicatively no more than once a month or on the occasion of particular initiatives (e.g., Salone del Mobile Furniture Fair) by email to the addresses of the Data Subject indicated each time within the contractual relationship between the Controller and the company/entity to which the Data Subject belongs. Furthermore, in order to limit those communications to what is strictly necessary, the Data Subject will receive emails only subject to evaluating the commercial opportunity by the group company that has registered the contact. This evaluation will be based upon two criteria:
    • the type of clientele to which the Data Subject belongs (therefore, for example, promotional communications will not be sent to suppliers of Club House, which, by virtue of the commercial relationship in place or for which negotiations are in progress with the latter, are considered unlikely to be interested in purchasing products or participating in events of the Controller, while they will always be sent to potential professional purchasers of the products or services of the companies of the group to which the Controller belongs, so that they are made aware of all commercial opportunities with the Group companies); and
    • the sector of activity of the Data Subject (for example, if the Data Subject’s activity does not involve outdoor furniture, communications relating to Janus et Cie will not be sent).

In this way, communications are not sent indiscriminately and in a potentially inappropriate manner, but rather considering the immediate benefit for both the Data Subjects (which receive all and only the communications they are potentially interested in) and for the Controller. Each Data Subject will in any case be free to request directly from each group company the transmission of promotional material; in that case the evaluation of the company with which he/she originally had contact will not be necessary;

 

(the purposes indicated in letters c) to h) are known jointly as the “Legitimate Interest Purposes“).

 

  1. On what basis are the Data processed?

 

The processing of Data is necessary with reference to the Contractual Purposes and the Legal Purposes referred to in paragraph 4, letter a) and b), in order to allow you to participate in the event, to register to the platform, to negotiate, enter into, perform and/or terminate the contract between the Controller and the Data Subject, as well as to adhere to the provisions of applicable legislation. Any failure to provide the Data for those purposes will make it impossible for the Controller to allow you to participate in the event, to register to the platform or to perform the aforementioned contract.

 

The processing of Data for the Legitimate Interest Purposes is carried out in accordance with Article 6, letter f) of the European Regulation to pursue the legitimate interest of the Controller, which is equally balanced with the legitimate interest of the Data Subjects, as the activity of Personal Data processing is (i) limited to what is strictly necessary to perform the economic operations and other activities specified in letters c) to f) above and is (ii) functional to maintaining commercial relationships with professional clientele for the activities specified in points g) and h). Processing for the Legitimate Interest Purposes is not mandatory and the Data Subject may object immediately or subsequently to each processing activity using the methods stated in paragraph 11) of this Privacy Policy; however, if the Data Subject objects to such processing, his/her data may not be used for the Legitimate Interest Purposes. By way of example, for the activities specified under points g) and h), the Data Subject may object to both the communication of his/her contact details to other Group companies but also in general to receiving any promotional communication from the Controller, without this prejudicing in any way the contractual relationship with the Controller.

 

  1. How are the Data processed?

 

In relation to the purposes indicated above, the Data will be processed both using IT or automated tools and on paper, and they will be protected by way of appropriate measures to guarantee the confidentiality and security of the personal data. In particular, the Controller adopts appropriate organisational and technical measures to protect the Data in its possession against loss, theft, as well as unauthorised use, disclosure or modification of the Data.

 

  1. To whom are the Data communicated?

 

For the purposes stated in paragraph 4, the Controller may communicate – in whole or in part – the Data of the Data Subjects to the following categories of entities:

 

  1. employees of the Controller or of the entities indicated below, as persons in charge of the processing, as part of their respective duties and within the limits established by law;
  2. providers of services instrumental to or in support of those performed by the Controller and therefore, by way of example but without limitation, legal, administrative and tax consultants, banking institutions for the management of receipts and payments deriving from the execution of the contract between the Controller and the Data Subject or the company/entity to which he/she belongs, auditing companies, events management companies, companies instructed to send marketing newsletters, providers of technological services, in the capacity of autonomous data controllers or processors;
  3. end customers which may request the name or contact of the Data Subject in order to receive the services provided by the latter or by the company/entity to which the Data Subject belongs;
  4. sub-suppliers and/or subcontractors engaged in activities connected to the performance of the contract between the Controller and the Data Subject or the company/entity to which he/she belongs, in the capacity of external processors;
  5. other companies belonging to the group of which the Controller is part, situated in Italy and abroad, as data controllers for their own marketing purposes;
  6. retailers or commercial partners of the Controller or companies of the group to which the Controller belongs which perform services on behalf of the Controller, including the collection of data to be entered in the client relationship management system “CRM”. Those entities will act in the capacity of processors;
  7. public entities and/or judicial and/or control authorities whose right of access to the data of the Data Subject is envisaged by applicable legislation, in the capacity of autonomous data controllers; and
  8. transferees of businesses or business branches, companies resulting from mergers, demergers or other transformations of the Controller, as autonomous controllers.

 

Some of the entities listed above may be situated in countries outside the European Union or the European Economic Area. More specifically, the Data entered in the CRM database, whose servers are located in the territory of the European Union, will be shared with entities that may, however, be located both inside and outside the EEA, as the Controller offers its products and services to customers and commercial partners in all countries in which it is present.

In that case, the Data will be communicated in accordance with the following paragraph.

 

  1. Are the Data transferred abroad?

 

In compliance with applicable norms, the Data may be transferred abroad, even to countries not belonging to the European Economic Area and, in particular, to countries in which the companies of the group to which the Controller belongs are based, as well as showrooms and authorised retailers of products and services of the Controller which will have access to them via the CRM system; a full list of those entities is available on the website of the Controller, while the full list of group companies can be requested from the Controller by sending an email to the address stated in paragraph 11) below. Any transfer of Data to countries located outside the European Economic Area will occur, in any case, in respect of the appropriate and adequate guarantees for the purposes of that transfer, in accordance with Articles 44 et seq. of the European Regulation.

 

In any case, the Data Subject will be made aware of any transfer of Data outside the European Economic Area, through the update of this privacy policy, using the methods described in the paragraphs below.

 

  1. For how long are the Data stored?

 

The Data will be stored by the Controller:

 

  1. For registration to the event, for registration to the interactive digital platform or in the case of a positive outcome of the contractual negotiations, for a period equal to the duration of the contract entered into between the Controller and the Data Subject, or the company/entity to which he/she belongs, and for 10 years after its termination;
  2. in the case of a negative outcome of the contractual negotiations, the Data will be erased at the end of the negotiation phase;

 

except, in any case, where the further storage of Data is necessary in order to exercise or defend a claim of the Controller in relation to the Data Subject or third parties in any dispute.

 

With reference to Data processed for the purposes of sending commercial communications, the Controller will process the data of the Data Subject until the right to object is exercised and, in any case, for no more than 2 years from the end of the contractual relationship between the Controller and the company/entity to which the Data Subject belongs.

 

At the end of the storage period, the data will be erased, anonymised or aggregated.

 

 

  1. What are the rights of the Data Subjects?

 

Without prejudice to the possibility for the Data Subject not to provide his/her Data, the Data Subject may, at any time and free of charge:

 

  1. obtain confirmation of the existence or otherwise of Data concerning him/her;
  2. ask to be informed about the origin of the Data, the purposes of processing and its methods, as well as the logic applied to processing carried out using electronic tools;
  3. request the update, rectification or – if appropriate – supplementation of Data relating to him/her;
  4. obtain the erasure, transformation into anonymous form or blocking of Data potentially processed in violation of the law, as well as object, for legitimate reasons, to the processing;
  5. withdraw consent, where previously provided;
  6. ask the Controller to restrict the processing of the Data relating to him/her if (i) the Data Subject disputes the accuracy of the Data, for the period necessary for the Controller to verify the accuracy of those Data; (ii) the processing is unlawful and the Data Subject objects to the erasure of the Data and instead requests that their use be limited; (iii) although the Controller no longer needs them for the purposes of processing, the Data are required by the Data Subject for establishing, exercising or defending a claim judicially or extra-judicially; (iv) the Data Subject has objected to the processing in accordance with Article 21, paragraph 1 of the European Regulation pending verification with regard to any prevalence of the legitimate reasons of the Controller over those of the Data Subject;
  7. object at any time to the processing of his/her Data for Legitimate Interest Purposes;
  8. request the erasure of the Data concerning him/her without undue delay; and
  9. obtain the portability of the Data concerning him/her.

 

The Data Subject will also have the right to lodge a complaint with the Italian Data Protection Authority at the contact details indicated on the website www.garanteprivacy.it, where the conditions apply.

Requests to exercise the rights may be sent in writing to the Controller, which can be contacted at the following email address privacy@poltronafraugroup.com.

 

  1. DPO

 

The Controller has appointed a DPO who is responsible for compliance by the Controller with the fulfilments required by personal data protection legislation.

 

The Data Subject may contact the DPO securely and confidentially, at any time, if he/she has general questions on the processing of his/her personal data, or for any issue relating to data protection. The Data Protection Officer’s email address is: dpo.poltronafrau@dpoprofessionalservice.it.

 

  1. Amendments and updates

 

This Privacy Policy is valid from the effective date. The Controller may, however, make changes and/or additions to this privacy policy, including as a result of any subsequent regulatory changes and/or additions.

 

 

 

AUTONOMOUS CONTROLLERS FOR MANAGEMENT OF SALES AT THE SHOWROOMS
ITALYCompany Name: LUXURY LIVING GROUP s.r.l.

VAT no.: 10046911003

with registered office at: Via Balzella 56 – 47122 Forlì – Italy

E-mail: luxurygroupsrl@open.legalmail.it – info@luxurylivinggroup.com

ITALYCompany Name: LUXURY LIVING s.r.l.

VAT no.: 03341380404

With registered office at: via Durini 23 – 20122 Milan – Italy

E-mail: milano@luxurylivinggroup.com

FRANCECompany Name: LUXURY LIVING FRANCE S.a.r.l.

VAT no.: FR03507471308

With registered office at: Avenue George V – 75008 Paris – France

E-mail: paris@luxurylivinggroup.com

UNITED KINGDOMCompany Name: LUXURY LIVING CONTRACT & PROJECTS LIMITED

VAT no.:  191828479

With registered office at: Lynton House 7-12 Tavistock Square – WC1H 9BQ London – United Kingdom

E-mail: london@luxurylivinggroup.com

USACompany Name: LUXURY LIVING OF USA, LLC

VAT no.: 75-3253309

With registered office at: 50 N.E. 39 Street – Miami – FL 33137

E-mail: miami@luxurylivingusa.com

USACompany Name: LUXURY LIVING OF LOS ANGELES, LLC

VAT no.: 47-4131139

With registered office at: 8833 Beverly Boulevard – West Hollywood – CA 90048

E-mail: losangeles@luxurylivingusa.com

USACompany Name: LUXURY LIVING OF NEW YORK, LLC

VAT no.: 46-1178507

With registered office at: 153 Madison Avenue – New York 10016

E-mail: newyork@luxurylivingusa.com

 

 

Privacy policy for Consumers

PRIVACY POLICY in accordance with Article 13 of the General Data Protection Regulation (EU) 679/2016 (“GDPR”)

 

This Privacy Policy is valid from the date of publication (latest update: January 21, 2022). The Controller may make changes and/or additions to this Privacy Policy, including as a result of any subsequent regulatory changes and/or additions.

 

DATA CONTROLLER

 

Club House Italia S.p.A. (“Club House” or “Controller”), VAT no. 06271501006 with registered office in via Balzella 56, 47122 Forlì (FC), E-mail privacy@poltronafraugroup.com.

 

As described in this privacy policy, we collect and process your Personal Data through an innovative customer relationship management system “CRM”. The Data may be collected directly from you when you visit one of our showrooms located in the various countries of the world, during our events or when you browse on our website. The Data collected will be entered into our central database and we will process them, in the capacity of autonomous controller, for marketing and profiling purposes, both for activities implemented in Italy and for activities carried out abroad. The Data may also be collected by our associated and/or subsidiary companies and by our retailers or commercial partners that operate in Italy and abroad and in that case they will be designated by us as processors.

 

With reference, on the other hand, solely to the management of sales and after-sales activities at some of our showrooms, the companies listed below will collect and process the Data in the capacity of autonomous controllers, in accordance with what is indicated in this privacy policy (point 1.A and 1.D).

 

DATA PROTECTION OFFICER

 

The Controller has appointed a Data Protection Officer (“DPO”), who can be contacted at the following address: dpo.poltronafrau@dpoprofessionalservice.it.

 

DATA COLLECTION SOURCE

 

The personal data (the “Personal Data” or the “Data”) are automatically collected or provided through browsing or use of this website (the “Website”) or on the occasion of your visit to one of our showrooms (the “Showroom”), even for the purchase of one of our products (the “Products”).

 

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1.A – DATA PROCESSING CARRIED OUT FOR THE MANAGEMENT OF SALES AT THE SHOWROOMS

 

DATA CATEGORIES PERSONAL AND CONTACT DATA name, surname, tax code, e-mail, address, telephone number, billing address, passport details for the Tax Free/Refund service – PURCHASE DATA type and price of Products purchased

 

PROCESSING PURPOSE – To carry out the sale of Products at our Showrooms and to manage after-sales services (for example, returns, refunds, repairs, etc.).

 

MANDATORY OR OPTIONAL PROVISION OF DATA – Necessary. If you do not wish to provide your Data, the Controller will not be able proceed with the corresponding order or to manage the related Product after-sales services.

 

LEGAL BASIS OF PROCESSING – The need to perform a contract or to take steps prior to entering into a contract to which you are party, as well as the need to comply with legal obligations.

 

DATA STORAGE PERIOD: The Controller undertakes to erase your Data from its systems provided for the execution of the sale and management of the after-sales services 10 years after the date of the last purchase or from the last interaction with the Controller.

 

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1.B – DATA PROCESSING CARRIED OUT ON THE WEBSITE

 

 

CATEGORIES OF DATA – PERSONAL AND CONTACT DATA name, surname, email, phone number, country, region, city. Personal data communicated in the specific text form on the Website or to the mailbox of the Controller.

 

PURPOSE OF PROCESSING – To manage contact requests made via the specific Website page (“contacts”) or by email to the Controller

 

MANDATORY OR OPTIONAL PROVISION OF DATA – Necessary. If you do not provide these Data, it will not be possible for the Controller to process the requests sent.

 

LEGAL BASIS OF PROCESSING – The need to perform a contract or to take steps prior to entering into a contract to which you are party, as well as the need to comply with legal obligations.

 

DATA STORAGE PERIOD – The Controller undertakes to erase your Data from its systems provided in relation to requests submitted via the Website or by email 1 year after the date of provision.

 

 

***

 

APPLICATIONS – If you would like to submit to the Controller, via the Website, your application for a job with the Controller or one of the companies of the group to which the Controller belongs, your Data will be processed in accordance with the respective privacy policy, available at the following link: https://careers.poltronafrau.com/

 

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1.C – DATA PROCESSING CARRIED OUT BY MEANS OF THE CUSTOMER RELATIONSHIP MANAGEMENT SYSTEM “CRM”

 

1) REGISTRATION AS A CUSTOMER

 

CATEGORIES OF DATA – PERSONAL AND CONTACT DATA name, surname, date of birth, email, address, telephone number

 

PURPOSE OF PROCESSING – To allow you to register as a customer and to use the respective services (for example to participate to one of our events). You may make this registration to our Website, at one of our showrooms or during one of our events.

 

MANDATORY OR OPTIONAL PROVISION OF DATA – Necessary. If you do not wish to provide your Data, you will not be able to register as a customer or to use the related services.

 

LEGAL BASIS OF PROCESSING – The need to perform a contract or to take steps prior to entering into a contract to which you are party, as well as the need to comply with legal obligations.

 

DATA STORAGE PERIOD – The Controller undertakes to erase your Data from its systems provided for your registration 10 years after the date of cancellation of the relevant registration.

 

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2) MARKETING

 

CATEGORIES OF DATA – PERSONAL AND CONTACT DATA name, surname, email, address, telephone number

 

PURPOSE OF PROCESSING – To send you marketing information about collections, exhibitions, and events, including through our newsletter, or allow you to participate in any customer satisfaction surveys and market research to improve the Products. These communications will be sent by email or telephone, including by automated means (SMS, social media messaging systems). We will carry out communications by automated means approximately no more than 2 times a month or on the occasion of particular initiatives (eg Salone del Mobile). You can also choose to be contacted exclusively via traditional methods, expressing your opposition to receiving communications through automated methods, by writing to privacy@poltronafraugroup.com.

 

MANDATORY OR OPTIONAL PROVISION OF DATA – Optional. If you do not wish to provide your Data, the Controller will be unable to keep you constantly updated on the special offers and promotions for its customers, or use the Data for market research, and statistical and customer satisfaction analyses.

 

LEGAL BASIS OF PROCESSING – Your explicit consent to the processing of Data for this purpose. If you have given your consent, you can withdraw it at any time by clicking on the unsubscribe button contained in the emails or newsletters received or sending an email to privacy@poltronafraugroup.com.

 

DATA STORAGE PERIOD – The Controller will erase the Data processed in order to send you marketing information, including customised information following classification or profiling based on the parameters described above, about collections, exhibitions, and events, as well as for the participation in customer satisfaction surveys and market research, 10 years after the collection of the Data, or until you object. To that end, the Controller has taken into consideration the type of goods offered for which it considers an average frequency of purchase by customers of one or a maximum two products per capita every 6-7 years. Therefore, shorter timescales for data analysis would prevent the offer of customised services. In any case, the Data will be stored for 10 years for the purposes of sales management and after-sales services.

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3) COMMUNICATE DATA TO OTHER COMPANIES OF THE GROUP FOR MARKETING PURPOSES

 

CATEGORIES OF DATA – PERSONAL AND CONTACT DATA name, surname, email, address, telephone number

 

PURPOSE OF PROCESSING – To communicate your Data to other companies of the Group to which the Controller belongs, so that they can send you marketing information about collections, exhibitions, and events, including through newsletters in relation to its products and services, and to participate in any customer satisfaction surveys and market research to improve the Products.

 

MANDATORY OR OPTIONAL PROVISION OF DATA – Optional. If you do not wish to provide your Data, the Controller will not be able to communicate the Data to the other group companies for such purposes.

 

LEGAL BASIS OF PROCESSING – Your explicit consent to the processing of Data for this purpose. If you have given your consent, you can withdraw it at any time by clicking on the unsubscribe button contained in the emails or newsletters you receive or by writing to privacy@poltronafraugroup.com.

 

DATA STORAGE PERIOD – The Controller will erase the Data processed in order to send you marketing information, including customised information following classification or profiling based on the parameters described above, about collections, exhibitions, and events, as well as for the participation in customer satisfaction surveys and market research, 10 years after the collection of the Data, or until you object. To that end, the Controller has taken into consideration the type of goods offered for which it considers an average frequency of purchase by customers of one or a maximum two products per capita every 6-7 years. Therefore, shorter timescales for data analysis would prevent the offer of customised services. In any case, the Data will be stored for 10 years for the purposes of sales management and after-sales services.

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4) CLASSIFICATION OF CUSTOMERS

 

CATEGORIES OF DATA – PERSONAL AND CONTACT DATA name, surname, age bracket, email, telephone number, country of residence – Product purchase channel (e.g., web, showroom)

 

PURPOSE OF PROCESSING – Classification of customers based upon a series of parameters, for the purposes of sending targeted commercial communications relating to the requirements of a certain category or bracket of which you form part (e.g., customers aged from 50 to 70 years old, residents of a specific regionetc.).

 

MANDATORY OR OPTIONAL PROVISION OF DATA – Optional. If you wish to object to the processing of your Data, it will not be possible for the Controller to keep you constantly updated on offers and promotions dedicated to certain categories of customers. If you have given your consent to receive promotional information in any case, you may therefore only receive generic newsletters.

 

LEGAL BASIS OF PROCESSING – The legitimate interest of the Controller in achieving the maximum efficiency of its marketing activities. We will send promotional communications taking account of your bracket or category only with your prior consent, which may be withdrawn at any time and without prejudice. You can exercise your right to object to the receipt of these communications at any time, immediately or at a later date, by clicking the unsubscribe button contained in the emails or newsletters you receive or by writing to privacy@poltronafraugroup.com.

 

DATA STORAGE PERIOD – The Controller will erase the Data processed in order to send you marketing information, including customised information following classification or profiling based on the parameters described above, about collections, exhibitions, and events, as well as for the participation in customer satisfaction surveys and market research, 10 years after the collection of the Data, or until you object. To that end, the Controller has taken into consideration the type of goods offered for which it considers an average frequency of purchase by customers of one or a maximum two products per capita every 6-7 years. Therefore, shorter timescales for data analysis would prevent the offer of customised services. In any case, the Data will be stored for 10 years for the purposes of sales management and after-sales services.

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5) PROFILING OF CUSTOMERS

 

CATEGORIES OF DATA – PERSONAL AND CONTACT DATA name, surname, date of birth, age bracket, email, telephone number, country of residence – OTHER DATA profession, frequency and Product purchase channels (e.g., web, showroom), products viewed, catalogues requested, interests and data relating to your behaviour on our Website.

 

PURPOSE OF PROCESSING – Profiling of customers to assess your preferences, interests, characteristics, and consumption habits based upon a series of parameters, for the purposes of sending customised promotional communication or for a personalised purchasing experience in our Showrooms.

 

MANDATORY OR OPTIONAL PROVISION OF DATA – Optional. If you do not wish to provide your Data, it will not be possible for the Controller to keep you constantly updated on offers and targeted promotions with respect to your preferences, interests, characteristics, and consumption habits or to offer you a personalised purchase experience at our Showrooms. If you have given your consent to receive promotional information in any case, you may therefore only receive generic newsletters.

 

LEGAL BASIS OF PROCESSING – Your explicit consent to the processing of Data for this purpose. If you have provided consent, you may withdraw it at any time by writing to privacy@poltronafraugroup.com.

 

DATA STORAGE PERIOD – The Controller will erase the Data processed in order to send you marketing information, including customised information, following classification or profiling based on the parameters described above, about collections, exhibitions, and events, as well as for the participation in customer satisfaction surveys and market research, 10 years after the collection of the Data, or until you object. To that end, the Controller has taken into consideration the type of goods offered for which it considers an average frequency of purchase by customers of one or a maximum two products per capita every 6-7 years. Therefore, shorter timescales for data analysis would prevent the offer of customised services. In any case, the Data will be stored for 10 years for the purposes of sales management and after-sales services.

 

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1.D – DATA PROCESSING CARRIED OUT FOR MARKETING PURPOSES FOLLOWING A SALE AT THE SHOWROOM OR ON THE WEBSITE

 

CATEGORIES OF DATA – PERSONAL AND CONTACT DATA name, surname, e-mail – PURCHASE DATA type of Products purchased

 

PURPOSE OF PROCESSING – The sending of communications containing marketing offers related to Products similar to those already purchased (soft spam).

 

MANDATORY OR OPTIONAL PROVISION OF DATA – Optional. If you wish to object to the processing of your Data, it will not be possible for the Controller to keep you constantly updated on offers and promotions of products related to those already purchased.

 

LEGAL BASIS OF PROCESSING – The Controller’s legitimate interest in developing relationships with its customers and increasing the volume of requests and sales of the Products. You can exercise your right to object to the receipt of these communications at any time, immediately or at a later date, by clicking the unsubscribe button contained in the emails or newsletters you receive or by writing to privacy@poltronafraugroup.com.

 

DATA STORAGE PERIOD – The Controller will erase the Data processed for the purposes of sending communications containing marketing offers related to Products similar to those already purchased (soft spam), 24 months after the date of each purchase, unless any objection is made before that period elapses and without prejudice to their storage for 10 years for the purposes of executing the sale and for the management of after-sales services.

 

2 – DATA PROCESSING METHODS AND ANY FURTHER STORAGE OF DATA

 

The Data will be collected and processed in compliance with the principles of fairness, lawfulness, and transparency, through manual or automated methods, always within the limits of the processing purposes described above and, in any case, in order to ensure the security and confidentiality of the Data. With respect to the storage of the data, the Controller has indicated the respective timescales in correspondence with each processing activity and it undertakes, in any case, to base the Data processing on principles of adequacy and minimisation, checking annually the need to store the Data for a period of time not exceeding what is necessary for the achievement of the purposes for which they were collected and processed. The Controller may store the Data to fulfil regulatory obligations, or to establish, exercise or defend a legal claim. Upon achieving the purposes for which the Data were collected and processed, the Controller will take the appropriate measures to make the Data anonymous, so as to prevent your identification, notwithstanding its right to continue using the Data anonymously for statistical purposes.

 

3 – ANY AUTOMATED DECISION-MAKING PROCESSES

 

As indicated above, the Controller carries out, based upon its legitimate interest, a classification of its customers for the purpose of sending information of a commercial nature on collections, exhibitions and events targeted relative to the needs of a certain category or bracket of which you form part. That process is carried out by breaking down the data subjects into non-invasive and non-discriminatory categories, such as country of residence (residents in the Lombardy region when, for example, identifying a category of data subjects interested in the opening of a new store in Milan), age bracket (e.g. customers aged from 50 to 70 if, for example, the product is aimed statistically at this age bracket), and purchase channels of Products (e.g. differentiating communications sent to mainly web customers from those who prefer physical stores). Following this analysis, which may also be carried out in automated form, the user may be classified into one or more groups with different characteristics and may receive from the Controller communications dedicated to that category which the Controller believes are in line with its requirements. In relation to this processing, the Controller has successfully conducted a balancing test in order to determine that the processing linked to the classification in question is carried out on the legal basis of the legitimate interest of the Controller in achieving maximum efficiency in its marketing activities.  The Controller may also, with your consent, analyse your consumer habits over time, to assess in more depth what may be possible with a simple categorisation, such as products or initiatives responding to your tastes and preferences (for example, if, during a timeframe of 2 years, you demonstrate interest in one of our particular products or the line created by one of our designers, we will send you offers dedicated to that type of product and not others in which you are not interested or that do not meet your tastes and preferences). In this way we will be able to offer you a unique and customised purchasing experience even if you come to see us at one of our showrooms. In that case, our sales assistant will be able to recognise you and direct you in the most efficient manner to the product that you prefer. Of course, you can always ask our sales staff to show you different proposals. It is noted that the Controller has carried out a specific impact assessment of the personal data processing necessary for the profiling activities to guarantee respect of the principles of the GDPR, including non-discrimination, effectiveness, and absence of harmful consequences for the data subject.

 

 

4 – PERSONS AUTHORISED TO PROCESS THE DATA

 

The Data may be processed by persons appointed by the Controller who have been expressly authorised and have received adequate operating instructions in relation to the processing purposes set out above.

 

 

 

5 – POSSIBLE DATA RECIPIENTS

 

The Data will not be disseminated. The following entities may become aware of the Data in relation to the processing purposes outlined above and may process them, independently, as separate Data Controllers or as Data Processors duly appointed by the Controller (the list of those entities can be requested from the Controller by writing to privacy@poltronafraugroup.com):

  • Retailers or commercial partners of the Controller or Companies of the group to which the Controller belongs which, on our behalf, will collect the Data to be inserted in our customer relationship management system “CRM”; those entities will act as processors. We remind you that if you want to be registered as a customer or consent to the processing of your personal data for marketing and/or profiling purposes, your Data will be entered into this CRM database, the servers of which are located in the European Union. In that case, the Controller will share your Data with these entities which may, however, be situated both inside and outside your country of residence and both inside and outside the EEA, as the Controller offers its products to customers in all countries in which it is present. In particular, your Data will automatically be accessible to the sales managers and/or representatives at our showrooms for marketing and profiling purposes. For example: if you visit a showroom in a country other than your country of residence, the personal information will also be accessible by that showroom, so as to offer you products most in line with your requirements. Of course, appropriate organisational and security measures will be taken for the sharing and transfer of the data, as indicated below in point 6. For further information on the entities and countries involved, please send a request to the following email address: privacy@poltronafraugroup.com
  • Companies of the group of which the Controller is part to which we will communicate your Data for sending marketing information on collections, exhibitions, and events, by the aforementioned companies, in relation to their products and services; those entities will act as autonomous Data controllers and they will receive the same only where you have provided consent to the communication of Data.
  • Companies of the group to which the Controller belongs for administrative and accounting purposes; those entities will act in the capacity of processors.
  • Entities that may access the Data by virtue of EU law or the law of the Member State to which the Controller is subject; those entities will act in the capacity of autonomous controllers.
  • Companies that carry out and provide additional services related to the processing purposes, banking operators, electronic payment carriers, credit card issuers, internet providers, couriers and shipping agents, companies that manage events or carry out newsletter mailing or market research activities, companies that offer data analysis services, companies that offer IT infrastructures and IT support and consulting services, legal or accountancy firms, and auditors; those entities will act in the capacity of processors or in some cases autonomous controllers;
  • Purchasers or successors of the Controller in cases of merger, transfer, restructuring, reorganisation, dissolution or other sale or transfer of some or all of the assets of the Controller, in which the Data may be transferred; those entities will act as autonomous controllers and we will only communicate to them the Data necessary for the assessment of the operation based upon our legitimate interests.

 

6 – TRANSFER OF PERSONAL DATA ABROAD

 

All Data processing is carried out in countries of the European Union.

If the Data need to be transferred to a Third Country, for example, to manage relationships with customers that have interests in countries other than the European Union, the Controller undertakes to:

  • Ensure that the country to which the Data will be sent guarantees an adequate level of protection, as provided under Article 45 of the GDPR; or
  • Comply with the standard contractual clauses for Data protection approved by the European Commission as to the transfer of personal Data outside the EEA in accordance with Article 46.2 of the GDPR.

 

7 – YOUR RIGHTS IN THE CAPACITY OF DATA SUBJECT – COMPLAINT TO A SUPERVISORY AUTHORITY

 

In relation to the above Data processing, you can exercise at any time, by sending an email to privacy@poltronafraugroup.com, the following rights under the conditions and within the limits indicated in Articles 12 and 13 of the GDPR:

  • Right of access (Art. 15 GDPR).
  • Right of rectification of inaccurate data and completion of incomplete data (Art. 16 GDPR).
  • Right to erasure of Data (Art. 17 GDPR).
  • Right to restriction of processing (Art. 18 GDPR).
  • Right to object to processing carried out in accordance with Art. 6, paragraph 1, letters e) or f) GDPR.

You also have the right to lodge a complaint with the Supervisory Authority, i.e., the Italian Data Protection Authority (known as (“Privacy Guarantor”) and/or other competent supervisory authorities (Art. 77 GDPR).

Moreover, if the processing is based on consent or a contract and is carried out by automated means, you have the right to receive your Data in a structured, commonly used, and machine-readable format and, if technically feasible, to transmit those Data to another Data Controller without hindrance under Article 20 of the GDPR.

You also have the right to object at any time to the processing of the Data, immediately or after the transfer of the Data, in relation to the sending by the Controller of unsolicited communications containing marketing offers related to Products similar to those already purchased (soft spam) directly to the email address provided during the purchase of Products, pursuant to Art. 130, paragraph 4 of Italian Legislative Decree no. 196/2003, as amended by Italian Legislative Decree no. 101/2018.

You can also choose to be contacted for marketing purposes exclusively via traditional methods, expressing your opposition to receiving communications through automated methods.

You have the right to withdraw the consent provided for marketing and/or profiling purposes at any time.

 

 

 

8 – MINORS

 

The Website and the Products are in no way intended for minors under the age of 18; therefore, the Controller does not carry out any collection and/or processing of personal data relating to such minors. In the event that personal data relating to minors are entered on the Website, the Controller will erase them.

 

 

AUTONOMOUS DATA CONTROLLERS FOR SHOWROOMS SALES
ITALYCompany name: LUXURY LIVING GROUP s.r.l.

VAT no: 10046911003

With registered office in: Via Balzella 56 – 47122 Forlì – Italy

E-mail: luxurygroupsrl@open.legalmail.it – info@luxurylivinggroup.com

ITALYCompany name: LUXURY LIVING s.r.l.

VAT no: 03341380404

With registered office in: via Durini 23 – 20122 Milan – Italy

E-mail: milano@luxurylivinggroup.com  

FRANCECompany name: LUXURY LIVING FRANCE S.a.r.l.

VAT no: FR03507471308

With registered office in: 18 Avenue George V – 75008 Paris – France

E-mail: paris@luxurylivinggroup.com

UNITED KINGDOMCompany name: LUXURY LIVING CONTRACT & PROJECTS LIMITED

VAT no: 191828479

With registered office in: Lynton House 7-12 Tavistock Square – WC1H 9BQ London – United Kingdom

E-mail: london@luxurylivinggroup.com

USACompany name: LUXURY LIVING OF USA, LLC

VAT no: 75-3253309

With registered office in: 50 N.E. 39 Street – Miami – FL 33137

E-mail: miami@luxurylivingusa.com

USACompany name: LUXURY LIVING OF LOS ANGELES, LLC

VAT no: 47-4131139

With registered office in: 8833 Beverly Boulevard – West Hollywood – CA 90048

E-mail: losangeles@luxurylivingusa.com

USACompany name: LUXURY LIVING OF NEW YORK, LLC

VAT no: 46-1178507

With registered office in: 153 Madison Avenue – New York 10016

E-mail: newyork@luxurylivingusa.com

CHINACompany name: LUXURY LIVING CHINA (BEIJING) TRADING CO., LTD

VAT no: 911101050918530837

With registered office in: Unit 2103 of No. 2 office building of China Central Place No. 79, Jian Guo Road, Chao Yang District – 100022 Beijing – China

E-mail: china@luxurylivinggroup.com

CHINACompany name: LUXURY LIVING CHINA (BEIJING) TRADING CO., LTD – SHANGHAI BRANCH

VAT no: 91310000MA1FYGPU6Q

With registered office in: Room 504-59S No. 1376 West NanJing Road, JingAn District – 2000040 Shanghai – RPCChao Yang District – 100022 Beijing – China

E-mail: china@luxurylivinggroup.com

HONG KONGCompany name: LUXURY LIVING HONG KONG TRADING CO. LIMITED

VAT no: 69604516-000

With registered office in: Unit 305-7, 3/F., Laford Centre, 838 – Lai Chi Kok Road – Cheung Sha Wan – Kowloon – Hong Kong Chao Yang District – 100022 Beijing – China

E-mail: hongkong@luxurylivinggroup.com