Informativa sulla privacy
Privacy policy
Franklin S.r.l. a company incorporated in Italy having its registered office at VIA COSTA DEL BUSO 1, NEGRAR DI VALPOLICELLA (VR), Italy, and holding VAT no. BNCMRA63L10L781U (“F&M”), in its capacity as data controller informs you of the following regarding the processing of your personal data (“data”) under the applicable privacy laws (“Privacy Laws”).
The terms “we”, “us” and “our” used in this Policy refer to F&M.
Personal information we collect
When you visit the Site, we collect certain essential information required for the Site to function. Subject to your prior explicit consent (managed via our Cookie Banner), we may also automatically collect additional information about your device, including information about your web browser, IP address, time zone, and non-essential cookies (such as analytics or marketing cookies). Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.
We collect Device Information using the following technologies:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.
Additionally, when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number. We refer to this information as “Order Information”.
When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.
How do we use your personal information?
We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:
- Communicate with you;
- Screen our orders for potential risk or fraud; and
- When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
We process your Order Information based on Contractual Necessity (Article 6(1)(b) GDPR) to fulfill our contract with you. We process your Device Information and marketing data based on your explicit Consent (Article 6(1)(a) GDPR) or our Legitimate Interests (Article 6(1)(f) GDPR) to prevent fraud and optimize our Site.
Categories of subjects to whom data may be communicated
The Personal Information is accessible to us and to our duly authorised staff. The Personal Information is also shared with our service providers, for example for technical and organisational services functional to the purposes indicated above, including in associated form, shipping, marketing and payment management companies, who act as our Data Processors on the basis of our instructions.
The Personal Information are communicated to third parties in the following cases: (i) when disclosure is required by applicable laws and regulations with respect to legitimate third parties receiving communications, such as public authorities and bodies, who act as independent data controllers for their respective institutional purposes; (ii) communication to third parties (such as current or proposed assignees, transferees, participants or sub-participants in rights or our business), independent data controllers, in case of extraordinary operations (e.g. mergers, acquisitions, company transfers, etc.). The data are not disseminated, except in the case of particular initiatives (e.g. online) in respect of which we will provide you with specific information at the time.
Personal data may be transferred to recipients located outside the EEA, including affiliated entities in Hong Kong, for corporate administration, IT support, and operational management. If and where such transfer is made to a country that has not been recognised by the European Commission as providing an adequate level of protection, the Seller will implement an appropriate transfer mechanism permitted under Chapter V of the GDPR, such as Standard Contractual Clauses together with any supplementary measures required.
A list of third-country recipients and the safeguards used (e.g. Standard Contractual Clauses + supplementary measures) is available upon request.
Behavioural advertising
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by using the links below:
- Facebook: https://www.facebook.com/settings/?tab=ads
- Google: https://www.google.com/settings/ads/anonymous
- Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
Do not track
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
Your rights
You may contact us at any time, to exercise your rights under applicable Privacy Laws (such as: obtain confirmation of the existence or not of your data, access the data, verify the content, origin, correctness, ask for amendments, updates, rectification, cancellation, anonymization, ask for data portability, restriction of processing) through the contact information below. You may at any time lodge a complaint with the competent authority pursuant to art. 77 GDPR.
Additionally, if you are a European resident, we note that we are processing your information in order to fulfil contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above.
Data retention
We will retain your Order Information for the period necessary to fulfill the purposes outlined in this policy, and generally for a period of 10 years to comply with applicable Italian tax, accounting, and legal requirements, after which it will be securely deleted or anonymized.
Changes
We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.
Contact us
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e‑mail at info@franklinandmarshall.com or by mail using the details provided below:
Franklin S.r.l. VIA COSTA DEL BUSO 1, NEGRAR DI VALPOLICELLA (VR), Italy