When you are visiting our website www.franzi1864.com (the “Website”), when you are purchasing online products, when you are using our social media or through any other forms of interaction with us, directly or indirectly, you provide information and data to us. This information and data will be processed in compliance and accordance with the provisions of EU Regulation 679/2016 (“GDPR”). In accordance with current regulation, the conduct of Franzi will be based on the principles of lawfulness, correctness, transparency, limitation of purposes and storage, data minimization, accuracy, integrity and confidentiality.
This text helps you to understand how we will use your information. Please also note that when using this Website you are also subject to our “General Terms and Conditions of Sale”, which supplement this Policy.
1. DATA CONTROLLER
The data controller is Franzi 1864 S.R.L., a company incorporated under Italian law with its registered office at Via Bernardino Zenale 13, 20123 Milano, Italy, registered with the Camera di Commercio Milano under number MI – 2111944 (“Franzi”). If you have any questions or requests regarding our privacy policy or the way we process your data in general, please contact us via section 15 below. We do not knowingly collect personal information from children who are 16 years old and younger without proper parental consent. If you are a parent or guardian of a child using our services, please send us an email at info@franzi1864.com and we will delete any data related to your child.
2. HOW WE COLLECT YOUR INFORMATION
Depending on the nature of the relationship you have with Franzi, we may collect your personal information, directly or indirectly, in various ways when you:
- fill in a form (paper or electronic) received in a physical store;
- visit our Website, online applications or open our emails (e.g. through cookies or similar technologies);
- interact with representatives on visits to a physical store that sell products of Franzi;
- contact us directly by email, phone, post, message (instant messaging applications), via our Website, web form, social media or by any other means;
- interact with any of our online checkouts;
- purchase online products from us. We may collect information on third-party sites (e.g. Facebook, Instagram, etc.) when, for example, you give us an opinion or comment about our products and services.
Finally, we also collect information we receive from other sources. We are working closely with third parties (this can be, for instance, business partners, sub-contractors in technical, payment and delivery services) who may share information with us.
3. THE INFORMATION YOU COLLECT
We collect and process the following data about you when you access, interact, or operate with the Website and/or services and products:
- Personal identification data (including surname(s), name(s), email(s), phone number, date of birth, postal address, delivery address, country of residence, your fiscal code, and optionally your passport number as part of a tax-free procedure), e.g. when you fill in a form in a physical store; when you purchase a product on our Website; to verify your email address to help prevent spam, fraud, and abuse; to send you information about Franzi products and services that can enhance your use of the service; to communicate with you;
- Technical information (electronic data), including the IP address used to connect your device to the internet, the type and version of the browser, the time-zone setting, the browser plugins’ type and versions, the operating system and platform, the device ID, etc. on each visit to our Website e.g. to keep our Website secure and prevent of fraud; to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, and for statistical and survey purposes;
- Preferences regarding our collections or other luxury brands, as well as your interests and lifestyle during your visits to our physical store based on our interactions and meetings with you e.g. to provide you with information about other services and products which we offer and which may be of interest to you;
- Information related to credit card payments and payment orders (such as name and other details identifying the customer, destination country of the payment transaction, amount and currency of the payment transaction; International Bank Account Number (“IBAN”) when such bank account has an IBAN code, or the bank account code as corresponds in each case) e.g. to verify and execute financial transactions related to your payments;
- Employment-related personal information (such as employment responsibilities, name, location of employment) to review and evaluate your application when you apply via our Website or a third-party site (e.g. LinkedIn);
- Ordinary information about you based on messages you post on third-party sites, or via comments/reviews, or when you contact us by email, post, telephone or any other communication channels e.g. to answer all your inquiries/questions;
- And any other information about you that needs to be processed according to the General Terms and Conditions of Sale.
4. HOW WE USE YOUR INFORMATION
In accordance with the legal basis explained in section 7 below, we use your information as follows:
- to process your purchases, online and offline, and manage your relationship with Franzi in order to improve the management of our relationship with you and keep track of your purchases, particularly for after-sales service issues;
- to provide you with information about other services and products which we offer and which may be of interest to you;
- to verify and execute financial transactions related to your payments;
- to answer all your inquiries/questions when you intentionally communicate with our sales consultants via instant messaging applications (e.g. WhatsApp, WeChat, Line, KakaoTalk or similar);
- to review and evaluate your application when you apply via our Website or a thirdparty site (e.g. LinkedIn);
- to inform you of changes to our services;
- to fight against counterfeiting and related sales of Franzi products;
- for marketing purposes: to contact you, with your consent, if necessary, in order to invite you to events, and to offer you marketing content which is appropriate, personalised, and likely to interest you;
- to conduct market research/data analysis and identify customer profiles;
- to manage contracts and relationships with our suppliers and partners;
- for security purposes: we process your data and images (from our surveillance cameras) to protect you and Franzi and its physical stores;
- to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, and for statistical and survey purposes;
- to improve our Website and social networks to ensure that content is presented in the most efficient way for you and your computer/device; as part of our efforts to keep our Website secure and to prevent fraud;
- to measure or understand the efficacy of the advertising and marketing campaigns we offer, and to provide you with relevant advertising;
- to deliver our products. We use your personal data to take and handle your orders online and deliver the products.
5. DISCLOSURE OF YOUR INFOMATION
For the purposes mentioned above, we may share your information with:
- our commercial partners (e.g. for delivering packages); banks and insurers;
- our professional advisors;
- our IT service provider(s);
- our providers of marketing services;
- providers of online payment services;
- providers of analysis and search engines which help us improve and optimise our Website, such as Google Analytics;
- fraud detection agencies and other third parties who operate and maintain fraud detection registers;
- third party service providers related to the operation and maintenance of the information systems processing your personal data (these providers only have access to the personal data necessary to carry out their missions);
- the courts and tribunals of the judicial order in the event of a dispute involving you;
- law enforcement authorities in the event of a finding or a suspicion of the occurrence of an offence involving you in accordance with or as required by applicable law.
We will also disclose information to third parties under the following circumstances:
- in the event of the purchase or sale of a business or assets, we reserve the right to disclose your personal information to the vendor or purchaser of the business or assets.
- during such transactions, if Franzi or all of its assets were to be purchased by a third party, the information concerning its customers would be part of the assets transferred.
- where we are required to disclose or share your information in order to comply with a legal obligation or to protect the rights, property or security of Franzi of our customers or of others. This includes the sharing of information with public authorities (including the judicial authorities and the police) in the event of, for example, a cyber incident;
- where necessary to achieve one of the purposes described in section 6 of this Policy.
6. COOKIES
Our Website uses cookies. They help us in particular to provide you with a good experience when you browse our Website and also allow us to improve it. For more information about cookies and why we use them, please refer to our Cookie Policy.
7. LEGAL BASIS
Your information is collected and processed on the following legal basis:
- where it is necessary for the pursuit of our legitimate interests, provided that your fundamental rights and freedoms are not affected (e.g. we use your information to establish your preferences in order better to customise our product offerings, prevent fraud and secure our Website);
- where it is necessary to perform our contractual obligations towards you including the repair of a hand bag, to complete your payment transaction for a product, to contact you as necessary in connection with a contract with you (the delivery of a product);
- where it is necessary to fulfil our legal or regulatory obligations to which we are subject (e.g. we collect your bank account information for identity verification, or as part of our billing obligations);
- where you have given your consent for collection and processing, e.g. if you have given your express consent for this purpose, we are likely to use your contact data (email, phone, postal address) to send you marketing materials.
8. YOUR RIGHTS
You have certain rights regarding the information we hold about you. You can exercise these rights by contacting us (see details regarding contacts below):
- you have the right to access the information we hold about you;
- you have the right, under certain circumstances, to request restrictions on, or the termination of, the processing of your information. Where processing is restricted, we will continue to store your data, but we will no longer use it;
- you have the right to request correction of your information if it is inaccurate or incomplete.
- you have the right, under certain circumstances, to request the deletion of your information from our systems;
- you have the right to lodge a complaint with the national data protection authority about how we handle or process your information.
- if our processing of your personal data is specifically based on your consent, you have the right to withdraw that consent at any time. This includes your right to withdraw your consent for use of your data for direct marketing purposes;
- you have the right, under certain circumstances, to receive your data in a structured and standard- format so that you can reuse it for your own purposes in different services. For example, if you want to work with another service provider, you can move your data easily and securely to your new service provider.
You also have the right to object to certain types of processing, including processing for direct marketing purposes. Please note, however, that we may retain and use certain information for legal or administrative purposes (e.g. maintaining accounts). For all the aforementioned requests, please send us an email with as subject "request regarding data protection" and include a copy of your identity card or other proof of your identity (e.g. an identity card) to help us prevent unauthorised access by anyone to your information or its modification or deletion. We will respond as soon as possible. If we require more than one month from receipt to respond to your request, we will keep you informed.
9. TRANSFER OF YOUR INFORMATION
We may transfer your information outside of your country of residence or our country of operations where necessary (a) to achieve any of the purposes set out in Section 5 and/or (b) to disclose your information to a third party in accordance with Section 7 of this Policy.
If your information is transferred outside the European Economic Area (EEA), we will ensure that it is protected via the following guarantees, as laid out in the GDPR:
- the laws of the country to which your information is transferred must ensure an appropriate level of data protection; or
- the transfer must be governed by data protection provisions approved by the European Commission or be subject to the EU-US Privacy Shield.
If you would like to learn more about the transfer of your data and/or the safeguards in place (including how to obtain a copy), do not hesitate to contact us via the channels given in section 14 below.
10. AUTHORISED DATA PROCESSING
Personal data are processed with manual and automated tools, for the time necessary to achieve the purpose for which they were collected. Specific security measures are taken to prevent data loss, illegal or incorrect use and unauthorized access. Franzi adopts appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of personal data. Processing related to the web services of this site takes place at the data controller’s offices. The control and custody of information are handled by authorized personnel responsible for the reception of online requests. The data may occasionally be accessed, for technical reasons only, by authorized personnel who provide assistance to the Website and Franzi’s computer systems. No data deriving from web navigation is communicated or disclosed to third parties except in compliance with legal obligations.
11. SECURITY
We have implemented a number of security measures on our Website with the aim of preventing unauthorised disclosure of, or access to, information collected and/or received. We have strived to create a secure and reliable Website. Please note, however, that the confidentiality of any communication or other material transmitted to us or which we transmit to third parties via our Website or by email cannot be guaranteed. We accept no responsibility for the security of the information transmitted using these methods. All information you provide to us is stored on secure servers in the EEA. When you receive (or choose) a password that allows you to access certain parts of our Website, you are responsible for maintaining the confidentiality of that password. We ask you not to share your passwords.
12. RETENTION OF YOUR INFORMATION
The information we collect is stored in accordance with the applicable data protection regulations and legislation. We ensure that your personal data are kept for no longer than is necessary for the purposes for which they are processed as set out in this Policy. Unless described in the table below, when determining the relevant retention periods, we will take into account factors including: our contractual obligations and rights in relation to the information involved; legal obligation(s) under applicable law to retain data for a certain period of time; statute of limitations under applicable law(s); our justifiable reasons for processing where we have carried out balancing tests; and guidelines issued by relevant data protection authorities. You will find below the list of purposes with the corresponding retention periods:
| PROCESSING OBJECTIVE | RETENTION PERIOD |
| Management of pre-contractual relations with potential customers (prospects). | The retention period is 3 years from the last action/reaction on the part of the person concerned. |
| To process your purchases and manage your relationship with Franzi in order to improve the management of our relationship with you and keep track of your purchases, especially for after-sales service issues. | The retention period is 10 years from your last purchase. |
| To verify and execute financial transactions related to your payments | The retention period is 10 years from your last purchase. |
| To answer all your inquiries/questions when you intentionally communicate with our sales consultants via instant messaging applications (e.g. WhatsApp, WeChat, Line, KakaoTalk or similar). | The retention period is 3 years from your last purchase. |
| To review and evaluate your application when you apply via our Website or a third-party site (e.g. LinkedIn). | The retention period is 6 months from submission of your application. |
| For marketing purposes. | The retention period is 5 years from the last action/reaction on the part of the person concerned. |
| To conduct market research/data analysis and identify customer profiles | The retention period is from 3 to 10 years depending on the initial purpose for which the data was collected. |
| To manage contracts and relationships with our suppliers and partners. | The retention period is 10 years from the end of the contract with you. |
Except if:
- the processing of your data is necessary in the context of actual or potential litigation (e.g. we need this information to establish or defend rights), in which case we will keep your data until the end of such a dispute; and/or
- retention is necessary to enable us to comply with any legal or regulatory obligations (e.g. for tax purposes), in which case we will keep your information as long as is necessary to fulfil that obligation.
13. THIRD PARTY WEBSITES
Our Website may, from time to time, include links to or from the websites of our networks of partners, advertisers or subsidiaries. If you follow a link to one of these websites and/or applications, be aware that such websites and/or applications have their own privacy policies over which we have no control. They are therefore not the subject of this Policy and we decline all responsible for those policies. Please check such policies before sending any information to such websites and/or applications.
14. CONSENT FOR THE COLLECTION AND USE YOUR INFORMATION – CHANGES TO OUR POLICY
By using our Website, or by completing the form distributed in our shops, you acknowledge to having read the terms of this Policy and agree to the collection and use of your information as indicated above. We may change this Policy at any time, in particular to reflect any legislative or regulatory changes. All changes we make to our Policy will be posted on our webpage and, if applicable, will be brought to your attention by email. Continued use of our Website following the publication of these changes this Policy implies your acceptance of these changes. This Policy was last updated on 13/09/2022.
15. HOW TO CONTACT US
If you have any questions, comments or queries regarding this “Privacy Policy”, you can write to the following address: info@franzi1864.com.