Privacy Policy

PRIVACY POLICY FOR THE PROCESSING OF PERSONAL DATA pursuant to Article 13 of the General Data Protection Regulation (EU) 679/2016 ("GDPR").

This Privacy Policy is valid as of the date of its publication (last update: 27 March 2024). Amendments and/or additions may be made, also as a consequence of any subsequent regulatory changes and/or additions.

DATA CONTROLLER AND DATA PROCESSOR

This privacy policy describes the processing operations carried out by Interni S.p.A. with sole shareholder ("Interni"), VAT No. IT00818300964 with registered office in Via F. Turati 8, 20121 Milan (MI), e-mail privacy@poltronafraugroup.com as autonomous data controller and as joint data controller with the company FiloBlu S.p.A., Tax Code/VAT Number 04274870288, with registered office in Santa Maria di Sala (Ve) via Caltana 116/c (“Filoblu”) e-mail privacy@filoblu.com.

Specifically, Interni acts as autonomous data controller for the processing of personal data necessary to carry out promotional and marketing activities, relying on FiloBlu as data processor in the performance of such online operations.

On the other hand, Interni and Filoblu (the "Joint Data Controllers") jointly process the data relating to the activities of user registration to the website and online product sales. The Joint Data Controllers will jointly process your data on the basis of specific agreements; we will be happy to provide you with more information on their essential content if you so request. FiloBlu has also appointed a Data Protection Officer (DPO) who can be contacted at the following e-mail address: dpo@filoblu.com

DATA COLLECTION SOURCE

Personal data (the "Personal Data" or "Data") is automatically collected or provided through browsing or the use of this website (the "Website"), when you visit one of Interni’s showrooms (the "Showrooms"), or when you purchase one of Interni’s products (the "Products").

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1.A - DATA PROCESSING CARRIED OUT FOR THE MANAGEMENT OF SHOWROOM SALES (Interni autonomous data controller)

DATA CATEGORIES - PERSONAL DATA AND CONTACT DETAILS first name, last name, tax code, e-mail, address, telephone number, shipping address, passport data for Tax Free/Refund service - PURCHASE DATA type and price of Products purchased.

PURPOSE OF THE PROCESSING - Perform sales of products at Interni's showrooms and manage after-sales services (e.g. returns, refunds, repairs, etc.).

MANDATORY OR OPTIONAL PROVISION OF DATA - Necessary. If you do not wish to provide your Data, Interni will not be able to process the corresponding purchase order or manage the services related to the after-sale of the Products.

LEGAL BASIS OF THE PROCESSING - The need to perform pre-contractual and contractual obligations to which you are a party, as well as the need to fulfil legal obligations.

PERSONAL DATA RETENTION PERIOD – Interni undertakes to delete your Data provided for the execution of the sale and the management of after-sales services from its database 10 years after the date of your last purchase or your last interaction with Interni.

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1.B - DATA PROCESSING CARRIED OUT ON THE WEBSITE - ONLINE SALE (Internal and Filoblu Joint Data Controllers)

DATA CATEGORIES - PERSONAL DATA AND CONTACT DETAILS first name, last name, date of birth, tax code, e-mail, telephone number, address, shipping address - PURCHASE DATA type and price of Products purchased - OTHER DATA The personal data communicated in the text box on the Website

PURPOSE OF THE PROCESSING - Perform sales of products through the Website and manage after-sales services (e.g. returns, refunds, repairs, etc.).

MANDATORY OR OPTIONAL PROVISION OF DATA - Necessary. If you do not wish to provide your Data, the Joint Data Controllers will not be able to process the corresponding purchase order or manage the services related to the after-sale of the Products.

LEGAL BASIS OF THE PROCESSING - The need to perform pre-contractual and contractual obligations to which you are a party, as well as the need to fulfil legal obligations.

PERSONAL DATA RETENTION PERIOD – the Joint Data Controllers undertake to delete your Data provided for the execution of the sale and the management of after-sales services from its database 10 years after the date of your last purchase or your last interaction with the Joint Data Controllers.

Fraud prevention

In some cases, to finalise your purchase, some additional checks may need to be carried out in order to prevent fraud and, therefore, you may receive messages, including by e-mail from our dedicated account customerservice@internionline.it, in which we will ask you to send us the authorisation code, and/or the credit card used for the purchase, on which we will ask you to obscure the eight central digits. The data collected in this way will be kept for 1 (one) year from the time of collection for evidence purposes, for cooperation with the judicial authorities and to deal with any disputes that may arise in this regard. We guarantee that the data collected in this way will be processed in full compliance with current legislation on the protection of personal data and may have to be shared with third parties who process credit or debit card payments and perform anti-fraud checks, banks, judicial authorities.

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DATA CATEGORIES - PERSONAL DATA AND CONTACT DETAILS first name, last name, e-mail, address, telephone number - OTHER DATA contractual and project documentation

PURPOSE OF THE PROCESSING - To enable you to register as a customer on the Website and to access one of the restricted areas of the Website or to use our services (such as participation in one of Interni's 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 take advantage of related services in the reserved areas of the Website or participate in one of Interni's events.

LEGAL BASIS OF THE PROCESSING - The need to perform pre-contractual and contractual obligations to which you are a party, as well as the need to fulfil legal obligations.

PERSONAL DATA RETENTION PERIOD - The Joint Data Controllers agree to delete your data from their systems 10 years after your registration is cancelled, which includes data related to your access to the reserved areas of the Website and the use of related services.

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DATA CATEGORIES - PERSONAL DATA AND CONTACT DETAILS First name, last name, e-mail, telephone number, country, region, city. The personal data communicated in the text on the Website or to the Joint Data Controller's e-mail inbox.

MANDATORY OR OPTIONAL PROVISION OF DATA - Necessary. If you do not provide your data, the Joint Data Controllers will not be able to process the requests submitted.

LEGAL BASIS OF THE PROCESSING - The need to perform pre-contractual and contractual obligations to which you are a party, as well as the need to fulfil legal obligations.

PERSONAL DATA RETENTION PERIOD - The Joint Data Controllers undertake to delete any Data provided in relation to requests made through the Website or by e-mail from their systems after 1 year from when the Data was provided.

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DATA CATEGORIES - ECONOMIC ANALYSIS AND STATISTICAL DATA FROM END USERS

PURPOSE OF THE PROCESSING – Processing of statistics and market analyses in order to improve the offer and for the purpose of optimising e-commerce activities also through the use of BI tools.

MANDATORY OR OPTIONAL PROVISION OF DATA - Necessary.

LEGAL BASIS OF THE PROCESSING – Legitimate interest of the Joint Data Controllers.

PERSONAL DATA RETENTION PERIOD - The Joint Data Controllers undertake to delete your data from their systems 10 years after collection. In any case, anonymisation systems are implemented one year after collection.

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CANDIDACIES - Should you wish to send Interni an application for a job with Interni or one of the companies in the group to which Interni belongs through the Website, your data will be processed in accordance with the relevant privacy policy, available at the following link: https://careers.poltronafrau.com/

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2) MARKETING (Interni autonomous data controller)

DATA CATEGORIES - PERSONAL DATA AND CONTACT DETAILS first name, last name, mail, address, telephone number.

PURPOSE OF THE PROCESSING - Communicate marketing information about collections, exhibitions, and events, including through the Interni newsletter, and invite you to participate in customer satisfaction surveys and market research to enhance our products. These communications may be sent via email or phone, including automated methods such as SMS and social media messaging. Automated messages will be sent no more than twice a month or for special events (e.g., Salone del Mobile). You can always choose to receive communications only through traditional methods by opting out of automated messages. To do so, please contact us by writing to privacy@poltronafraugroup.com.

MANDATORY OR OPTIONAL PROVISION OF DATA - Optional. If you choose not to provide your Data, Interni will not be able to keep you updated on offers and promotions reserved for its customers. Additionally, we will not be able to use your Data for market research, statistical analyses, or customer satisfaction studies.

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

PERSONAL DATA RETENTION PERIOD - Interni has decided to provide for the deletion of the Data processed for the purpose of sending you commercial information, including personalised information, following categorisation on the basis of the parameters described herein, on collections, exhibitions and events, as well as for participation in customer satisfaction surveys and market research, 10 years after the collection of the Data, or until you object. Interni considered the nature of the products, which typically involve an average purchase frequency of one or two items per person every 6-7 years. As a result, shorter data retention periods would not support providing personalised services. Nonetheless, data will still be retained for 10 years for sales management and after-sales support.

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3) DISCLOSURE OF DATA TO GROUP COMPANIES FOR MARKETING PURPOSES (Interni autonomous data controller)

DATA CATEGORIES - PERSONAL DATA AND CONTACT DETAILS first name, last name, mail, address, telephone number.

PURPOSE OF THE PROCESSING - Disclose your data to other companies in the group to which Interni belongs so that they can send you commercial information, about collections, exhibitions and events, including through newsletters, in relation to their products and services and to participate in any customer satisfaction surveys and market research for the improvement of Products.

MANDATORY OR OPTIONAL PROVISION OF DATA - Optional. If you do not wish to provide your Data, Interni will not be able to disclose your data to the other group companies for these purposes.

LEGAL BASIS OF THE PROCESSING - Your explicit consent to the processing of your Data for this purpose. If you have provided consent, you may revoke it at any time by clicking on the unsubscribe button in the e-mails or newsletters you receive or by writing to privacy@poltronafraugroup.com.

PERSONAL DATA RETENTION PERIOD - Interni has decided to provide for the deletion of the Data processed for the purpose of sending you commercial information, including personalised information, following categorisation on the basis of the parameters described herein, on collections, exhibitions and events, as well as for participation in customer satisfaction surveys and market research, 10 years after the collection of the Data, or until you object.

Interni considered the nature of the products, which typically involve an average purchase frequency of one or two items per person every 6-7 years. As a result, shorter data retention periods would not support providing personalised services. Nonetheless, data will still be retained for 10 years for sales management and after-sales support.

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4) CUSTOMER CATEGORISATION (Interni autonomous data controller)

DATA CATEGORIES - PERSONAL AND CONTACT DATA first name, surname, age group, e-mail, telephone number, country of residence - OTHER DATA profession, Product purchase channels (e.g. web, showroom)

PURPOSE OF THE PROCESSING - Categorisation of customers based on a number of parameters, for the purpose of sending promotional communications targeted to the needs of a certain category or bracket to which you belong (e.g. customers aged 50 to 70, residents of a specific region, etc.).

MANDATORY OR OPTIONAL PROVISION OF DATA - Optional. Should you object to the processing of your data, it will not be possible for Interni to keep you constantly updated on offers and promotions for certain categories of customers. If you have given your consent to receive promotional information anyway, you may then only receive generic newsletters.

LEGAL BASIS OF THE PROCESSING - Interni's legitimate interest in achieving maximum efficiency in its marketing activities. We will only send communications with promotional content taking into account your bracket or category if you have given your consent, which may be revoked at any time and without prejudice. You may exercise your right to opt out of receiving these communications at any time, either immediately or at a later date, by clicking on the unsubscribe button contained in any e-mail or newsletter you receive or by writing to privacy@poltronafraugroup.com.

PERSONAL DATA RETENTION PERIOD - Interni has decided to provide for the deletion of the Data processed for the purpose of sending you commercial information, including personalised information, following categorisation on the basis of the parameters described herein, on collections, exhibitions and events, as well as for participation in customer satisfaction surveys and market research, 10 years after the collection of the Data, or until you object.

Interni considered the nature of the products, which typically involve an average purchase frequency of one or two items per person every 6-7 years. As a result, shorter data retention periods would not support providing personalised services. Nonetheless, data will still be retained for 10 years for sales management and after-sales support.

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1.D - DATA PROCESSING FOR COMMERCIAL PURPOSES FOLLOWING A SALE IN THE SHOWROOM OR ON THE WEBSITE (Interni autonomous data controller)

DATA CATEGORIES - PERSONAL DATA AND CONTACT DETAILS first name, last name, e-mail - PURCHASE DATA type of Products purchased

PURPOSE OF THE PROCESSING - The sending of communications containing commercial proposals concerning products similar to those already purchased (soft spam).

MANDATORY OR OPTIONAL PROVISION OF DATA - Optional. Should you wish to object to the processing of your data, it will not be possible for Interni to keep you constantly updated on offers and promotions of products similar to those you have already purchased.

LEGAL BASIS OF THE PROCESSING - Interni’s legitimate interest in building customer relationships and increasing the volume of requests and sales for its Products. You may exercise your right to object to receiving these communications at any time, either immediately or at a later date, by clicking on the unsubscribe button contained in the e-mails or newsletters you receive or by writing to privacy@poltronafraugroup.com.

PERSONAL DATA RETENTION PERIOD - Interni has agreed to provide for the deletion of the Data processed for the purpose of sending communications containing commercial proposals regarding Products similar to those already purchased (soft spam), after 24 months from the date of each purchase, unless an objection is lodged before this deadline and without prejudice to their storage for 10 years for the purposes of executing the sale and managing after-sales services.

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2 – DATA PROCESSING METHODS AND POSSIBLE FURTHER DATA RETENTION

The Data will be collected and processed in compliance with the principles of correctness, legality and transparency, by manual or automated means, always within the limits of the processing purposes described in this privacy policy and, in any case, in a way that guarantees the security and confidentiality of the Data.

With regard to data retention, Interni and Filoblu, respectively for processing as autonomous and joint data controller, have indicated the relevant timeframes in correspondence with each processing operation and undertake in any case to inspire the processing of Data to the principles of adequacy and minimisation, annually verifying the need for retention for a period of time no longer than is necessary to achieve the purposes for which the Data was collected and processed. It is understood that Interni and Filoblu may retain Data to fulfil legal obligations, or to ascertain, exercise or defend a right in court. Once the purposes for which the Data has been collected and processed have been fulfilled, Interni and Filoblu will take appropriate measures to make the Data anonymous, to prevent its identification, without prejudice, however, to the possibility to continue using the Data anonymously.

3 - ANY AUTOMATED DECISION-MAKING PROCESSES

As mentioned above and based on your legitimate interest, Interni categorises its clients in order to send you commercial information on collections, exhibitions and events targeted to the needs of a certain category or bracket to which you belong. This process is carried out by subdividing the data subjects into non-invasive and non-discriminatory categories, such as country of residence (e.g. targeting residents of Lombardy for a new store opening in Milan), age range (e.g. For instance, focusing on customers aged 50 to 70 if the product is statistically suited for this age group), and product purchase channels (e.g. Differentiating between communications for online shoppers versus those who prefer physical stores). Following this analysis, which may also take place in automated form, the user may be classified into one or more groups with different characteristics and receive communications from Interni dedicated to that category which Interni considers to be in line with their needs. In relation to this processing, Interni has positively conducted a balancing test in order to determine that the processing linked to this categorisation is conducted on the legal basis of Interni's legitimate interest in achieving maximum efficiency in its marketing activities.

4 - PERSONS AUTHORISED TO PROCESS DATA

The Data may be processed by the Interni and Filoblu data processors, who have been expressly authorised and given adequate operational instructions in relation to the purposes of the processing described above.

5 - POSSIBLE DATA RECIPIENTS

Data will not be disseminated. The following persons may become aware of the Data in connection with the processing purposes described above and may process the Data independently, as separate data controllers, or as data processors specifically appointed by Interni and/or Filoblu (the list of such persons may be requested by writing to privacy@poltronafraugroup.com and privacy@filoblu.com):

Interni's retailers or business partners who will receive, at your request, the configuration of the Products you selected for the purpose of finalising the purchase; these entities will act as autonomous data controllers and please also refer to their privacy policy;
Interni's resellers or business partners or group companies to which Interni belongs; these entities will act as data processors;
Group companies of which Interni is a member to which we will disclose Data for the purpose of sending commercial information, on collections, exhibitions and events, by the above-mentioned companies, regarding their products and services; these entities will act as autonomous Data controllers and will only receive the Data if you have given your consent to the disclosure of the Data;
Group companies to which Interni belongs for administrative and accounting purposes; these entities will act as data processors;
Subjects who can access the Data by virtue of legal provisions provided for by the law of the European Union or by the law of the Member State to which Interni and Filoblu are subject; these subjects will act as autonomous data controllers;
Companies that carry out and provide further services related to the processing purposes, banking operators, electronic payment providers, credit card issuers, internet providers, couriers and forwarding agents, companies that organise events or send newsletters or market research, companies that offer data analysis services, companies that offer IT infrastructures and IT assistance and consultancy services, law firms or accountants, auditors; these subjects will act as data processors or in some cases as autonomous data controllers;
Interni or Filoblu's purchasers or successors in the event of a merger, divestiture, restructuring, reorganisation, dissolution or other sale or transfer of some or all of Interni or Filoblu's assets, in which the Data may be transferred; these entities will act as autonomous data controllers and we will only disclose the Data necessary for the assessment of the transaction based on our legitimate interest.

6 - TRANSFER OF DATA ABROAD

All Data processing is performed in countries within the European Union.

Should there be a need to transfer Data to Third Countries, e.g. for the management of relations with customers having interests in Countries other than the European Union, Interni and Filoblu undertake to:

Ensure that the country to which the Data will be sent guarantees an adequate level of protection, as required by Article 45 GDPR; or
Use the standard contractual Data Protection Clauses approved by the European Commission for the transfer of personal information outside the EEA pursuant to Article 46.2 GDPR.

7 - YOUR RIGHTS AS DATA SUBJECT – FILING A CLAIM WITH A SUPERVISORY AUTHORITY

In relation to the aforementioned processing of Data, you may exercise the following rights at any time, by e-mail to privacy@poltronafraugroup.com and privacy@filoblu.com, subject to the conditions and within the limits set out in Articles 12 and 13 GDPR:

Right of access (Article 15 GDPR);
Right to rectification of inaccurate data and integration of incomplete data (Article 16 GDPR);
Right to erasure (Article 17 GDPR);
Right to restriction of processing (Article 18 GDPR);
Right to object to processing carried out pursuant to Article 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 (“Privacy Guarantor”) and/or other competent supervisory authorities (Article 77 GDPR).

Furthermore, if the processing is based on consent or contract and is carried out by automated means, you may exercise your right to receive the Data in a structured, commonly used and machine-readable format and, if technically feasible, to transfer the data to another data controller without hindrance pursuant to Article 20 GDPR.

You also have the right to object at any time to the processing of the Data, either immediately or subsequent to the provision of the Data itself, in connection with Interni's sending unsolicited notices containing commercial proposals relating to Products similar to those already purchased (soft spam) sent directly to the e-mail address provided at the time of the purchase of Products, pursuant to Article 130, paragraph 4, of Legislative Decree 196/2003, as amended by Legislative Decree 101/2018.

This is without prejudice to your possibility of preferring to be contacted for marketing purposes exclusively by traditional means, by expressing your opposition only to receiving communications by automated means.

The user has the right to withdraw consent given for marketing purposes at any time.

8 – MINORS

The Website and the Products are in no way intended for minors under 18 years old, therefore Interni and Filoblu do not collect and/or process personal data referring to minors. Should any personal data concerning minors be entered on the Website, Interni and Filoblu will delete such data.