Pivacy Order

Privacy Policy for the processing of personal data

Pursuant to Article 13 of the General Data Protection Regulation (EU) 679/2016 ("GDPR").

This Policy is valid from the date of publication (last updated: 13 April 2023). The Controller may make changes and/or additions to this Policy, including as a result of any subsequent legislative changes and/or additions.

Data Controller

Interni S.p.A., single-member company ("Interni" or "Controller"), VAT no. IT00818300964, with registered office at Via F. Turati 8, 20121 Milan (MI). E-mail: privacy@poltronafraugroup.com.

Source of the data

Personal data (the "Personal Data" or "Data") is collected automatically or provided through browsing or use of this website (the "Website") or on the occasion of your visit to one of our showrooms (the "Showrooms"), including for the purchase of one of our products (the "Products").

1.A – Processing of data for the management of sales at the Showrooms

Categories of data. Personal and contact data: first name, last name, tax code, e-mail, address, telephone number, shipping address, passport data for the Tax Free/Refund service. Purchase data: type and price of the Products purchased.

Purpose of processing. To carry out the sale of Products at its Showrooms and to manage after-sales services (for example, returns, refunds, repairs, etc.).

Mandatory or optional provision of data. Mandatory. Should you decide not to provide your Data, the Controller will be unable to process the corresponding purchase order or to manage the after-sales services related to the Products.

Legal basis of processing. The need to perform pre-contractual and contractual obligations to which you are a party, as well as the need to comply with legal obligations.

Retention period. The Controller undertakes to delete from its systems the Data provided by you for the performance of the sale and the management of after-sales services 10 years after the date of the last purchase or the last interaction with the Controller.

1.B – Processing of data on the Website (online sales)

Categories of data. Personal and contact data: first name, last name, tax code, e-mail, telephone number, address, shipping address. Purchase data: type and price of the Products purchased. Other data: the personal data provided in the dedicated text field on the Website.

Purpose of processing. To carry out the sale of Products through the Website and to manage after-sales services (for example, returns, refunds, repairs, etc.).

Mandatory or optional provision of data. Mandatory. Should you decide not to provide your Data, the Controller will be unable to process the corresponding purchase order, nor to manage the after-sales services related to the Products.

Legal basis of processing. The need to perform pre-contractual and contractual obligations to which you are a party, as well as the need to comply with legal obligations.

Registration as a customer and access to reserved areas

Categories of data. Personal and contact data: first name, last name, e-mail, address, telephone number. Other data: contractual and project documentation relating to you.

Purpose of processing. To allow you to register as a customer on the Website and to access one of the reserved areas of the Website or to use our services (such as, for example, participation in one of our events).

Mandatory or optional provision of data. Mandatory. Should you decide not to provide your Data, you will not be able to register as a customer or use the related services in the reserved areas of the Website, nor to participate in one of our events.

Legal basis of processing. The need to perform pre-contractual and contractual obligations to which you are a party, as well as the need to comply with legal obligations.

Retention period. The Controller undertakes to delete from its systems the Data provided by you for your registration and access to the reserved areas of the Website and the use of the related services, 10 years after the date of cancellation of the relevant subscription.

Management of contact requests

Categories of data. Personal and contact data: first name, last name, e-mail, telephone number, country, region, city. The personal data provided in the dedicated text field on the Website or to the Controller's e-mail address.

Purpose of processing. Management of contact requests submitted through the dedicated page of the Website ("contact") or by e-mail to the Controller.

Mandatory or optional provision of data. Mandatory. In the absence of such provision, the Controller will not be able to process the requests sent.

Legal basis of processing. The need to perform pre-contractual and contractual obligations to which you are a party, as well as the need to comply with legal obligations.

Retention period. The Controller undertakes to delete from its systems the Data provided by you in relation to requests submitted through the Website or by e-mail 1 year after the date on which it was provided.

Job applications

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

2 – Marketing

Categories of data. Personal and contact data: first name, last name, e-mail, address, telephone number.

Purpose of processing. To communicate commercial information to you regarding collections, exhibitions and events, including through our newsletter, or to allow you to participate in any customer satisfaction surveys and market research for the improvement of the Products. These communications will be sent by e-mail or telephone, including by automated means (SMS, social network messaging systems). We will carry out communications by automated means approximately no more than twice a month or on the occasion of particular initiatives (e.g. Salone del Mobile). You also have, in any case, the option to prefer to be contacted exclusively through traditional means, by expressing your objection only to receiving communications through automated means by writing to privacy@poltronafraugroup.com.

Mandatory or optional provision of data. Optional. Should you decide not to provide your Data, the Controller will not be able to keep you constantly updated on the offers and promotions reserved for its customers, nor to use the Data for market research and statistical and customer satisfaction analysis.

Legal basis of processing. Your explicit consent to the processing of the Data for this purpose. Should you have given it, you may withdraw it at any time by clicking on the unsubscribe button contained in the e-mails or newsletters received, or by writing to privacy@poltronafraugroup.com.

Retention period. The Controller has decided to delete the Data processed for the purpose of sending you commercial information, including personalized information, following categorization on the basis of the parameters described here, regarding 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 your possible objection. To this end, the Controller has taken into consideration the type of goods offered, for which an average purchase frequency by customers of one or at most two products per capita every 6-7 years is assumed. Therefore, shorter data analysis periods would not allow the offering of personalized services. In any case, the retention of the Data for 10 years for the purposes of managing sales and after-sales services remains unchanged.

3 – Communication of data to group companies for marketing purposes

Categories of data. Personal and contact data: first name, last name, e-mail, address, telephone number.

Purpose of processing. To communicate your Data to other companies of the group to which the Controller belongs so that they may send you commercial information regarding collections, exhibitions and events, including through newsletters, in relation to their own products and services, and to participate in any customer satisfaction surveys and market research for the improvement of the Products.

Mandatory or optional provision of data. Optional. Should you decide not to provide your Data, the Controller will not be able to communicate the Data to the other group companies for such purposes.

4 – Customer categorization

Categories of data. Personal and contact data: first name, last name, age range, e-mail, telephone number, country of residence. Other data: profession, purchase channels of the Products (e.g. web, showroom).

Purpose of processing. Categorization of customers on the basis of a series of parameters, for the purpose of sending promotional communications targeted to the needs of a certain category or range to which you belong (e.g. customers aged 50 to 70, residents in a specific region, etc.).

Mandatory or optional provision of data. Optional. Should you wish to object to the processing of your Data, the Controller will not be able to keep you constantly updated on the offers and promotions dedicated to certain customer categories. If you have given your consent to receive promotional information in any case, you may therefore receive only generic newsletters.

Legal basis of processing. The legitimate interest of the Controller in achieving maximum efficiency in its marketing activities. We will send promotional communications taking into account your range or category of membership only if you have given your consent, which may be withdrawn at any time and without prejudice. You may at any time exercise your right to object to receiving these communications, immediately or subsequently, by clicking on the unsubscribe button contained in the e-mails or newsletters received, or by writing to privacy@poltronafraugroup.com.

1.D – Processing of data for commercial purposes following a sale at the Showroom or on the Website

Categories of data. Personal and contact data: first name, last name, e-mail. Purchase data: type of the Products purchased.

Purpose of processing. The sending of communications containing commercial offers relating to Products similar to those already purchased (soft spam).

Legal basis of processing. The legitimate interest of the Controller in developing relationships with its customers and increasing the volume of requests and sales of the Products. You may at any time exercise your right to object to receiving these communications, immediately or subsequently, by clicking on the unsubscribe button contained in the e-mails or newsletters received, or by writing to privacy@poltronafraugroup.com.

Retention period. The Controller has decided to delete the Data processed for the purpose of sending communications containing commercial offers relating to Products similar to those already purchased (soft spam), 24 months after the date of each purchase, except in the case of objection if made before that deadline, and without prejudice to their retention for 10 years for the purposes of performing sales and managing after-sales services.

Methods of data processing and any further retention of data

The Data will be collected and processed in compliance with the principles of fairness, lawfulness and transparency, by manual or automated means, always within the limits of the processing purposes described in this policy and, in any case, in such a way as to ensure the security and confidentiality of the Data.

With regard to data retention, the Controller has indicated the relevant periods in correspondence with each processing operation and undertakes in any case to base the processing of the Data on the principles of adequacy and minimization, annually verifying the need for retention for a period no longer than necessary to achieve the purposes for which the Data was collected and processed. It is understood that the Controller may retain the Data to comply with regulatory obligations, or to ascertain, exercise or defend a right in court. Once the purposes for which the Data was collected and processed have been achieved, the Controller will take appropriate measures to render it anonymous, so as to prevent your identification, without prejudice in any case to the possibility of continuing to use the Data in anonymous form.

Any automated decision-making processes

As indicated above, the Controller carries out, on the basis of its legitimate interest, a categorization of its customers for the purpose of sending commercial information regarding collections, exhibitions and events targeted to the needs of a certain category or range to which you belong. This procedure is carried out by dividing data subjects according to minimally invasive and non-discriminatory categories, such as country of residence (residents in the Lombardy region, if, for example, the aim is to identify a category of subjects interested in the opening of a new point of sale in Milan), age range (e.g. customers aged 50 to 70, if, for example, it concerns a product statistically intended for this age range), and purchase channels of the Products (e.g. differentiating communications addressed to a predominantly web-based customer base 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 receive from the Controller communications dedicated to the category that the Controller believes to be in line with your needs. In relation to this processing, the Controller has successfully carried out a balancing test in order to determine that the processing related to the categorization in question is conducted on the legal basis of the Controller's legitimate interest in achieving maximum efficiency in its marketing activities.

Persons authorized to process the data

The Data may be processed by the Controller's appointees, who have been expressly authorized and have received adequate operating instructions in relation to the processing purposes set out above.

Possible recipients of the data

The Data will not be subject to dissemination. The following subjects may become aware of the Data in relation to the processing purposes set out above and may process it, autonomously, as separate Data Controllers, or as Data Processors specifically appointed by the Controller (the list of such subjects may be requested from the Controller by writing to privacy@poltronafraugroup.com):

Resellers or commercial partners of the Controller who will receive, at your request, the configuration of the Products selected by you in order to finalize the purchase; such subjects will act as autonomous data controllers, and please also refer to their privacy policy;
Resellers or commercial partners of the Controller or companies of the group to which the Controller belongs; such subjects will act as data processors;
Companies of the group to which the Controller belongs, to whom we will communicate the Data for the sending of commercial information regarding collections, exhibitions and events, by said companies, in relation to their own products and services; such subjects will act as autonomous controllers of the Data and will receive it only if you have given consent to the communication of the Data;
Companies of the group to which the Controller belongs, for administrative and accounting purposes; such subjects will act as data processors;
Subjects who may access the Data by virtue of legal provisions under European Union law or the law of the member state to which the Controller is subject; such subjects will act as autonomous data controllers;
Companies that carry out and provide additional services connected to the processing purposes, banking operators, electronic payment carriers, credit card issuers, internet providers, couriers and shippers, companies that carry out event organization activities or the sending of newsletters or market research, companies that offer data analysis services, companies that offer IT infrastructure and IT assistance and consultancy services, law firms or accountants, auditors; such subjects will act as data processors or in certain cases as autonomous data controllers;
Acquirers or successors of the Controller in the event of merger, transfer, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Controller's assets, in which the Data may be subject to transfer; such subjects will act as autonomous data controllers and we will communicate to them only the Data necessary for the evaluation of the transaction on the basis of our legitimate interest.

Transfer of personal data abroad

The entire processing of the Data takes place in the countries of the European Union. Should there be a need to transfer the Data to Third Countries, for example for the management of relationships with customers who have interests in countries outside 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 for by Article 45 GDPR; or
Use the standard data protection contractual clauses approved by the European Commission for the transfer of personal information outside the EEA pursuant to Article 46.2 GDPR.

Your rights as a data subject – Complaint to a Supervisory Authority

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

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

The user also has the right to lodge a complaint with the Supervisory Authority, namely the Italian Data Protection Authority (the "Garante Privacy") and/or other competent supervisory authorities (Art. 77 GDPR).

Furthermore, in the event that the processing is based on consent or on contract and is carried out by automated means, it is possible to exercise the right to receive the Data in a structured, commonly used and machine-readable format, as well as, where technically feasible, to transmit it to another controller without hindrance pursuant to Art. 20 GDPR.

You also have the right to object at any time to the processing of the Data, immediately or subsequently to the provision of the Data itself, in relation to the sending by the Controller of unsolicited communications containing commercial offers relating to Products similar to those already purchased (soft spam) carried out directly to the e-mail