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NOTICE ON THE PROCESSING OF PERSONAL DATA – www.poltronafrau.com

pursuant to Art. 13 EU Regulation 2016/679 (“GDPR”)

version of 28 December 2020

Poltrona Frau S.p.A. has prepared this document (“Notice”) to illustrate how it protects the personal data you have voluntarily provided to us during the data gathering campaign on the Facebook and Instagram platforms, to receive interesting information, news and details about projects from the world of Poltrona Frau.

This Notice refers exclusively to the processing performed by Poltrona Frau. For data processing by Facebook and Instagram, you may refer to their notices available here https://www.facebook.com/about/privacy.

1.  DATA CONTROLLER

The Data Controller is Poltrona Frau S.p.A. with sole shareholder, with registered office located at Via Busnelli, no. 1, 20821 Meda (MB), VAT no. 05079060017, a company subject to management and coordination activities by Haworth Italy Holding S.r.l. (“Poltrona Frau” or the “Controller”), [email protected].

The Controller has appointed a Data Protection Officer ("DPO"), who can be contacted at the following address: [email protected].

2.  WHEN AND FOR WHAT PURPOSES WE PROCESS YOUR DATA

The Controller will collect and process your name, surname, email address, telephone number and city (the “Data”) to send you marketing information or information about Poltrona Frau 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 our products. These communications will be sent by email or telephone, including by automated means (SMS, social media).

The legal basis is 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 will receive or by writing to [email protected]

The provision of Data for this purpose is optional. If you do not wish to provide your Data, Poltrona Frau will be unable to keep you updated on the special offers and promotions for its customers, or use the Data for market research, and statistical and customer satisfaction analysis.

In any case, you can also choose to be contacted exclusively via traditional methods, expressing your opposition to receiving communications through automated methods, by writing to [email protected].

3.  DATA STORAGE PERIOD

Poltrona Frau will eliminate the Data 5 years after they are collected, or when you express your objection to their storage. In any case, Poltrona Frau undertakes to base the Data processing on the principles of adequacy and minimization, checking annually the need for storage for a period of time not exceeding what is necessary for the achievement of the purposes for which the Data were collected and processed. The Controller may store the Data to fulfil regulatory obligations, or to ascertain, exercise or defend its right in the court.

Upon achievement of 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 the possibility of continuing to use the Data anonymously for statistical purposes.

4.  METHOD OF PROCESSING

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.

5.  PERSONS AUTHORISED TO PERFORM DATA PROCESSING

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

6.  CATEGORIES OF DATA RECIPIENTS

The Data will not be disseminated.

The following subjects may become aware of the Data in relation to the purposes of the processing outlined above and may process them, independently, as separate Data Controllers or as Data Processors duly appointed by Poltrona Frau (the list of such subjects can be requested from the Controller by writing to [email protected]):

-       Subjects who may access the Data by virtue of EU law or the law of the Member State to which the Controller is subject;

-       Companies that carry out and provide additional services related to the purposes of the processing, internet providers, companies that 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;

-       Purchasers or successors of Poltrona Frau in the event of a merger, sale, restructuring, reorganisation, winding-up or other sale or transfer of all or some of Poltrona Frau’s assets in the context of which the Data are transferred.

7.  TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

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

Should it be necessary to transfer the Data to Third Countries, 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 information outside the EEA in accordance with Article 46.2 of the GDPR.

8.  DATA SUBJECT RIGHTS – COMPLAINTS TO THE SUPERVISORY AUTHORITY

In relation to the above Data processing, it is possible to exercise at any time, by sending an email to [email protected], the following rights under the conditions and within the limits provided for under Articles 12 and 13 of the GDPR:

Right of access (Article 15 GDPR); Right to rectification of inaccurate data and to have incomplete personal data completed (Article 16 GDPR); Right to erasure of data (Article 17 GDPR); Right to restriction of processing (Article 18 GDPR); Right to object to processing under Article 6(1), point (e) or (f) of the GDPR.

You also have the right to lodge a complaint with the Supervisory Authority, i.e. the Italian Data Protection Authority (“Garante Privacy”) and/or other competent supervisory authorities (Article 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 have the right to withdraw the consent provided for commercial and marketing purposes at any time. You can also choose to be contacted for marketing purposes exclusively via traditional methods, expressing your opposition to receiving communications through automated methods.

9.  MINORS

The Products offered by Poltrona Frau 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 individuals. In the case that personal data relating to minors are provided in any event, Poltrona Frau will delete them.

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This Notice is effective from the date of publication. The Controller may make changes and/or additions to this Notice, including as a result of any subsequent regulatory changes and/or addendums.