PRIVACY POLICY

Privacy Notice pursuant to Article 13 of Regulation (EU) 2016/679 ("GDPR")
Poltronesofà S.p.A. ("poltronesofà", the "Controller" or the "Data Controller") processes the personal data of users ("Users") and purchasers of poltronesofà products ("Customers") who: (i) browse the website www.poltronesofa.com (the "Website"); (ii) submit requests through the contact forms available on the Website; or (iii) register for the Website's Registered Area.

This Privacy Notice explains how and why the Controller processes Users' and Customers' personal data, in accordance with the applicable data protection laws.
By accessing and browsing the Website, Users acknowledge that they have read and understood this Privacy Notice.


1. DATA CONTROLLER

The Data Controller is Poltronesofà S.p.A., with its registered office at Via Lunga No. 16, 40053 Valsamoggia, Crespellano (Bologna), Italy, and its administrative office at Via Raffaele Bendandi No. 14, 47122 Villanova di Forlì (Forlì-Cesena), Italy.


2. CATEGORIES OF PERSONAL DATA PROCESSED AND METHODS OF COLLECTION

The categories of personal data processed by the Data Controller and the related methods of collection are as follows:
2.1 Personal Data Provided Directly by Users and/or Customers
Users and/or Customers may access and use the specific features made available on the Website, as described listed below.
- 2.1.1. “Contact Us”
The “Contact Us” section contains several contact forms through which where Users and/or Customers may be asked to provide personal data, including, by way of example, their first name, last name and email address.
These data are required to enable the Controller to respond to specific requests submitted by Users and/or Customers. Depending on the contact form selected, such requests may concern:
• information regarding the delivery, maintenance and care of purchased products and, more generally, information relating to purchases made at the stores;
• information about promotions currently available at the stores;
• suggestions for improving the Website.
- 2.1.2. Newsletter Subscription – "Receive Promotions and News"
When Users and/or Customers access the Website, a newsletter subscription form is displayed.
To subscribe to the poltronesofà newsletter, Users and/or Customers may be asked to provide certain personal data, including, by way of example, their first name, last name, email address, postal code, mobile phone number and date of birth.
- 2.1.3. Reserved Area
When registering for the Registered Reserved Area, Users and/or Customers will be asked to provide certain personal data, including, by way of example, their first name, last name, email address and mobile phone number, for the purpose of creating login credentials to access the Registered Reserved Area.

* * *

Providing the information requested in the forms referred to in Sections 2.1.1, 2.1.2 and 2.1.3 is voluntary. However, failure to complete the fields marked with an asterisk (*) will prevent the Controller from processing the relevant request.

2.2 Browsing Data
The IT systems and software procedures used to operate the Website automatically collect certain personal data during their normal operation. The transmission of such data is inherent in the use of Internet communication protocols.

Although this information data is not collected in order to identify individuals, it could, by its very nature and when combined with other data, allow users to be identified.
This category of data includes, for example, IP addresses, domain names of the devices used to access the Website, the URI (Uniform Resource Identifier) addresses of requested resources, the date and time of requests, the method used to submit requests to the server, the size of the response files, the numerical status code returned by the server (e.g. successful request or error), and other parameters relating to the user's operating system and IT environment.

Such data are processed solely for the purpose of obtaining anonymous statistical information on the use of the Website, ensuring its proper functioning, and are deleted immediately after processing.

2.3 User and/or Customer Location Data
Through the “Our Stores” section and the “Find a Store Near Me” feature, and subject to the User's and/or Customer's prior consent, the Website processes location data in order to to provide a service enabling Users and Customers to locate the nearest poltronesofà stores on a map.

2.4 Cookies
The Website uses cookies that may collect information capable of identifying or relating to an individual.
For further information regarding the processing of personal data through cookies, please refer to the Cookie Policy available at the following link.


3. PURPOSES OF THE PROCESSING, LEGAL BASIS AND DATA RETENTION PERIOD

The Controller processes personal data for the purposes set out below by means of IT tools and systems strictly related to such purposes and, in any event, in a manner that ensures the security and confidentiality of the personal data in compliance with the applicable law.

3.1 To enable the User to browse the Website and use the services made available through it.
The legal basis for this processing is the performance of a contract contractual obligations and the fulfilment of requests from the data subject, or the implementation of pre-contractual measures taken at the request of the data subject pursuant to Article 6(1)(b) of the GDPR.
The personal data will be retained for as long as necessary to enable the User to use the relevant service. This retention period may be extended where the data subject's personal data are processed for other specific purposes.

3.2 To respond to requests submitted to the Controller through the contact forms available in the "Contact Us" section of the Website.
The legal basis for this processing is the performance of contractual obligations and the fulfilment of requests from the a contract or the implementation of pre-contractual measures taken at the request of the data subject pursuant to Article 6(1)(b) of the GDPR.
The personal data will be retained for as long as necessary to process the relevant request. This retention period may be extended where the data subject's personal data are processed for other specific purposes.

3.3 To enable Customers registered with the Registered Reserved Area to use the services available on the Website relating to products purchased from at poltronesofà stores.
In particular, Customers may can download the warranty relating to the purchased product, view their previous purchases and monitor the status of their orders (for example, track the delivery of orders being processed or request information and customer support).
The legal basis for this processing is the performance of a contract to which the data subject is a party pursuant to Article 6(1)(b) of the GDPR.
The personal data will be retained for 10 years from the delivery date of the purchased product.

3.4 To send advertising and marketing communications relating to poltronesofà's and its partners' products, services and events, and to carry out market research and customer satisfaction surveys concerning poltronesofà's products, services and/or events (direct marketing purposes)
Subject to the User's and/or Customer's prior consent, poltronesofà may carry out direct marketing activities relating to promotions and commercial or advertising communications concerning its own products, services and events, as well as initiatives involving its partners, provided that such initiatives are defined and managed by poltronesofà (for example, the opening of new stores). Poltronesofà may also conduct customer satisfaction surveys and market research relating to its products, services and/or events.
For the purpose of sending marketing communications (commercial and promotional communications), poltronesofà may use channels including email, SMS, MMS, chat services, instant messaging applications (including, for example, WhatsApp Business), social media platforms and ordinary mail.
The legal basis for this processing is the data subject's consent pursuant to Article 6(1)(a) of the GDPR.
The personal data will be retained for 8 years from the date on which consent is collected or, if earlier, until consent is withdrawn.
At any time, the User and/or Customer may withdraw their consent by clicking the "unsubscribe" link included in the marketing communications received or by contacting the Controller at: [email protected].

3.5 To carry out statistical analyses on anonymous or aggregated data regarding Users' and/or Customers' interest in poltronesofà's products, services and/or events.
In particular, the Controller carries out this processing in order to improve the customer experience and to develop products and services that better meet customers' needs.
The legal basis for this processing is the Controller's legitimate interests pursuant to Article 6(1)(f) of the GDPR.
The personal data will be retained for 4 years, it being understood that, for these purposes, the Controller processes the data exclusively in an aggregated and anonymised form.

3.6 To analyse and evaluate the User's/Customer's interests, habits, preferences and purchasing behaviour in order to provide updates on products and promotions tailored to the User's/Customer's profile, including through automated means, tracking pixels and the use of online services and/or social media providers such as Google and Meta (profiling purposes).
Subject to the User's and/or Customer's prior consent, poltronesofà may analyse demographic data (e.g. age), contact details (e.g. address), the Customer's interests, purchasing habits and purchasing behaviour (e.g. the date, subject matter and value of purchases made at poltronesofà stores), as well as preferences expressed in relation to the products and services offered by poltronesofà.
In addition, poltronesofà may analyse Users' and Customers' interactions with marketing emails sent by the Company through the use of tracking pixels. These technologies enable poltronesofà to collect information such as whether an email has been opened, the time spent viewing it and the number of times it has subsequently been opened. Such information may be processed using electronic tools capable of aggregating and comparing personal data in order to personalise communications sent to Users and/or Customers, suggest products and services that may be of interest to them and offer access to specific commercial initiatives.
For these purposes, poltronesofà may use online services and/or social media providers (such as Google, Meta and similar providers) to carry out customer targeting activities, create advertising campaigns addressed to individuals sharing characteristics similar to those of its Users and/or Customers (so-called lookalike audiences) or exclude specific Users and/or Customers from certain advertising campaigns. In particular, such services enable poltronesofà to: (i) analyse the personal data shared with them; (ii) segment such data and perform carry out customer matching activities; and (iii) apply algorithms to generate lookalike audiences and deliver targeted advertising through the providers' advertising services.
Under the contractual arrangements entered into with such providers, certain processing activities described above (such as data analysis and customer matching) are carried out by the providers acting as data processors pursuant to Article 28 GDPR. Other processing activities (such as the algorithmic processing required to generate lookalike audiences and the subsequent delivery of targeted advertising) are carried out by the providers acting as independent data controllers. In any event, personal data will be shared with such providers only where the User and/or Customer has provided their prior consent.
Users and Customers may, at any time, modify their preferences and settings relating to processing activities carried out by such providers acting as independent data controllers, or withdraw the consent previously provided, by contacting the Controller at: [email protected].

For further information regarding the processing activities carried out by such providers in their capacity as independent data controllers, Users and Customers are invited to consult the relevant privacy notices available at the following links: Facebook Privacy policy and Google policies.
The legal basis for this processing is the data subject's consent pursuant to Article 6(1)(a) of the GDPR.
Personal data will be retained for 4 years from the date on which consent is collected or, if earlier, until consent is withdrawn. At any time, Users and/or Customers may withdraw their consent by contacting the Controller at: [email protected].

3.7 To send commercial communications related ing to products and services similar to those previously purchased by the Customer (Soft Spam).
Poltronesofà may send promotional, commercial or advertising communications by email concerning products and services similar to those previously purchased by the Customer, unless the Customer objects to receiving such communications. The Customer may object at any time.
The legal basis for this processing, which does not require the Customer's consent, is Article 6(1)(f) of the GDPR, provided that the communications relate to products or services similar to those previously purchased by the Customer and that the Customer, having been duly informed, has not objected to the use of their email address for this purpose, either initially or on the occasion of any subsequent communication.
As a general rule, the relevant personal data will be retained until the Customer objects to the processing.

3.8 To determine the User's and/or Customer's location in order to display the nearest poltronesofà stores on the a map.
Where the User and/or Customer has enabled location sharing through their browser settings, the Controller processes the User's and/or Customer's geolocation data solely for the purpose of displaying the nearest poltronesofà stores on the map.
The legal basis for this processing is the performance of pre-contractual measures or the provision of a service requested by the data subject pursuant to Article 6(1)(b) of the GDPR.
Geolocation data are processed exclusively for the duration of the browsing session or until the User and/or Customer disables the relevant functionality. No geolocation data are retained after the session has ended.
Users and Customers may disable the geolocation function at any time, including temporarily, through their browser settings or the settings of the device used.

3.9 To prevent or pursue unlawful conduct, infringements of rights (including those of third parties), cybercrime or offences committed through electronic communications networks.
The legal basis for this processing is the Controller's legitimate interests pursuant to Article 6(1)(f) of the GDPR.
Personal data will be retained for the period reasonably necessary to enable poltronesofà to establish, exercise or defend its legal rights from the moment it becomes aware of the unlawful conduct or its potential occurrence.

3.10 To comply with legal obligations to which the Controller is subject.
The Controller processes Users' and/or Customers' personal data in order to comply with applicable legal obligations, including administrative and accounting requirements.
The legal basis for this processing is compliance with a legal obligation pursuant to Article 6(1)(c) of the GDPR.
Personal data will be retained for the period required under the applicable laws to enable the Controller to comply with its legal obligations.


4. DATA SUBJECT RIGHTS

Users and Customers may contact poltronesofà at any time (using the contact details provided above or by emailing [email protected]) to exercise the rights provided for under Articles 15 et seq. of the GDPR, as summarised below:
Right of access: You may request information regarding the processing activities carried out by the Controller or confirmation as to whether your personal data are being processed. You may also request a copy of your personal data and verify which personal data are held by the Controller.
Right to rectification: You have the right to request the correction of inaccurate personal data concerning you, as well as the completion of incomplete personal data.
Right to erasure: You have the right to request the deletion of your personal data (or part thereof), including data that are no longer necessary for the purposes for which they were collected or otherwise processed.
Right to restriction of processing: You may request that the Controller restrict the processing of your personal data where the conditions laid down by applicable law are met.
Right to object: You may object to the processing of your personal data, unless the Controller demonstrates compelling legitimate grounds for continuing the processing which override your interests, rights and freedoms.
Right to data portability: You may obtain from the Controller the personal data you have provided, in a structured, commonly used and machine-readable format, and transmit those data to another controller. This right applies where the processing is carried out by automated means and is based on your consent or on the performance of a contract.
Right to withdraw consent: Where processing is based on your consent, you may withdraw such consent at any time. The withdrawal of consent shall not affect the lawfulness of processing carried out before such withdrawal.
Right not to be subject to automated decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This right does not apply where: (i) the processing is necessary for entering into or performing a contract between you and the Controller; (ii) the processing is authorised by applicable law; or (iii) the processing is based on your explicit consent.

The Controller will respond as soon as reasonably possible and, in any event, within no later than 30 days of from receiving the request. Where necessary, poltronesofà may request additional information to verify the identity of the requester.
Without prejudice to any other administrative or judicial remedy available, Users and/or Customers also have the right to lodge a complaint with the competent supervisory authority if they believe that the processing of their personal data infringes the applicable data protection legislation.


5. SHARING OF PERSONAL DATA AND DATA RECIPIENTS

For the purposes described in Section 3 above, the Controller may share Users' and/or Customers' personal data with the following categories of recipients.

5.1 Other companies within the poltronesofà Group for organisational and administrative purposes.

5.2 Service providers acting as Data Processors: the User's and/or Customer's personal data may be disclosed to third parties engaged by the Controller to provide certain services and activities, who process personal data on behalf of the Controller under data processing agreements compliant with Article 28 of the GDPR (including, by way of example, IT and technology service providers, online service and social media providers, communication agencies, analytics providers and similar service providers).
Such recipients will have access only to the personal data necessary to perform the services entrusted to them and may use such data solely for the purpose of providing those services on behalf of poltronesofà or to comply with applicable legal obligations.
An updated list of the Controller's data processors appointed pursuant to Article 28 GDPR is available upon request by contacting [email protected].

5.3 Online service providers and social media providers: subject to the User's and/or Customer's prior consent, poltronesofà may share Users' and/or Customers' personal data with online service providers and/or social media providers (such as Google, Meta and similar providers) for audience targeting and the delivery of advertising campaigns.

5.4 Judicial authorities and public authorities: where permitted or required by law, poltronesofà may disclose personal data to judicial authorities, administrative authorities or other public bodies in order to protect or enforce its rights or the rights of third parties, or to comply with legal obligations.


6. WHERE PERSONAL DATA ARE PROCESSED – INTERNATIONAL DATA TRANSFERS

Users' and Customers' personal data are processed by poltronesofà in Italy.
Such personal data may also be processed in other Member States of the European Union by service providers acting as data processors pursuant to Article 28 GDPR. In addition, certain service providers may be located outside the European Economic Area ("EEA").
In such cases, poltronesofà ensures that any transfer and processing of personal data complies with the GDPR. Personal data will be transferred only where:
• the European Commission has adopted an adequacy decision in respect of the destination country;
• appropriate safeguards are in place, such as the Standard Contractual Clauses approved by the European Commission or Binding Corporate Rules; or
• where neither of the above applies, the transfer is otherwise permitted under the GDPR, including where authorised by the User and/or Customer or necessary for the performance of a contract with, or in the interest of, the User and/or Customer.

Where personal data are transferred outside the European Union, the Controller will provide the information required under Article 13(1)(f) of the GDPR.
Notwithstanding the above, Users and Customers acknowledge and accept that online service providers and social media providers may, acting as independent data controllers within the meaning of Article 4(7) GDPR, transfer personal data to countries outside the EEA.
Users and Customers are therefore encouraged to consult the relevant privacy notices available at the following links: Facebook Privacy Policy and Google Policies.


7. CHANGES TO THIS PRIVACY NOTICE

This Privacy Notice may be amended from time to time to reflect changes in applicable laws, technological developments, changes in the way personal data are collected and processed, or the introduction of new Website features.
Where material changes are made that may significantly affect Users and/or Customers, the Controller will provide appropriate notice using the means it considers most suitable.
Users and Customers are encouraged to review this Privacy Notice periodically to remain informed of any updates.
Any amendments will become effective upon publication on the Website. Continued access to or use of the Website after such publication shall constitute acceptance of the updated Privacy Notice.

Last updated: 15 July 2026