Privacy information for Users

Fratelli Leo S.r.l., with registered office in Strada del Drosso, 39 - 10135 Turin, VAT no./C.F. 11867770015 and registration number in the Turin Company Register 11867770015, paid-up share capital €10,000.00, as independent owners  of the treatment of personal data of users (hereinafter, the "Users”) who browse and use the services available on the website www.fratellileo.com (hereinafter, the “Site"i i"Services”) provide below the privacy information pursuant to art. 13 of EU Regulation 2016/679 of 27 April 2016 (hereinafter, "Regulation”, or even the “Applicable Law”).

This Site and the Services are reserved for individuals who have reached the age of eighteen. The Data Controllers therefore do not collect personal data relating to persons under the age of 18. At the request of the Users, the Data Controllers will promptly delete all personal data involuntarily collected and relating to persons under the age of 18.

The Owners take the utmost account of the right to privacy and protection of personal data of their Users. For any information in relation to this privacy statement, Users can contact the Owners at any time, using the following methods:

• By sending a registered letter with return receipt to the registered office of the Data Controller Fratelli Leo Srl (Strada del Drosso 39, 10135, Turin);
• By sending an e-mail message to info@fratellileo.com.

Fratelli Leo srl has not identified the figure of the Data Protection Officer (RPD or DPO), as it is not subject to the designation obligation set forth in art. 37 of the Regulation.

1. Purpose of the treatment

• Users' personal data will be processed lawfully by Fratelli Leo srl pursuant to art. 6 of the Regulation for the following processing purposes:

1. contractual obligations and provision of the Services:

• To allow the use of the Services, including but not limited to the purchase of products, the shipment of the purchased products, manage any returns of the purchased products: the data processed are the name, surname, shipping address, email address, as well as any personal information of the User possibly and voluntarily communicated, for example in the case of a return note;
• For the management of any requests received through the customer service and/or the Site: the data processed are name, surname, e-mail address, and other data that may be necessary depending on the circumstance (for example the order number ; address, etc.).

The User's personal data will be used by Fratelli Leo for this purpose exclusive to ascertain the User's identity (also by validating the e-mail address), thus avoiding possible scams or abuses, and to contact the User for service reasons only (e.g. send notifications relating to the Services) and/or manage orders and requests as indicated above. Without prejudice to the provisions elsewhere in this privacy statement, in no case Fratelli Leo will make the Users' personal data accessible to other Users and/or third parties.

The legal basis on which the treatment is based is the need to give execution of pre-contractual and contractual obligations of which the User is a part. The provision of personal data for the processing purposes indicated above is optional, but necessary, since failure to provide them will make it impossible for the User to use the Services and purchase the Products on the Site or receive after-sales assistance.

1. administrative-accounting purposes, or to carry out activities of an organisational, administrative, financial and accounting nature, such as internal organizational activities and activities functional to the fulfillment of contractual and pre-contractual obligations, by way of example, issuing purchase receipts and/or invoices;

The legal basis on which the treatment is based is the need to give execution of pre-contractual and contractual obligations of which the User is a part, in addition to the need to fulfill legal obligations. The provision of personal data for the processing purposes indicated above is mandatory to finalize orders and to comply with legal obligations.

1. legal purposes, or to fulfill obligations established by law, by an authority, by a regulation or by European legislation.

The legal basis on which the treatment is based is the need to fulfill legal obligations. The provision of personal data for the processing purposes indicated above is mandatory.

• Users' personal data will be processed lawfully dal Partner pursuant to art. 6 of the Regulation for the following processing purposes:

1. contractual obligations and provision of the Services:

• to allow navigation of the Site: the data processed are the IP address and log data;
• to allow the user to register on the Site and implement the Conditions of Use of the Site, which are accepted by the User during registration: the data processed are: name, surname, date of birth (not mandatory), the province of residence/domicile, the email address;

The legal basis on which the treatment is based is the need to give execution of pre-contractual and contractual obligations of which the User is a part. The provision of personal data for the processing purposes indicated above is optional, but necessary, since failure to provide them will make it impossible for the User to navigate the site, register on the Site and use the Services.

1. marketing purposes, previous free and optional consent of the User, i.e. for sending information and communications of a commercial nature or information on products, Services and events and participation in customer satisfaction surveys and market research for the improvement of the Services, also by sending periodic newsletters : the data processed are name, surname, email as well as the date of birth which will be used, for example, to send you greetings and/or promotions dedicated to your birthday or based on the reference age range.

The legal basis is the explicit consent of the User to the processing of data for this purpose. The provision of data for this purpose is optional. In case of lack of consent, the possibility of registering on the Site will not be affected in any way.

In the event of consent, the User may revoke it at any time by making a request to the Partner in the manner indicated in paragraph 6 below.

The User can also easily oppose further sending of promotional communications via email by clicking on the appropriate link for the withdrawal of consent, which is present in each promotional email. Once the consent has been revoked, the Partner will send the User an e-mail message to confirm that the consent has been revoked.

The Partner informs that, following the exercise of the right to oppose the sending of promotional communications via email, it is possible that, for technical and operational reasons (e.g. formation of contact lists already completed shortly before receipt by the Partner of the opposition request) the User continues to receive some further promotional messages on the same day in which he exercised his right. If the User should continue to receive promotional messages after 24 hours have passed from the exercise of the right to object, please report the problem to the Partner, using the contacts indicated in paragraph 6 below.

1. legal purposes, or to fulfill obligations established by law, by an authority, by a regulation or by European legislation.

The legal basis on which the treatment is based is the need to fulfill legal obligations. The provision of personal data for the processing purposes indicated above is mandatory.

2. Methods of treatment

The Data Controllers will process the Users' personal data using manual and IT tools, with logic strictly related to the purposes themselves and, in any case, in such a way as to guarantee the security and confidentiality of the data. 

3. Data retention times

Users' personal data will be kept for the time strictly necessary to carry out the primary purposes illustrated in paragraph 1 above, or in any case according to the provisions of the law / or necessary for the protection in civil law of the interests of both Users and Owners.

In particular, Fratelli Leo undertakes to delete the data provided from its systems:

• for the execution of the sale and the management of the Services, including after-sales services after 10 years from the date of the last purchase or from the last interaction with Fratelli Leo;
• the data provided in relation to requests forwarded through the customer service or the Website after 10 years from the date of the provision;

The Partner undertakes to delete from its systems:        

• the data provided for registration on the Site after 10 years from the date of cancellation of the relative registration on the Site;
• the data processed in order to send information of a commercial nature as well as for participation in customer satisfaction surveys and market research, after 5 years from the collection of the data, or until any objection.

In any case, each Data Controller undertakes to inspire the processing of data on the principles of adequacy and minimization, verifying annually the need to keep them for a period of time no longer than what is necessary to achieve the purposes for which the data were collected and treated.

Each Data Controller may keep the data to fulfill regulatory obligations, or to ascertain, exercise or defend a right in court.

Once the purposes for which the data were collected and processed have been achieved, each Data Controller will take the appropriate measures to make them anonymous, so as to prevent your identification, in any case without prejudice to the possibility of continuing to use the data anonymously.

4. Scope of communication and dissemination of data

The personal data of the Users, the employees and/or collaborators of the Owners in charge of managing the Site and all the services connected to the provision of the Services, including marketing activities, may become aware of. These subjects, who have been instructed to do so by the Data Controllers pursuant to Article 29 of the Regulation, will process the Users' data exclusively for the purposes indicated in this information and in compliance with the provisions of the Applicable Regulations. 

The personal data of the Users may also be disclosed to third parties who may process personal data on behalf of the Data Controllers as "Data Processors", such as, by way of example, IT and logistics service providers functional to the operation of the Site and /or of the Services, outsourced, hosting or cloud computing service providers, professionals and consultants of each Owner.

Users have the right to obtain a list of any data processors appointed respectively by each Data Controller, by making a request to the Data Controller concerned in the manner indicated in paragraph 6 below.

Furthermore, the personal data of Users may be communicated by Fratelli Leo, to the extent that this is necessary and essential to give execution of contractual obligations, to independent third party data controllers, such as payment service managers and logistics services necessary for the delivery of goods sold through the Site. These independent data controllers will process the User's data exclusively for the purpose of correctly fulfilling orders relating to the Services.

5. Transfer of personal data to third countries

The entire data processing takes place in Italy, in the countries of the European Union, in Canada and, in some cases, in the United States.

Should there be a need to transfer the data to further Third Countries, each Data Controller undertakes to:

• Make sure that the country to which the data will be sent guarantees an adequate level of protection, as required by Article 45 of the 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.

6. Rights of the interested parties

Users will be able to exercise the rights guaranteed to them by the Applicable Regulations by contacting the Owners in the following ways: 

• By sending a registered letter with return receipt to the registered office of the Data Controllers
• By sending an email to the address info@fratellileo.com

Fratelli Leo srl will comply with the requests of the Users relating to the treatments of which they are the Owners.

Pursuant to the Applicable Regulations, the Data Controllers inform that Users have the right to obtain the indication (i) of the origin of personal data; (ii) the purposes and methods of processing; (iii) of the logic applied in case of treatment carried out with the aid of electronic instruments; (iv) of the identification details of the Owners and managers; (v) of the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as managers or agents. 

Furthermore, Users have the right to obtain:

1. to the'access, l'update, the rectification or, when they are interested, theintegration some data;
2. b) no cancellation, the anonymous transformation or the block data processed in violation of the law, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;
3. c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfillment is proves impossible or involves the use of means manifestly disproportionate to the protected right.

Furthermore, Users have:

1. a) the right to withdraw consent at any time, if the treatment is based on their consent;
2. b) (where applicable) the right to data portability (right to receive all personal data concerning them in a structured format, commonly used and readable by an automatic device), the right to limitation of the treatment of personal data and the right to cancellation (“right to be forgotten”);
3. c) he right to object:
4. i) in whole or in part, for legitimate reasons, to the processing of personal data concerning them, even if pertinent to the purpose of the collection;
5. ii) in whole or in part, to the processing of personal data concerning them for the purpose of sending advertising materials or direct sales or for carrying out market research or commercial communication;

iii) if personal data are processed for direct marketing purposes, at any time, to the processing of their data carried out for this purpose, including profiling insofar as it is connected to such direct marketing.

1. d) if they believe that the processing that concerns them violates the Regulation, the right to lodge a complaint with a Supervisory Authority (in the Member State in which they habitually reside, in the one in which they work or in the one in which the alleged infringement has occurred). The Italian Supervisory Authority is the Guarantor for the protection of personal data, with headquarters in Piazza Venezia n. 11 - 00187 – Rome (http://www.garanteprivacy.it/).

The Owners are not responsible for updating all the links that can be viewed in this Information, therefore whenever a link is not functional and/or updated, Users acknowledge and accept that they must always refer to the document and/or section of the websites referred to by this link. 

Fratelli Leo s.r.l.
Registered office: in Strada del Drosso, 39, 10135 Turin
Tel. +39 011 0746033
VAT number, tax code and membership number
in the Turin Company Register: IT11867770015
REA TO-1246882

none I am. €10,000.00 VAT