PRIVACY | South Africa

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

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

version of April 27th, 2020

Poltrona Frau S.p.A. has prepared this document (the “Notice”) to describe how it protects your personal data, which is collected automatically or provided through the navigation or use of the website www.poltronafrau.net (the “Website”), including for the purchase of “Poltrona Frau” branded products (the “Products”).

Therefore, this Privacy Notice relates exclusively to the Website and does not relate to other sites, pages, social media sites or online services that can be accessed via hyperlinks that may be published on the Website.

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”), privacy@poltronafraugroup.net.

The Controller has appointed a Data Protection Officer (“DPO), who can be contacted at the following address: dpo.poltronafrau@dpoprofessionalservice.it.

2. TYPE OF DATA PROCESSED AND WHEN

The Controller will collect and process your personal data (the “Data”) on the following occasions:

- Product purchases on the Website (including, for example, delivery, invoicing, etc.) and management of related after-sales services (for example, returns, refunds, repairs): email, first name, surname, address, telephone number, billing/shipping address, company name, tax code, VAT number, and personal data that may be communicated in the appropriate fields;

- Your registration/access to one of the “Architect/Designer”, “Dealer” and “Customer” reserved areas of the Website and use of the related services: first name, surname, email, password, country and region;

- Requests made to the Call Centre: the personal data communicated to provide the requested support;

- Any other requests sent through the “Contacts” page of the Website, including requests for information and/or bookings for visits to the Poltrona Frau Museum: first name, surname, email, category (individual/professional), company/publication, address, country, date and time of visit, type of group, number of participants, and personal data that may be communicated in the appropriate fields or through the dedicated Poltrona Frau email box;

- Receipt of marketing information or information about collections, exhibitions and events and your potential participation in customer satisfaction surveys and market research for Product improvement purposes from both the Controller and other companies belonging to the same Group: first name, surname, email, category (individual/professional). These communications will be sent by email or telephone, including by automated means (SMS, social media);

- Classification of Website users based on the following parameters, for the purpose of sending the customised communications and newsletters referred to in the previous point: country of residence, age group, category (individual/professional), value, frequency and channels for the purchase of the Products;

- Receipt of communications containing marketing offers related to Products similar to those already purchased (soft spam): email.

Navigation data

These data, required in order to use the Website, are processed solely to obtain statistical information on the use of the Website services (most visited pages, number of visitors per hour or per day, geographical areas of origin, etc.) and to check the proper functioning of the Website itself and of the services offered through it.

This category of data includes: log files, IP addresses, user terminal domain names, uniform resource identifier (uri) notation addresses, server request times and methods, server responses, other operating system parameters, and the IT environment used by each Website user.

Navigation data are not stored for more than 7 days and are deleted immediately after their aggregation, without prejudice to the potential need for the Judicial Authority to investigate crimes.

During navigation, Poltrona Frau also collects cookies (small text files containing a certain amount of information exchanged between the Website and the browser).

To find out how Poltrona Frau manages cookies, visit the Cookie Policy.

Call Centre

Any telephone calls made to the Call Centre number specified on the Website may involve the processing of the Data you provided on that occasion, in order to respond to your requests.

Poltrona Frau may use third-party call centres that operate, always in full compliance with the privacy regulations, through a special service contract on behalf of the Controller, and as Data Processors under Article 28 of the GDPR.

3. PURPOSE AND LEGAL BASIS OF THE PROCESSING – MANDATORY OR OPTIONAL DATA

A) To sell products through the Website (including, for example, delivery, invoicing, etc.) and manage after-sales services (for example, returns, refunds, repairs, etc.).

The legal basis of the processing is the performance of pre-contractual and contractual obligations that you are a part of, as well as compliance with legal obligations.

The provision of your Data for this purpose is mandatory and, in the absence of such Data, Poltrona Frau will not be able proceed with the corresponding order or to manage the related Product after-sales services.

B) To allow you to register and access one of the “Architect/Designer”, “Dealer” and “Customer” reserved areas of the Website and use the related services.

The legal basis of the processing is the performance of pre-contractual and contractual obligations that you are a part of, as well as compliance with legal obligations.

The provision of Data for this purpose is optional. If you do not wish to provide your Data, you will not be able to use the related services in the reserved areas of the Website.

C) Manage requests made to the Call Centre.

The legal basis of the processing is the performance of pre-contractual and contractual obligations that you are a part of, as well as compliance with legal obligations.

The provision of your Data for this purpose is optional. However, if you do not provide these Data, it will not be possible for Poltrona Frau to process your requests to our Call Centre.

D) Management of contact requests through the relevant page of the Website, including requests for information and/or bookings for the Poltrona Frau Museum.

The legal basis of the processing is the performance of pre-contractual and contractual obligations that you are a part of, as well as compliance with legal obligations.

The provision of your Data for this purpose is optional. However, if you do not provide these Data, it will not be possible for Poltrona Frau to process your requests and/or bookings for visits to the Poltrona Frau Museum sent via the Website.

E) To send you marketing information about collections, exhibitions and events, including through our newsletter, or allow you to participate in any customer satisfaction surveys and market research for the improvement of the Products.

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 privacy@poltronafraugroup.net.

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 privacy@poltronafraugroup.net.

F) To communicate your Data to other companies of the Group that Poltrona Frau belongs to, so that they can send you marketing information about collections, exhibitions and events, including through newsletters in relation to its products and services, and to participate in any customer satisfaction surveys and market research for the improvement of its Products.

The provision of Data for this purpose is optional. If you do not wish to provide your Data, Poltrona Frau will not be able to communicate the Data to the other Group companies for such purposes.

G) Classification of Website users based on a series of parameters, for the purpose of sending the customised communications and newsletters.

The legal basis is the legitimate interest of the Controller in achieving the maximum efficiency of its marketing activities.

We will send promotional communications taking your preferences into account only with your prior consent, which may be withdrawn at any time unconditionally. You can exercise your right to oppose the receipt of these communications at any time, immediately or at a later date, by clicking the unsubscribe button contained in the emails or newsletters you receive or by writing to privacy@poltronafraugroup.net.

H) The sending of communications containing marketing offers related to Products similar to those already purchased (soft spam).

The legal basis is Poltrona Frau’s legitimate interest in developing relationships with its customers and increasing the volume of requests and sales of the Products.

You can exercise your right to oppose the receipt of these communications at any time, immediately or at a later date, by clicking the unsubscribe button contained in the emails or newsletters you receive or by writing to privacy@poltronafraugroup.net.

4. DATA STORAGE PERIOD

- Poltrona Frau undertakes to delete your Data from its systems provided for the execution of the sale and management of the after-sales services and for making bookings for visits to the Poltrona Frau Museum, 10 years after the date of the last purchase/booking or since the last interaction with the Controller.

- Poltrona Frau undertakes to delete your Data from its systems provided in relation to the requests submitted to the Call Centre or through the Website, 1 year after the date of provision of the Data;

- Poltrona Frau undertakes to delete your Data from its systems provided for your registration and access to the “Architect/Designer”, “Dealer” and “Customer” reserved areas of the Website and for use of the related services, 10 years after the date of cancellation of the relevant registration on the Website;

- Poltrona Frau will delete the Data processed in order to send you marketing information, including customised information following classification based on the parameters described above, about collections, exhibitions and events, as well as for the participation in customer satisfaction surveys and market research, 5 years after the collection of the Data, or until you object. In any case, the Data will be kept for 10 years for the purposes of sales management and after-sales services;

- Poltrona Frau will delete the Data processed for the purposes of sending communications containing marketing offers related to Products similar to those already purchased (soft spam), 24 months after the date of each purchase, without prejudice to their storage for 10 years for the purposes of executing the sale and the management of after-sales services.

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.

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.

5. 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.

6. AUTOMATED DECISION-MAKING PROCESSES

As indicated above, Poltrona Frau classifies its Website users in order to send customised information of a marketing nature about collections, exhibitions and events.

This procedure is carried out by dividing the data subjects according to minimally invasive categories, such as country of residence, age group, category (individual/professional), value, frequency and channels for the purchase of the Products.

Following this analysis, which can also be carried out in automated form, the user can be classified in one or more groups with different characteristics and receive from Poltrona Frau customised communications that Poltrona Frau believes are in line with the user’s tastes and preferences.

In relation to this processing, Poltrona Frau has successfully conducted a balancing test in order to determine that the processing linked to the classification in question is carried out on the legal basis of the legitimate interest of the Controller in achieving maximum efficiency in its marketing activities.

7. PERSONS AUTHORIZED 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.

8. 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 privacy@poltronafraugroup.net):

- Companies within the same Group as Poltrona Frau for the sending of marketing information about collections, exhibitions and events by the above companies in relation to their products and services;

- Companies within the same Group as Poltrona Frau for administrative and accounting purposes;

- 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, banking operators, electronic payment carriers, credit card issuers, internet providers, couriers and shipping agents, 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.

9. 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

10. 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 privacy@poltronafraugroup.net, 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.

The User also has the right to make a complaint to the Supervisory Authority, i.e. to 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 also has the right to object at any time to the processing of the Data, immediately or after the transfer of the Data, in relation to the sending by the Controller of unsolicited communications containing marketing offers related to Products similar to those already purchased (soft spam) directly to the email address provided during the purchase of Products, pursuant to art. 130, paragraph 4 of Italian Legislative Decree no. 196/2003, as amended by Italian Legislative Decree no. 101/2018.

You can also choose to be contacted for marketing purposes exclusively via traditional methods, expressing your opposition to receiving communications through automated methods.

11. MINORS

The Website and the Products offered therein 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 event that personal data relating to minors are entered on the Website, Poltrona Frau will delete them.

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If you would like to submit your application for a job with Poltrona Frau, your Data will be processed in accordance with the relevant privacy notice, available at the following link: CAREERS

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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.