Privacy Policy
Privacy Policy
Last updated: July 2024
About Serapian
Stefano Serapian S.r.l. (“Serapian”, "we", "us" and "our") has its registered offices at Benigno Crespi 26, 20159 Milano. This is considered to be the “data controller” for the purposes of certain data protection laws and regulations.
Our Privacy Commitments
Our Privacy Policy is centred around the following three privacy commitments:
Commitment 1: Transparency & Trust - Privacy is built into all of our products and services by design and by default. We respect the trust you place in us with your personal information. We will be fully transparent with you regarding the purposes for which we use your personal information and will only use it for those specified purposes when we have a right to do so. This will include, where necessary, obtaining your explicit consent. Any material changes to how we process your personal information will be notified to you.
Commitment 2: Protecting Your Personal information - We commit to implementing leading data protection, privacy and security standards so that you feel comfortable that your personal information is protected – if there is an incident impacting your personal information, we commit to notifying you and/or relevant regulators in accordance with data breach notification requirements. Your personal information will be handled with the same protection when it is shared with third parties or when it is transferred internationally. We will only retain your personal information for as long as is necessary or for as long as required by law.
Commitment 3: Respecting Your Rights - We will respect the choices you make in relation to your personal information. We will respect the legal rights you have in relation to accessing, erasing and updating the personal information that we hold about you. We will also respect the choices you make in relation to objecting to how we process your personal information and will provide channels for you to contact us with questions or complaints.
This Privacy Policy & Updates
Please take a moment to read the following policy as well as our Cookie Policy that explains how we collect, use, disclose and transfer the personal information collected about you at any touchpoint, including on our websites, mobile applications and other digital platforms (together referred to as the “Platforms”), when you visit our boutiques or events, contact us by e-mail, telephone or online chat, or when you interact with us over social media platforms or other marketing and advertising channels. Our Cookie Policy explains how we collect information through the use of cookies and related technologies when you use our Platforms.
Where we offer our products for sale online or by phone through our Client Relations Center, you must read the applicable Conditions of Sale, which will govern the terms and conditions of any such purchases made in this way. Other terms and conditions, such as Conditions of Service, may also apply in respect of any other services that we may provide to you.
From time to time we may update this Privacy Policy. When we do, we will publish the changes on this Platform.
Commitment 1: Transparency & Trust
Information that you provide to us or we collect about you
We collect the following personal information about you as detailed below:
General personal & user account information: To benefit from our products, services, events, boutique appointments and/or other client programmes, you may need to provide your contact details or create an account with us. You may provide personal information about yourself, including name and address, date of birth, e-mail address, telephone number, marital status, nationality and gender. Your account will store information about yourself, your purchasing history, unique account identification number, username, password, time zone, claims and repair history, as well as any conversation history.
Client 360 view data: In order to have a full understanding of our clients, we may also collect and store data about your behaviour, interests, preferences (such as products, topics, and channel and frequency of communication), wish lists, hobbies, client interactions and marketing campaign activities, opinions, customer reviews, demographic data, habits, celebration events, purchasing reviews and feedback as well as your general purchasing tendencies.
Transactional and payment information: When you purchase products and/or services, we collect additional information, such as your shipping address, proof of delivery, billing address and relevant payment information.
Identification information: We may collect identification information from you, such as passport data or national ID data, in circumstances where we need this to provide products and/or services to you.
Correspondence, call recordings, online or video chat: We collect personal information from you when you correspond with us (for example, if you contact us with a query about one of our products and/or services), when you provide your details when you visit our boutiques, contact us or our Client Relations Center by e-mail, telephone, contact form or otherwise participate in online or video chat. Please note that phone calls, online or video chat or other correspondence will on occasion be recorded for security, evidence, training, quality control, analysis and development purposes.
Social media platforms data: If you choose to interact with us via a social media platform or other third party service, we will collect the information you have provided to us through that platform, which may include behavioural data such as your browsing records and purchase history on that platform. In addition, you may grant us access to certain data from your social media profiles for social log-in purposes.
Cookie data: We also collect certain information automatically about visitors to our Platforms, described in our Cookie Policy. This may include data relating to advertising IDs, pixel tags or your unique online personal identifier.
Location data: We will collect information about your location to the extent that we provide any location services.
CCTV, video surveillance data & Wi-Fi data: In our retail boutiques, corporate premises or other areas, we collect data using CCTV or other video surveillance technology. If you register for our free Wi-Fi service at our stores, events or other premises, we may collect certain information about your device, including device or IP address, connection date and time and the location(s) at which you connected to our Wi-Fi service.
Photos & video recordings: Some of our technology products, including connected mirrors, augmented reality technologies or photo booths, collect photographs or video recordings from you. This data may also allow us to take measurements from you required for our products and/or services. We may also take photographs or make video or voice recordings of you at one of our events.
Surveys and market research: We carry out surveys and market research and we will collect your response data.
Information you provide about third parties: You may provide personal information about a third party (such as your partner or child), including name and address, date of birth, e-mail address, telephone number, marital status, wish list, hobbies and preferences.
Information we collect from third parties about you: We also may collect any of the above information about you from third parties, including our authorised dealers, social media platforms, advertising and marketing partners, analytics providers, and third parties that provide technical or strategic data services to us and we may collate such information with other information that we have. We may also collect personal information about you from publicly-available sources.
Sensitive or special categories of data: We may ask you to provide sensitive or special categories of data (for example, allergens or accessibility requirements for events), in which case we will provide you with enhanced privacy information and ask for your explicit consent at the time of our request. Otherwise, if you provide such data to us without us asking you for it, we will take the fact you have provided such data as your explicit consent for us to process it.
Purposes of processing and our legal justification for processing
We may process your personal information for the purposes listed below on the basis of the following justifications:
Consent: this is the legal basis when you have given clear consent for us to process your personal information (for example, where you consent to receiving marketing information).
Performance of a contract: the processing is necessary for a contract we are entering into with you (including compliance with our Terms of Use), or because we have asked you to take specific steps before entering into a contract (for example, processing your contact information relating to the purchase and delivery of a product).
Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party (for example, for the running of our business, protecting against fraud, or Platform security), unless there is a good reason to protect your personal information which overrides those legitimate interests.
Legal obligation: the processing is necessary for us to comply with the law (for example, a court order).
Other grounds: the processing may on occasion be necessary for other legal reasons such as to prevent and detect crime, to protect life or the processing is otherwise in the public interest.
The purposes of processing and justifications are as follows:
Service-related processing: We process your personal information for service-related purposes, including product reservations and sales, service communications, programme updates, announcements and administrative messages, such as acknowledgment and confirmation of, or changes to, orders and shipment, confirmation of, or changes to, event or appointment bookings, repair notifications as well as to notify you about changes to our terms or privacy policy. In addition, we may send you service-related messages when you abandon your shopping cart or browsing session unexpectedly – our primary justification is for the performance of a contract but we may also rely on legitimate interests (for example, to ensure you are content with your purchase and that we are providing our products and services to you in a secure, effective and efficient manner), legal obligation or consent.
Marketing-related communications and digital advertising: We process your personal information for marketing-related purposes, including sending you marketing communications (including by telephone,
e-mail, post and electronic or text messages, including WhatsApp or other one-to-one communications, and delivering personalised messages or advertising on social media or other digital platforms) relating to us and other third party partners that we think may be of interest to you. We may also share your personal information (such as your e-mail address, usually in an encrypted or ‘hashed’ form, or specific cookie data) with social media and other platforms or other service providers for the purposes of custom audience or lookalike matching, or intra-group client/prospect matching for marketing purposes – our primary justification for marketing-related communications and digital advertising processing is either consent or legitimate interests (for example, to recommend certain products to you). Where we rely on consent, you may withdraw your consent at any time by e-mailing the address below in the section headed “Contact us” or clicking on the ‘unsubscribe’ link in any marketing e-mails or text messages. Where we request your consent at multiple touchpoints (for example, in-store or on the Platforms) and at different times, any consent collected will remain valid unless you expressly opt-out.
Accounts & records: We process your personal information for the purposes of managing our accounts and records – our primary justification is for the performance of a contract but we may also rely on consent, legitimate interests (for example, to prevent fraud) or legal obligation.
Logistics, transactional and payment processing: We process your personal information for the purposes of managing and fulfilling purchase, gift and repair orders or returns, communications preferences during repairs, facilitating delivery, and providing after-sales services – our primary justification is for the performance of a contract but we may also rely on legitimate interests (for example, to ensure we are collecting payments effectively), legal obligation or consent.
Enquiries: We process your personal information for the purposes of dealing with your enquiries and requests, and offering client services to you – our primary justification is for the performance of a contract but we may also rely on legitimate interests (for example, to respond to your queries in an effective manner) or consent.
Events, appointments and communities: We process your personal information for the purposes of organising and running events, boutique appointments and membership communities, including registering you as a member, attendee or speaker, or reporting or logging a health and safety incident that you may have suffered or assisted with. We may also take photographs or make video or voice recordings of you at one of our events for promotional purposes – our primary justification is for the performance of a contract but we may also rely on consent, legitimate interests (for example, to respond to your queries or to manage and administer events) or legal obligation.
Competitions, prize draws and other promotions: We process your personal information for the purposes of running competitions, prize draws, and other promotions, and we need to collect information from you to administer such promotions – our primary justification is for the performance of a contract but we may also rely on legitimate interests (for example, to track client engagement), legal obligation or consent.
Regulatory compliance, credit checking and prevention of prohibited activities: We process your personal information for the purposes of undertaking anti-money laundering or international sanctions compliance, credit checking, prevention of fraud and other prohibited or illegal activities as part of our efforts to keep our Platforms and services secure or as otherwise required to respond to a legitimate request from a third party (for example, a regulatory or police authority or financial institution) – our primary justification is legitimate interests (for example, to prevent fraud or other crime) but we may also rely on legal obligation or consent. We reserve our rights not to provide products and/or services to you where we have a legitimate reason not to do so in accordance with applicable law.
Automated technologies & profiling: We process your personal information as part of our use of innovative technologies, including profiling technologies, artificial intelligence, machine learning and advanced algorithms, to help us identify and predict any products, diagnostics, services or other information that may be of interest to you based on the information that you provide to us or we collect from third parties (as detailed in the section ”Information we collect from third parties about you”). This may lead to automated decisions about you being taken using technology without human involvement. It may include decisions regarding our products, services, event invitations, personal benefits and other information. The purpose is to improve your experience of our products and/or services by way of offering you tailored products and/or services, and being able to respond effectively and swiftly to your feedback. This may involve, for example, techniques used to predict your behaviour and may include data clustering, data mining, data fusion or other data intelligence methods used to extract value and meaning from your personal information. This may be completely automated (such as to escalate complaints) or involve human intervention where the final decision is taken by an individual. When we use your personal information for any automated decisions and/or profiling, we will take steps to be transparent and fair and to make decisions free from bias. We will implement reasonable safeguards designed to protect any of your personal information. In certain circumstances, we will provide you with an opportunity to opt-out of automated decisions and/or profiling – our primary justification is legitimate interests (for example, to improve our Client Relations Center training) and consent.
Market research, analysis of feedback and client engagement: We process your personal information for the purposes of conducting market research (including surveys) and analysis and improve consumer engagement as a result of client feedback, comments, preferences and general use of our Platforms, products and/or services so that we can continuously improve our offerings and the products and/or services we provide to our clients – our primary justification is legitimate interests (for example, to improve our Platforms) but we may also rely on consent.
Location services: We process your personal information for the purposes of providing you with location-based services when we are able to use information about your location. For these services, which are typically available on mobile devices or applications, you are provided with the opportunity to provide your consent to the use of location services, which, for example, process information deriving from GPS, sensors, beacons or Wi-Fi access points in order to allow you to benefit from a more personalised service. Your device will have settings that allow you to turn off these services should you no longer wish to benefit from them – our primary justification is consent.
CCTV, video surveillance & WiFi processing: We process your personal information using CCTV and video surveillance data for the prevention and detection of crime, assisting law enforcement agencies in the apprehension, investigation and prosecution of offenders, ensuring the safety of our staff, visitors and property and, occasionally, to monitor in-store activity or WiFi browsing – our primary justification is legitimate interests (for example, to secure our premises) and legal obligation but we may also rely on consent.
New retail technologies: We may process your personal information for the purposes of our use of new retail technologies to provide you with enhanced in-store and online experiences, including virtual try-ons, augmented reality and product configurators. For example, we may use images or videos of your hand to generate and send you a photograph or a video clip showing product(s) on your hand – our primary justification is both legitimate interests (for example, to monitor client engagement with new technologies) and consent.
Platform support, maintenance and security: We process your personal information in connection with administering and protecting our business and the Platforms (including troubleshooting, dealing with error messages, data analysis, testing, system maintenance, support, reporting and hosting of data) – our primary justification is legitimate interests (for example, to ensure our Platforms run effectively and securely) but we may also rely on legal obligation or consent.
Receipt of products and services from suppliers: We process your personal information for the purposes of benefiting from any products or services provided by you or your organisation, where you are, or your organisation is, a supplier – our primary justification is performance of a contract but we may also rely on legitimate interests (for example, to receive services) or consent.
Business administration and legal compliance: We process your personal information for the purposes of the administration of our business or to comply with our legal obligations – our primary justification is legal obligation but we may also rely on legitimate interests (for example, to maintain our records) or consent.
Enable a corporate transaction such as a merger or acquisition: We process your personal information for the purposes of any merger or acquisition activity and we will disclose your personal information to any third party that purchases, or to which we transfer, all or substantially all of our assets and business – our primary justification is legitimate interests (for example, to facilitate discussions with third party stakeholders) but we may also rely on legal obligation or consent.
Cookie and other automated technologies: We process your personal information in accordance with our Cookie Policy – our primary justification is consent, performance of a contract and legitimate interests (for example, where cookies are strictly necessary).
Material changes
Where we materially change the way in which we process your personal information, or if we plan to use your personal information for a new purpose not set out in the section above, we will take the appropriate measures required under applicable law, such as to notify you by e-mail or other suitable means.
Our Cookie Policy
This Platform uses cookies according to our Cookie Policy. This Cookie Policy is available to users on each page of the website linked to this Privacy Policy and on each information banner regarding cookies.
Like most platforms, our Platforms log IP addresses and use cookies and similar technologies that allow us to recognise you and to customise your experience, and provide us with information about the way our visitors access our Platforms. You can find out more about how we use cookies and related technologies below.
What is a cookie?
Cookies are text files, containing small amounts of information, which are downloaded to your computer or mobile device when you visit a website or mobile application. They are used to recognise your computer as you move between pages on a website, or when you return to a website or mobile application you have visited previously. Cookies are widely used in order to make platforms work, or to work more efficiently, as well as to provide information to the owners of the platform.
We use cookies to enhance the online experience of our visitors (for example, by remembering your language and/or product preferences) and to better understand how our Platforms are used. Cookies will tell us, for example, whether you have visited our Platforms before or whether you are a new visitor. They can also help to ensure that adverts you see online are more relevant to you and your interests.
There are two broad categories of cookies:
First party cookies, served directly by us to your computer or mobile device. They are used only by us to recognise your computer or mobile device when it revisits our Platforms.
Third party cookies, which are served by a third party service provider on our Platforms, and can be used by the service provider to recognise your computer or mobile device when it visits other platforms. Third party cookies are most commonly used for platform analytics or advertising purposes.
Cookies can remain on your computer or mobile device for different periods of time. We use both 'session cookies' and ‘persistent cookies’. Session cookies exist only while your browser is open and are deleted automatically once you close your browser. Persistent cookies survive after your browser is closed, and can be used to recognise your computer or mobile device when you open your browser and browse the internet again.
What cookies do we use?
The Platform serves only the following types of cookies to your computer or mobile device for the following purposes:
Technical Cookies: These cookies are essential to provide you with services available through this Platform and to use some of its features, such as access to secure areas. Without these cookies, services you have asked for, like transactional pages and secure login accounts, would not be possible.
Functionality Cookies: These cookies serve a variety of purposes related to the presentation, performance and functionality of this Platform. Their overall purpose, however, is to enhance visitors’ experience and enjoyment of this Platform. For example, some of these cookies enable visitors to specify language, product or other platform preferences.
Analytical Cookies: These cookies, including those from third parties (such as Google Analytics), are used to collect information about how visitors use our Platforms. This information includes the number of visitors to our Platforms, the platforms that referred them to our Platforms and the pages that they visited on our Platforms. We use this information to help run our Platforms more efficiently, to gather broad demographic information and to monitor the level of activity on our Platforms.
Advertising Cookies: These cookies, including those from third parties, are aimed at creating profiles related to you and are used to deliver adverts more relevant to you and your interests in line with your preferences expressed while surfing the web. They are also used to limit the number of times you see an advertisement as well as help to evaluate the effectiveness of advertising and promotion. They are usually placed by advertising networks with our permission. They remember that you have visited a platform and this information is shared with other organisations such as advertisers, social media platforms or our display partners.
Social Cookies: These cookies are third party cookies that allow you to interact with social media platforms (e.g. share or like buttons).
How to control or delete cookies
The use of cookies does not always require your express consent. In particular, technical cookies do not require such consent as far as they are necessary to provide a service expressly requested by the user. On the other hand, your prior consent is required for functionality cookies, analytical cookies, advertising cookies and social cookies.
You have the right to withdraw your consent and refuse the use of cookies at any time and we have explained how you can exercise this right below. However, please note that if you choose to refuse cookies you may not be able to use the full functionality of our Platforms.
You can set your cookie preferences by changing your browser settings so that cookies from this Platform cannot be placed on your computer or mobile device. In order to do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” facility).
If you would like to learn more, please visit http://www.aboutads.info/choices/ and/or https://globalprivacycontrol.org/. More detail on how businesses use cookies is available at www.allaboutcookies.org. We are not responsible for effectiveness of or compliance with any third parties’ opt-out options.
Third Party Vendors & Cookies
We also benefit from data provided by third parties where you provide us with your consent to set the relevant cookies and/or other tracking technologies. We set out below a summary of the key data sources.
We use a number of Meta services and other similar products on our Platforms, including through the use of the pixel and other business products. In some circumstances, Meta or the other platform provider acts as our data processor and in other circumstances, they are a joint data controller (for example, Meta with respect to Custom Audiences). Further details of how they process your personal information, the legal basis they rely on, your rights and contact details can be found on the relevant platform.
About Advertising
The Platforms use third parties such as network advertisers and ad exchanges to serve you ads on third party platforms after you leave our Platforms, and we use third party analytics and other service providers to evaluate and provide us and/or third parties with information about the use of the Platforms and viewing of ads and of our content. Network advertisers are third parties that display advertisements, which are based on your visits to the Platforms and other apps and sites you have visited. Third party ad serving enables us to target advertisements to you for products and services that you might be interested in.
Third party tracking technologies are not controlled by us, even if they are associated with our Platforms or our ads. Statements regarding our practices do not apply to the methods for collecting information used by these third parties and others or the use of the information that such third parties collect. The relevant third party’s terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices. We make no representations regarding the policies or practices of third party advertisers or advertising networks or exchanges or related third parties, such as Meta.
You have choices in respect of the delivery of ads. You can opt-out of receiving certain types of behavioural ads by visiting the third party websites described in the section headed “How to control or delete cookies” in our Cookie Policy. We are not responsible for effectiveness of or compliance with any third parties’ opt-out options.
Commitment 2: Protecting Your Personal Information
Protecting your personal information
We want you to feel confident about sharing your personal information with us, and we are committed to protecting the personal information we collect by implementing leading data protection, privacy and security standards. We limit access to personal information about you to employees who reasonably need access to it, to provide products or services to you or in order to do their jobs. We have appropriate technical and organisational physical, electronic, and procedural safeguards to protect the personal information that you provide to us against unauthorised or unlawful processing and against accidental loss, damage or destruction. However, where we ask you to choose a password in order to access certain parts of our Platforms, you are responsible for selecting a secure password and keeping that password confidential. You should choose a password which you do not use on any other site, and you should not share it with anyone else.
Sharing your personal information
We only share personal information with others when we are permitted by law to do so. When we share personal information with others, we put contractual arrangements and security mechanisms in place to protect the personal information shared and to comply with our data protection, confidentiality and security standards and obligations. We share your personal information with third parties in the following circumstances:
Our affiliated group companies: We may share your personal information with our affiliated group companies for the purposes specified above, where we are permitted by law to do so (including where we have a lawful basis to do so).
Service providers (including data processors): We will disclose your personal information to our appointed third party service providers (which may process your personal information as data processors on our behalf), including for the purposes of providing online and other payment services, handling credit checks and fraud prevention, product shipment, cloud storage and any other services required in order for us to use your personal information for the purposes specified in this Privacy Policy. In certain circumstances, certain fraud-prevention service providers consider themselves to be independent data controllers.
Regulatory, authority and other third party disclosures: We will disclose your personal information to any law enforcement agency, court, police, regulator, government authority or any other third party, including a relevant financial institution, where we believe this is necessary to comply with a legal or regulatory obligation, to protect our rights or the rights of any third party, or where it is otherwise in the public interest or our legitimate interests or those of a third party (for example to respond to a request from a third party to disclose personal information to investigate an alleged crime, to check that we are complying with applicable law and regulations, or to establish, exercise or defend legal rights). In addition, we may share your data with insurance providers and/or lost or stolen organisations to facilitate the recovery of any lost or stolen items.
Mergers & acquisitions: We will disclose your personal information to any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this Privacy Policy.
Social media platforms and other third party digital vendors: We may share your personal information with social media platforms as explained above or in the Cookie Policy.
Transferring your personal information globally
Personal information we collect may be transferred to, stored and processed in any country or territory where one or more of our affiliated group companies or any third party listed in the section headed “Sharing your personal information” above are located or maintain facilities. Some of these third parties will use cloud-based storage solutions. While other territories may not have the same standards of data protection as those within your home country, we will continue to protect the personal information we transfer in accordance with this Privacy Policy.
Privacy risk assessments
We may periodically conduct risk assessments related to the processing of your personal information, especially when introducing new technologies or functionalities. In certain circumstances, these new technologies or functionalities may require us to provide enhanced privacy notices and/or consent forms to ensure that we continue to meet our privacy commitments towards you.
Retaining your personal information
We keep your personal information only for as long as is necessary for our purposes of processing, and in particular to protect ourselves in the event of a legal claim (for example, information relating to a contract with you will be kept for the lifetime of the contract and up to ten years after) as well as necessary to comply with statutory retention obligations. After this period it will be deleted or in some cases anonymised. Where we have your consent to process your personal information and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent we will delete your personal information.
If you request that we no longer send you direct marketing communications or you exercise your right to be forgotten, we will keep a record of your request and contact details to ensure that your request is respected.
Commitment 3: Respecting your rights
We commit to respecting your rights. If you wish to exercise any of the rights set out below, which are available to you under applicable law, please write to us at the address listed below.
Right of access
You have the right to ask for access to any personal information that is being processed by us.
Right to erasure / restriction of processing
In some circumstances, you have the right to request the erasure of your personal information or to restrict how we use it.
Right to update or correct
You have the right to ask us to correct any inaccurate personal information and to update any out-of-date personal information.
Right to object
You have in certain circumstances the right to object, on grounds relating to your particular situation, at any time to the processing of personal information concerning you which is carried out on the basis of legitimate interests or in the public interest.
Furthermore, you have the right to object where your personal information is processed for direct marketing purposes.
Right to data portability
In some circumstances, you have the right to request from us the personal information concerning you that you have provided to us in a structured, commonly used, machine-readable format.
Right to withdraw consent
If you have given us consent to process your personal information, you can withdraw this consent at any time with effect for the future. The withdrawal does not affect the lawfulness of the processing carried out on the basis of this consent until the withdrawal.
Right to complain
If you have a concern about how we use your personal information, as a first step please contact us using the details set out below and we will do our best to resolve your concern. After investigating your concern, we will respond to you in writing within a reasonable time setting out our proposed remedial action.
If you think we have processed your personal information in a manner that is unlawful or breaches your rights, you also have the right to complain to a relevant data protection authority, for example in your place of residence, or the jurisdiction in which the processing took place.
Right to object to advertising using e-mail
In the event that we have obtained your e-mail address in connection with the sale of a product and/or service and use your e-mail address for direct advertising of our own similar products and/or services, you may object to such use of your e-mail address at any time with effect for the future by e-mailing the address below in the section headed “Contact us” or clicking the ‘unsubscribe’ link in any of our marketing e-mails.
However, please note that we may continue to send you service-related (i.e. non-marketing) communications, such as e-mail updates on your order status.
Children
The Platforms are not directed at anyone who we know to be a child in the relevant country of data collection (for example, in the US this is under 13 and in certain European countries this is under 16), nor do we collect any personal information from anyone who we know to be a child unless we have parental or guardian consent. Children should not use the Platforms and should not submit any personal information to us without parental or guardian consent.
California Privacy Rights
This section applies solely to the personal information collected online and offline of California consumers. This section is intended to address the relevant notice requirements of the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), and uses certain terms that have the meaning given to them in the CCPA.
- Your information, sources and purposes: Please refer to the sections above headed “Information that you provide to us or we collect about you” for a description of the personal information we may collect about you (or have collected in the preceding 12 months) and the sources of such information (such as directly from you and your device or through certain third parties). These sections also describe the purposes for which we may use or have used such information. We do not collect or process sensitive personal information for purposes of inferring characteristics about consumers. To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.
- Retaining your information: We will retain your personal information for the time period reasonably necessary to achieve the purposes described in this Privacy Policy, or any other notice provided at the time of collection, taking into account applicable statutes of limitation and records retention requirements under applicable law.
- Disclosing your information: We may have disclosed your personal information to certain categories of third parties, as described in the section headed “Sharing your personal information” above.
- Selling your information/sharing your information for cross-context behavioral advertising: We do not sell or share your personal information in exchange for monetary compensation. As described in our Cookie Policy, we may allow certain third parties (such as certain advertising partners) to collect your personal information via automated technologies on our Platforms in an effort to serve you content and advertisements that may be of interest to you. We also may share your personal information, such as your e-mail address, with third parties to help support our marketing activities. This kind of sharing may be considered a sale or sharing for cross-context behavioral advertising under the CCPA. You have the right to opt out of this disclosure of your personal information, as described below
- Your rights: Subject to exceptions under applicable law, you may have certain choices regarding our use and disclosure of your personal information, as described below:
- Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.
- Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
- Deletion: You have the right to request that we delete certain personal information we have collected from you.
- Opt-out of Selling or Sharing: You have the right to opt out of the sale of your personal information or sharing of your personal information for cross-context behavioral advertising. You can opt out of cookie-based selling/sharing by clicking hereor broadcasting the Global Privacy Control signal. For more information about how to use the Global Privacy Control signal, please see https://globalprivacycontrol.org/. In addition, you can opt out of other types of selling/sharing as further described in the CCPA Opt-out Page. Your opt-out will be specific to the browser and device you are using and will apply to the website domain on which you submit the request. If you clear your cookies or use a new browser or device to access the site, please submit a new request to re-apply your opt-out choice. Note that even if you opt out of selling or sharing, you may still be served advertisements and receive marketing e-mails from us and our service providers.
To exercise your rights on behalf of yourself or another individual, please contact us as described in the section headed “Contact us” below. If you exercise your rights, we may require you to provide certain information to verify your identity (such as your name, e-mail address, phone number and/or address) or the authority of any third person acting on your behalf.
No discrimination: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. This section is available in alternative formats upon request by contacting us as described in the section headed “Contact us” below.
Personal, family and household clients: In addition, under California Civil Code Section 1798.83, if you are a California resident and your business relationship with us is primarily for personal, family or household purposes, you may request certain data regarding our disclosure, if any, of personal information to third parties for the third parties’ direct marketing purposes. To make such a request, please send an e-mail message to our e-mail address below with “Request for California Privacy Information” in the subject line. You may make such a request up to once per calendar year. If applicable, we will provide you, by e-mail, a list of the categories of personal information disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, along with the third parties’ names and addresses. Please note that not all personal information sharing is covered by Section 1798.83’s requirements.
Privacy: Other States
Your rights: If you are a New Jersey, Texas or Virginia resident and you interact with us in an individual or household capacity (and not in a commercial or employment context), subject to exceptions under applicable law, you may have certain choices regarding our use and disclosure of your personal information, as set forth above in ‘Commitment 3: Respecting your rights’ (including the rights to access and data portability, and to correct or delete certain personal information).
In addition, you have the right to opt-out of cookie-based selling/targeted advertising by clicking here or broadcastingthe Global Privacy control signal. For more information about how to use the Global Privacy Control signal, please see https://globalprivacycontrol.org/. You can opt-out of other types of selling/targeted advertising as further described in the Opt-out page.
To exercise your rights on behalf of yourself or another individual, please contact us as described in the section headed ‘Contact Us’ below. If you exercise your rights, we may require you to provide certain information to verify your identity (such as your name, email address, phone number and/or address) or the authority of any third person acting on your behalf.
You may appeal our decision with respect to a request you have submitted by contacting us as described in the section headed ‘Contact Us’ below.
Contact us
If you have any questions, comments or complaints about this Privacy Policy or Cookie Policy, or privacy matters generally, please contact us at the address provided below. You can also use this address if you wish to request access to the personal information about you that we process or to unsubscribe from any further e-mail marketing communications.
Stefano Serapian S.r.l.,
Via Benigno Crespi 26
20159 Milano, Italy