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Data Protection Policy

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Freddy S.p.A., a company represented by the acting legal representative with registered offices at 20 Corso Buenos Aires, 20124 Milan, Italy – (VAT no. 00207660994) email: [email protected]; DPO: [email protected]; Certified email: [email protected] (henceforth the “Data Controller”), as the data controller pursuant to art. 4, paragraph 7, and art. 24 of the Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (henceforth the “GDPR”), hereby provides notice, pursuant to art. 13 of the GDPR, that it will process the personal data of users of the website (data subjects).


1. Types of data processed

REGISTRATION: When you register, we will collect only your email. Subsequently, we will ask you to complete your profile, entering your personal information, address and contact info.

Become an INFLUENCER: If you want to participate in a casting call to become one of our influencers, we will collect the following personal data: name, surname, email, city, and Instagram username.

WORK WITH US: If you send us your CV, we will collect the data you provide us, generally personal information and contact information.

CONTACT US: If you fill in the “contact us” form, we will collect your email address.

CUSTOMER SERVICE: We will ask you for the personal information and contact information necessary to process your request. If you contact us via WhatsApp, we may process your mobile phone number and the data you provide us.

RETURNS: If you fill in the online return form, we will ask you for the personal information and contact information necessary to process your request.

NEWSLETTER: If you sign up for the newsletter, you will need to provide us with your email address. If you want, you can indicate what type of information you are most interested in receiving.

SUBSCRIPTION TO THE MEMBERSHIP PROGRAM: To sign up for the Membership program, you will be asked to provide your email.

SURVEYS/MARKET RESEARCH: We will request your personal data and contact information.

NOTIFY ME WHEN THE PRODUCT IS BACK IN STOCK: We will request your email address.

REGISTER AS AN INSTRUCTOR: If you register as an instructor, we will collect the following data: personal data (name, surname, date of birth) and contact information, such as email address and telephone number. We will also ask you to provide the information about the gym where you work, which does not constitute personal data in the strict sense of the word, though it would make it possible to identify you indirectly. We will also ask you for your addresses.

PURCHASES: If you complete a purchase, we will process the following data: personal data, contact information, and shipping information.

Your IP address and browsing log will always be saved.


2. Legal basis and purpose of processing

Data will be processed in order to carry out the activities connected to the establishment and management of the service requested of the Data Controller.
Said data will be processed lawfully, suitably and with absolute confidentiality, complying with adequate security and safety measures and pursuant to applicable laws and the GDPR.
Processing will take place on paper and digitally. The data provided will not be shared or published.
In particular:

REGISTRATION: the purpose is to allow you to log in to our website, manage your newsletter preferences and facilitate the shopping process. The legal basis for processing is consent.

BECOME AN INFLUENCER: The purpose of processing is to let you participate in casting calls; the legal basis for processing is consent as well as the execution of pre-contractual measures carried upon at the request of the data subject.

WORK WITH US: If submitting your CV without an open position:
To authorize the processing of your personal data, as necessary to complete your request, we need your consent.
If applying to an open position:
In this case, the lawfulness of the request derives from the execution of the pre-contractual measures carried out upon the request of the data subject and therefore we will not ask you to provide your explicit consent. We will not ask you to provide specific data; however, by providing personal data in your CV, you implicitly consent to the processing of that data.

CONTACT US: The legal basis for processing is consent and your personal data will be processed in order to respond to your request(s).

CUSTOMER SERVICES: The legal basis for processing is consent and your personal data will be processed in order to respond to your request(s).

RETURNS: The legal basis for processing is consent and your personal data will be processed in order to respond to your request(s).

CHAT-WHATSAPP: The legal basis for processing is consent and your personal data will be processed in order to respond to your request(s).

NEWSLETTER: The purpose of processing is to inform you of updates and promotions; the legal basis for processing is consent.

SUBSCRIPTION TO THE MEMBERSHIP PROGRAM: The purpose is to send you promos and discounts, and the legal basis is the execution of the contract, while to receive customized offers based on your purchases, you will be asked to give your consent to receiving marketing messages.

SURVEYS/MARKET RESEARCH: The legal basis is the consent of the data subject, and the purpose is to allow Freddy s.p.a. to send out survey and market research requests.

NOTIFY ME WHEN THE PRODUCT IS BACK IN STOCK: The legal basis is the performance of the precontractual measures taken at the request of the data subject.

REGISTER AS AN INSTRUCTOR: The legal basis for processing is consent and the purpose is to receive special discounts on your purchases.

PURCHASES: The purpose is to make it possible for you to purchase of our products and allow us to send them to you. The legal basis for processing is the fulfilment of a contract and its legal obligations (including accounting and tax obligations). Your data will be provided to the courier that will ship your items, duly appointed as the data processor. With your purchase, your data will be exported to CRM software for the delivery of sales information. Pursuant to art. 130 par. 4 of Italian leg. decree 196/03, your consent is not necessary, and you may opt out at any time.

DIRECT MARKETING, COMMERCIAL PARTNERS AND PROFILING: with your explicit consent, we will process your personal data including for direct marketing purposes through commercial partners, and we will conduct profiling activities.
Direct marketing: through the delivery of marketing materials and messages with informational and/or promotional content relating to products and services provided and/or promoted by the Data Controller, including via email and SMS messages (with specific, separate consent).
Commercial partner marketing: through the delivery of marketing materials and messages with informational and/or promotional content in relation to products and services provided by and/or promoted by FREDDY's commercial partners, which will process your data as independent data controllers.
Profiling: individual or aggregated, and for market research aimed, for example, at the analysis of consumer habits and choices, at the processing of statistics about them, or the assessment of their satisfaction with the prices and services offered.

THE FREDDY360° PROGRAMME: signing up for the FREDDY360° programme is strictly connected to the loyalty programme and thus does not require consent as the legal bases is derived from the fulfilment of the contract; the purpose is to offer you a series of benefits linked to the purchases made.
In any case: the IP address associated with the browsing log is saved for security purposes, in relation to the access to the relevant systems, and the legal basis is the legitimate interest of the Data Controller. For that same reason, we will also send you an email if you close your browser/tab to remind you of your abandoned cart.

 

3. Processing methods

The Data Controller will process personal data for the time necessary to fulfill the aforementioned purposes and, in any case, no longer than 10 years from the date they were obtained.

The data relating to website registration (including as an instructor) will be processed until you decide to delete your account. After 7 years of inactivity on the website, we will send you an email to check to see if you wish to remain registered and, if you fail to confirm your interest in remaining registered, we will delete your account. 

The data concerning your subscription to the Membership program will be deleted if you decide to unsubscribe or when you decide to delete your account or according to the standard manner applicable for account cancellation.

For newsletters, direct and indirect marketing and profiling, personal data will be deleted 5 years after the last message sent or the last profiling activity completed.

If you enroll in the Freddy360 programme, you accept the terms of the programme and can cancel your registration at any time.

By subscribing to the Membership program, you accept the terms and conditions, but you can unsubscribe at any time.

CVs will be stored for 36 months, after which they will be deleted.

If you write to us, we will process your data for the time strictly necessary to respond to your request; after that, your data will be deleted.

Browsing logs will be stored for up to 24 months max.

SURVEYS/MARKET RESEARCH: No more than 3 years after submission of the response. Afterwards, the data will be anonymized.

NOTIFY ME WHEN THE PRODUCT IS BACK IN STOCK: We will process your data for the time strictly necessary to fulfill your request, then we will delete it.

 

4. Communication of data

The Data Controller may share data for the purposes listed in art. 2, with entities with which their provision is necessary by law, for the fulfilment of the purposes established by law. The data provided will not be shared or published. If the user chooses “Klarna” as a payment gateway, he/she will be redirected to that page. Klarna acts as an independent owner. For Klarna privacy policy click here: www.klarna.com/international/privacy-policy.

 

5. Data Storage and Transfer

The management and storage of personal data will be carried out on servers located inside the European Union and in non-EU countries of the Data Controller and/or of third parties duly appointed as Data Processors. The Data Controller guarantees that the transfer of data to non-EU countries is carried out in compliance with articles 44-47 Chapter V of the GDPR through the signing of standard contract clauses and/or in favor of companies that have adhered to the Data Privacy Framework based on the adequacy decision of the European Commission of July 10, 2023.

 

6. Rights of the data subject

As the data subject, the client has the rights listed in art. 15 of the GDPR, more precisely:

  1. The interested party has the right to obtain confirmation of the existence or not of personal data concerning the same interested party, even if they haven't registered, and the communication of said data in an intelligible form.
  2. The interested party has the right to obtain information on:
    1. the origin of the personal data;
    2. the purpose and conditions of the processing;
    3. the logic applied in the case of processing done with electronic instruments;
    4. details of the controller, the processors and the representative;
    5. subjects or categories of subjects to whom the personal data can be communicated or can learn of the same as the appointed representative in the territory of the State, processors or persons responsible for the data.
  3. The interested party has the right to request:
    1. the revision, the correction or, in other words, the integration of the data, when this is in the interest of the same;
    2. the cancellation, transformation in anonymous form or blocking the data processed in violation of the Act, including data that doesn't need to be kept for the purposes for which the data was collected or subsequently processed;
    3. the declaration that the operations in letters a) and b) have been brought to the knowledge, also regarding the content of the same, to those the data has been communicated to or distributed to, with the exception of the case in which this fulfilment is impossible or involves the use of means that are clearly disproportionate with respect to the protected right.
  4. The interested party has the right to oppose, in whole or in part:
    1. for legitimate reasons, the processing of their personal data, even if relevant to the purpose of the collecting;
    2. the processing of personal data that regard the data subject for purposes not covered by art. 2.

Pursuant to art. 15 et seq. of the GDPR, the data subject has the right to request, at any time, access to his or her personal data, their rectification or erasure (right to be forgotten), and the restriction of their processing in the cases established by art. 18 of the GDPR; the data subject also has the right to data portability, receiving his or her personal data in a structured, commonly-used and machine-readable format in the cases established by art. 20 of the GDPR. At any time, pursuant to art. 7 of the GDPR, the data subject can withdraw his or her consent and, pursuant to art. 77 of the GDPR, lodge a complaint with a supervisory authority should he or she believe that the processing of personal data relating to him or her violates the GDPR.
Data subjects can object to the processing of their personal data pursuant to art. 21 of the GDPR. In that notice of objection, the data subject must justify their reasons for objecting: the Data Controller reserves the right to evaluate the request, which will not be accepted if there are legitimate, compelling grounds to process the data that override the interests, rights and freedoms of the data subject.


The data subject can assert his or her rights at any time by sending:

  • a return receipt registered letter to Freddy S.p.A. - Corso Buenos Aires, 20 - 20124 Milan, Italy
  • an email to (regular email): [email protected]; PEC (certified email): [email protected]

The company hereby declares to have appointed a DPO, who can be reached at the following email: [email protected] 

 

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