Privacy policy

CALZATURIFICIO FRAU SPA and FILOBLU S.p.A.

CALZATURIFICIO FRAU SPA (hereinafter “FRAU”) and FiloBlu S.p.A. (hereinafter ”FiloBlu”),
handle the protection of your personal data and the respect of your rights. In accordance with Regulation (EU) 2016/679 (hereinafter referred to as “GDPR”), on this page they shall set out how they process the personal data of users who consult this website or use the interactive services on it.

TABLE OF CONTENTS:

About us

In the processing of your personal data related to the activities of website browsing, website registration and product sales, the joint data holders are FRAU, Tax No./VAT No. IT00799810239, with registered office in Via Torino 18/20 - 37035 San Giovanni Ilarione (VR), Italy, and FiloBlu Spa, Tax No./Vat No. IT04274870288, with registered office in Via Caltana 116/c, Santa Maria di Sala (VE), Italy.
The agreement to be joint data holders was formalised between the aforementioned companies through a specific contract, which reflects the respective roles and relationships of the joint data holders with the data subjects. The content of the agreement is available to you and you may request it at the contact details given below (please see What your rights are and how you can exercise them, let. d)). Please also note that, irrespective of the provisions of the above-mentioned agreement, you may exercise your rights under the GDPR by contacting each data controller.
With regard to the processing of your personal data for promotional and marketing purposes, the data controller is FRAU, which avails itself of the support of FiloBlu for certain processing operations that it carried out in its capacity as data processor in compliance with the provisions established by Art. 28 of the GDPR.
FiloBlu has appointed a Data Protection Officer (DPO) whom you may contact at: dpo@filoblu.com

Our responsibility

If you are already a customer, are registered on or are simply visiting www.frau.it, or are subscribed to our newsletter, we would like to inform you that your data shall be legitimately processed in accordance with the provisions of this privacy policy and/or the specific privacy policies that have already been provided to you.

Your commitment

We only ask that you read this privacy policy carefully so that you are fully informed about how we process your personal data.

When and how we collect your personal data

As soon as you browse or interact with this website, we start processing your personal data. Your data may be collected either via your voluntary contribution or automatically while you are using the website. In the table below we indicate, for each processing activity, the data controller, joint data controller and the data processor, the nature of the data we process, the purpose of the processing in question, the legal basis and the storage period:

WEBSITE BROWSING

DATA CONTROLLER, JOINT DATA CONTROLLER, DATA PROCESSOR:	Frau and FiloBlu are joint data controllers
NATURE OF THE DATA PROCESSED:	Your IP address; login information; browser type and version; time zone; plug-in types; geolocation information about the country where you may be located; the operating system you are using and its versions; your navigation path within the website (Clickstream analysis); your views of products and services; page load and response times; download errors; navigation duration; behaviour and other actions, etc. This data is acquired by the computer systems responsible for the operation of this website.
PURPOSE OF PROCESSING:	enable web browsing; carry out aggregate statistical analyses aimed at measuring the proper functioning of this website and, in the event of cybercrimes, ascertain any liability.
LEGAL BASIS:	legitimate interest of joint data holders
STORAGE PERIOD:	30 days from the date of collection, unless a longer storage period is required by law or regulation in connection with investigations related to possible cybercrimes.

COMPLETE PURCHASE ORDERS

DATA CONTROLLER, JOINT DATA CONTROLLER, DATA PROCESSOR:	Frau and FiloBlu are joint data controllers
NATURE OF THE DATA PROCESSED:	Your full name, shipping and billing address, telephone number and email address.
PURPOSE OF PROCESSING:	processing of purchase orders placed online and performance of related activities (dispatch of goods, invoicing, payment management, shipment tracking, delivery of goods, possible activation of the return process and order refund, return management, etc.).
LEGAL BASIS:	performance of the contract
STORAGE PERIOD:	10 years from the conclusion of the order

CUSTOMER SERVICE

DATA CONTROLLER, JOINT DATA CONTROLLER, DATA PROCESSOR:	Frau and FiloBlu are joint data controllers
NATURE OF THE DATA PROCESSED:	identification and contact data and information provided by the data subject requesting support from customer service
PURPOSE OF PROCESSING:	respond to requests for assistance received from the data subject. Communication of changes to our services, customer support via live chat, telephone or email, including bug fixes.
LEGAL BASIS:	performance of the contract. Legitimate interest in the event of complaints or litigation
STORAGE PERIOD:	5 years after collection

COMMERCIAL COMMUNICATIONS

DATA CONTROLLER, JOINT DATA CONTROLLER, DATA PROCESSOR:	Frau is data holder and FiloBlu is the data processor
NATURE OF THE DATA PROCESSED:	identification and contact details
PURPOSE OF PROCESSING:	Data are processed in order to carry out commercial information activities and to send advertising material and newsletters on FRAU’s promotional and commercial initiatives and to survey the degree of satisfaction of the data subject, via telephone, SMS and email, as well as via traditional means (e.g. sending catalogues by post).
LEGAL BASIS:	consent of the data subject, which is always revocable
STORAGE PERIOD:	until revoked by the data subject

PERSONALISED COMMERCIAL COMMUNICATIONS

DATA CONTROLLER, JOINT DATA CONTROLLER, DATA PROCESSOR:	Frau is data holder and FiloBlu is the data processor
NATURE OF THE DATA PROCESSED:	data relating to the country of origin of the data subject
PURPOSE OF PROCESSING:	sending personalised commercial communications according to the country from which the data subject is interacting
LEGAL BASIS:	consent of the data subject
STORAGE PERIOD:	until revoked by the data subject

REGISTRATION FOR RESERVED AREA

DATA CONTROLLER, JOINT DATA CONTROLLER, DATA PROCESSOR:	Frau and FiloBlu are joint data controllers
NATURE OF THE DATA PROCESSED:	identification and contact data and information provided by the data subject in the registration form
PURPOSE OF PROCESSING:	creation of a reserved area that allows registration on the website, access to and the execution of services reserved for registered users and the possible submission through the site of a purchase order for available products with the consequent conclusion of the relevant contract of sale, including any administrative and accounting formalities
LEGAL BASIS:	performance of the contract
STORAGE PERIOD:	5 years after collection

STATISTICAL ANALYSIS

DATA CONTROLLER, JOINT DATA CONTROLLER, DATA PROCESSOR:	Frau and FiloBlu are joint data controllers
NATURE OF THE DATA PROCESSED:	purchase information and country of origin, processed in pseudonymised form
PURPOSE OF PROCESSING:	processing of statistical reports for organisational, production and market campaign development purposes
LEGAL BASIS:	legitimate interest
STORAGE PERIOD:	5 years after collection

REVIEWS AND COMMENTS

DATA CONTROLLER, JOINT DATA CONTROLLER, DATA PROCESSOR:	Frau and FiloBlu are joint data controllers
NATURE OF THE DATA PROCESSED:	identification and contact data and information provided by the data subject
PURPOSE OF PROCESSING:	analysing to provide feedback to reviews and comments
LEGAL BASIS:	contract performance and relationship management legitimate interest
STORAGE PERIOD:	until revocation or request for cancellation

CONTROL AND ANTI-FRAUD ACTIVITIES

DATA CONTROLLER, JOINT DATA CONTROLLER, DATA PROCESSOR:	Frau and FiloBlu are joint data controllers
NATURE OF THE DATA PROCESSED:	identification data, order details, payment instrument information
PURPOSE OF PROCESSING:	verify the correspondence between the acquiring party and the holder of the selected payment instrument. In some cases, in order to finalise your purchase, it may be necessary to carry out some additional checks with a view to fraud prevention and, therefore, you may receive communications, also by email from our dedicated account, in which we shall ask you to transmit the authorisation code and a copy of the credit card used for the purchase, on which we ask you to obscure the eight central digits. The data thus collected shall be retained for evidentiary purposes, in order to cooperate with the judicial authorities and to deal with any disputes that may arise in this regard
LEGAL BASIS:	legitimate interest
STORAGE PERIOD:	1 year after collection

To whom we disclose your data

The pursuit of the aforementioned purposes requires that your data can be accessed by:

authorised entities operating under the authority of FRAU and FiloBlu;
IT service providers and consultants, appointed as data processors;
credit institutions, shipping and transport companies, insurance companies;
public bodies in the event of control and/or inspections;
in order to offer you Klarna’s payment methods, at checkout we may pass on your personal information in the form of contact and order details to Klarna, so that Klarna can assess whether you are eligible for their payment methods and tailor these payment methods to your needs. Your transferred personal data is processed in line with the Klarna Privacy Policy.

Cookies

For any further information, please refer to the cookie policy on our website.

Where your data is stored

Your data is processed within the European Union.

How we process your data

The processing of your data is mainly carried out electronically, with the exception of product shipments, which may also be carried out by manual means. We guarantee that your data shall be processed with the utmost security: we have taken the appropriate physical, IT and organisational measures required to ensure the protection of your data.

What your rights are and how you can exercise them

a) you can decide whether to provide us with your data

In this case, you can continue to browse our website, but we will not be able to provide you with services that cannot be provided without processing your personal data.

b) you can disable cookies by changing your browser settings

You can block cookies by setting your browser to prevent their storage. You can also delete cookies directly from your browser settings. If you disable cookies, you can continue to browse our site, but some of our services may not function properly. Read more in our cookie policy..

c) you can ask us not to use your data for marketing reasons

You can always revoke your consent to receive promotional messages by clicking on the relevant link that you can find in each of our communications or by sending an email to the following address: privacy@filoblu.com.

d) you have the right to access information about yourself

This includes the right to know whether any personal data concerning you is being processed and, if confirmed, to obtain a copy of that data, as well as to request further information from us by sending an email to the following address: privacy@filoblu.com, regarding:

the categories of data we process;
the purposes of the processing;
the categories of possible recipients to whom the data may be disclosed;
the data retention period or, failing that, the criteria for determining that period;
other rights concerning the use of your data.

A copy of the above-mentioned joint data holder agreement may be requested from privacy@filoblu.com.

e) you have the right to obtain the correction and rectification of your data

if inaccurate or outdated, by sending an email to the following address: privacy@filoblu.com

f) you have the right to have your personal data deleted

If the storage of your personal data is no longer necessary for the purposes of processing, you may at any time ask us to cancel the personal data in our possession by sending an email to the following address: privacy@filoblu.com

g) you have the right to obtain the restriction of the processing of your personal data

by sending an email to the following address: privacy@filoblu.com if you have contested the accuracy of your personal data, if we are no longer authorised to process the data and/or if the storage of your personal data by us is no longer necessary for the purposes of the processing;

h) you have the right to object to the processing of your personal data where it is based on our legitimate interest;

i) you can always contact the Data Protection Authority to lodge any complaints you may have.

Before doing so, please contact us! We will be happy to solve any problems concerning the processing of your personal data.

l) you can change your mind whenever you want!

You may revoke your consent at any time by sending us an email to the following address: privacy@filoblu.com, or by clicking on the opt-out button at the bottom of our emails. If you decide to revoke your consent and there are no other reasons for us to process your personal data, we shall cease processing. On the other hand, should another legal basis authorise us to do so, we shall continue to process your data, always in respect of your rights.

Thank you!
Thank you for taking the time to read this privacy policy. We have attempted to make it simple, clear and transparent; however, we reserve the right to update it should the need arise. In any case, we are always seeking to improve: if you have any suggestions, please write to us at privacy@filoblu.com.