THE MOST COMPLETE, AUTHORITATIVE AND SECURE WEBSITE TO BUY WORKS OF ART.ENITFREUR

Privacy Policy

1. Who we are and to whom this Privacy Notice applies

This Privacy Notice on the protection of personal data (“Privacy Notice”) describes how Deodato.Gallery S.p.A. hereinafter referred to as “Deodato” or the “Data Controller”, processes the personal data of natural persons who interact with and use its websites and access the related activities.

Data Controller

Deodato.Gallery S.p.A.

Registered office: Via Nerino 2, 20123 - Milan (MI), Italy

General contact email address: [email protected]

Certified email address PEC: [email protected]

This Privacy Notice applies to the processing of personal data carried out by Deodato in relation to the following brands and online channels, mainly intended for the European Union / European Economic Area EU/EEA market:

including their respective websites, ecommerce platforms, reserved areas, online forms, newsletters, membership/fidelity programmes, official social media channels connected to such websites and any other digital initiative referred to on the websites themselves.

Unless otherwise specified, Deodato acts as Data Controller pursuant to Regulation EU 2016/679 “GDPR”.

2. What is meant by processing of personal data

“Personal data” means any information that identifies or makes a natural person identifiable, directly or indirectly, such as, by way of example: name and surname, email address, telephone number, shipping address, payment data, IP address, purchase data, preferences expressed on the website.

“Processing” means any operation carried out on personal data, including collection, recording, storage, consultation, use, disclosure, erasure, and so forth.

Data processing is carried out in compliance with the principles of lawfulness, fairness, transparency, data minimisation, accuracy, storage limitation, integrity and confidentiality, and accountability, as provided for by the GDPR and by the Italian Privacy Code Legislative Decree 196/2003, as amended by Legislative Decree 101/2018.

3. Who are the data subjects and what data we process

3.1 Categories of data subjects

We process personal data relating to the following categories of natural persons:

3.2 Categories of data processed

Depending on how the interaction with Deodato takes place, we may process the following categories of personal data:

Any additional basic identification data, such as date of birth and gender, may be collected on an optional basis in order to better personalise communications and initiatives, or to verify compliance with minimum age requirements. Providing such additional information is optional and does not affect the possibility of making purchases or using the basic services of the websites.

We do not request or process, through the channels described, special categories of data, so-called “sensitive data”, relating, by way of example but not limited to, health, religion, political opinions, genetic or biometric data, except in exceptional cases and always with a specific dedicated notice and subject to the data subject’s prior consent.

4. Purposes and methods of data processing

In this section we describe the main purposes for which we process your personal data, the legal basis that allows us to process them, the main categories of data involved and the retention periods.

The legal bases adopted for the processing and retention of personal data are listed below:

4.1 Online and offline purchases, performance of the contract and order management

Main purposes

Data processed main categories

Guest checkout

In line with European recommendations on data minimisation and with the most recent indications of the European Data Protection Board EDPB on the legal basis for the creation of accounts on ecommerce websites, Deodato allows you to make purchases without creating a personal account guest checkout. In this case, we collect only the data necessary to fulfil the order and comply with the related legal obligations.

Retention periods

4.2 Customer account management and reserved area

Main purposes

Legal basis

Data processed main categories

Retention periods

You may request deletion of your account at any time by following the instructions in the reserved area or by contacting us at the contact details indicated in section 10.

4.3 Membership/Fidelity Programme

Deodato may activate Membership/Fidelity programmes in order to reward and retain regular customers, including through dedicated benefits, point collections, early access to exhibitions and special initiatives.

Main purposes

Data processed main categories

Retention periods

Enrolment in the programme is entirely optional and failure to enrol does not affect the possibility of making purchases or using the other basic services of the website.

4.4 Newsletter and marketing communications

Main purposes

Data processed main categories

Retention periods

You may unsubscribe at any time by clicking on the link at the bottom of each communication or by contacting us at the contact details indicated in section 10. Withdrawal of consent does not affect the lawfulness of processing carried out before such withdrawal.

4.5 Personalised marketing, abandoned carts and favourites “light” profiling

Main purposes

The use of marketing automation tools, such as newsletter and multichannel campaign platforms, and advertising features offered by third parties, such as Meta, Google or other operators, which allow personalised ads and content to be shown on external websites and platforms, is always carried out in compliance with the choices expressed through the cookie banner and the consents provided.

Data processed main categories

Retention periods

You may object at any time to the processing of your data for marketing and profiling purposes, as indicated in section 8.

4.6 Customer care and customer support

Main purposes

Data processed main categories

Retention periods

Support requests may also be handled through instant messaging applications, such as WhatsApp Business. In such cases, certain data provided, such as telephone number, message content and any attachments, will be processed to respond to your requests and may also be processed by the providers of the messaging applications, acting as independent controllers or processors, according to their respective privacy policies.

The use of messaging apps for promotional communications will take place only on the basis of your specific consent or, in any case, consent clearly extended to that channel.

In order to facilitate online interactions and improve customer service, we may also use chats and virtual assistants such as chatbots, possibly based on AI technologies. In such cases, the data provided in chats are processed solely to provide you with answers, support or suggestions, as well as, in aggregated form, for internal analysis and service improvement. No decisions are made solely on the basis of automated processing that produce legal effects concerning you or that may significantly affect your personal sphere.

4.7 Events, competitions and special initiatives

Main purposes

Retention periods

4.8 Analysis, statistics and business development

Main purposes

Data processed main categories

Retention periods

4.9 Compliance with legal obligations and litigation management

Retention periods

4.10 IT security, fraud prevention and management

Main purposes

Data processed main categories

Retention periods

5. To whom we disclose personal data

Your personal data are processed by authorised Deodato personnel, duly instructed and bound by confidentiality obligations.

In addition, for the purposes described above, data may be disclosed to the following categories of recipients:

The updated list of processors may be requested by contacting Deodato at the contact details indicated in section 10.

6. Transfers of data to third countries

Personal data are normally processed within the European Economic Area EEA. However, certain service providers, such as cloud service providers, marketing and advertising tools, payment or communication platforms, may be located in or process data in countries outside the EEA.

In such cases, transfers of data to third countries will take place in compliance with Articles 44 et seq. of the GDPR, adopting one of the following safeguards:

Upon request, we may provide additional information on the safeguards adopted for transfers outside the EEA and a copy of the relevant Standard Contractual Clauses, within the limits allowed by confidentiality and security requirements.

7. How we use cookies and similar technologies

Our websites use cookies and similar technologies, such as pixels, tags and SDKs, for technical, statistical and, subject to consent, marketing and profiling purposes.

For more details on the types of cookies used, the specific purposes and retention periods, we invite you to consult the dedicated Cookie Policy, which is constantly updated and available on our websites. Through the dedicated panel, you may at any time change your preferences and withdraw consent to the use of non-technical cookies.

8. Your rights

As a data subject, you have the following rights in relation to your personal data, within the limits and under the conditions set out in Articles 15 to 22 of the GDPR:

To exercise your rights, you may contact Deodato at the contact details indicated in section 10. We will respond, as a rule, within 30 thirty days of receipt of the request, subject to the extensions provided for by the GDPR in particularly complex cases.

9. Right to lodge a complaint with the supervisory authority

If you believe that the processing of your personal data violates the applicable data protection legislation, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State where you habitually reside, work or where the alleged infringement occurred.

In Italy, the supervisory authority is the Italian Data Protection Authority, Autorità Garante per la protezione dei dati personali.

This is without prejudice to your right to refer the matter at any time to the competent judicial authorities.

10. Contact details of the Data Controller and Data Protection Officer DPO

Data Controller

Data Protection Officer DPO

If Deodato appoints a Data Protection Officer DPO pursuant to Articles 37 to 39 of the GDPR, the relevant updated contact details will be indicated in the updated versions of this Privacy Notice and in the privacy sections of the group websites.

For any question or request relating to the processing of your personal data, including the exercise of the rights described above, you may write to the Data Controller’s contact details, specifying “Privacy” in the subject line.

11. Changes to this Privacy Notice

This Privacy Notice may be subject to changes or updates, including as a result of:

In the event of substantial changes, we will inform you by appropriate means, through email communications, informative pop-ups or notices published on the group websites, so that you may review the updated version before the changes produce significant effects.

The latest version of the Privacy Notice is always available on the Deodato group websites.

Cookie Policy

Below is the Cookie policy to be used as an extended disclosure in accordance with Articles 13 and 14 of Regulation (EU) 2016/679 (hereinafter "GDPR").

What are Cookies?

Cookies are pieces of information sent by a web server (e.g., the site) to the Internet browser of the user, automatically stored by the user on the computer and automatically sent back to the server each time the site is accessed. By default, almost all web browsers are set to automatically accept cookies. Typically, cookies can be installed:

This website may use, also in combination with each other the following types of cookies classified according to the indications of the Privacy Guarantor and the Opinions issued in the European context by the Working Group Art. 29 / European Data Protection Committee:

Cookies on the Site

Technical cookies for which consent is not required

The Data Controller will install on your device and, in particular, in your browser or allow third parties to install certain cookies that are necessary for us to acquire or have our partners acquire statistical information in an anonymous and aggregate form related to your navigation on the pages of the Site.

Non-technical cookies for which your consent is required

Subject to your free, specific, informed and unambiguous consent, the Data Controller or third parties may install other markers that do not fall under the definition of technical cookies.

By default, such cookies are disabled.

When you first access the Site, you will see a banner that briefly informs you about the cookies used and allows you, via a special button, to select your preferences on such cookies. Please be advised that where you do not set preferences or close the banner without making choices, the Site will only use technical cookies for which consent is not required.

At any time, you may change your choices regarding these cookies through the appropriate preference management panel by clicking on the appropriate button at the bottom left.

If you do not wish to receive third-party cookies on your device, you may, through the link below, access the policies and consent forms of those third parties and exclude their receiving. These cookies are not directly controlled by the Site, therefore, you will need to refer to the third party websites, or to https://www.youronlinechoices.com/uk/ for information on how you can delete or manage cookies based on the browser you are using and to manage your preferences on third party cookies.

How to disable cookies by browser configuration

If you wish, you can also manage cookies directly through your browser settings. However, by deleting cookies from your browser, you may remove the preferences you have set for the Site, including technical cookies that record your preferences and your previous access to the Site. In that case, when you log in to the Site again, the cookie banner may appear again.

For more information and support you can also visit the specific help page of the web browser you are using, such as:

– Internet Explorer / Microsoft Edge:https://support.microsoft.com/en-gb/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d

– Google Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB

– Mozilla Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer

LIST OF COOKIES COLLECTED

The table below lists the cookies we collect and what information they store.

Cookies used by this website

Technical cookies do not require consent. Analytics and marketing cookies are set only after your consent, which you can withdraw at any time via the “Manage cookies” link.

Manage cookies