Privacy Policy
Version 1.7, last updated: November 4, 2026
Versione italiana1. Data controller
1.1 The controller of the personal data collected through the website torrinijewels.com (the "Site") and in the course of the relationship with the clients of the Florence boutique is Torrini 1369 s.r.l., with registered office at Piazza del Duomo 12/R, 50122 Florence, Italy, VAT No. IT 06111170483, registered with the Florence Register of Companies (REA FI-601401), certified email (PEC) torrini1369@pec.it (the "Maison" or the "Controller").
1.2 For any request concerning the processing of personal data or the exercise of the rights described in Section 13, data subjects may contact the Maison by email at info@torrinijewels.com or by telephone at +39 055 2302401.
1.3 The Maison has not appointed a Data Protection Officer (DPO), as the legal conditions requiring one are not met.
2. Categories of data processed
2.1 Data provided directly by the Client, through the Site, by email, live chat, WhatsApp, telephone or at the boutique:
- identification and contact details: first name, last name, email address, telephone number, shipping and billing address;
- data relating to the order or purchase: the Creation selected, configuration, size or length, any engraving text, information shown on the Certificate of Origin;
- payment data: handled by the payment service providers listed in Section 4 (the Maison does not store full payment card details);
- the content of communications with the Maison;
- optional information provided in the course of the relationship with the Maison: preferences, personal occasions (such as anniversaries), custom requests.
2.2 Third-party data: engravings and recipients. The engraving text chosen by the Client may contain personal data of third parties (names, initials, dates); where the Client designates someone else as the delivery recipient, the Maison processes the recipient's identification and contact details as provided by the Client. The Client warrants that such data are provided lawfully and that the recipient has been informed, where appropriate; the Maison processes them solely to make the Creation, deliver it and document the order, and discloses them to the carrier only to the extent necessary for delivery.
2.3 Data collected automatically while browsing: technical data (IP address, browser and device type, pages visited, referral source) collected through cookies and similar technologies, as described in Section 12 and in the Cookie Policy.
2.4 The Maison does not request or knowingly process special categories of data (Article 9 GDPR). Data subjects are asked not to include data of this kind in their communications with the Maison.
3. Purposes and legal bases of processing
3.1 The Maison processes personal data for the purposes and on the legal bases set out below:
- Management of the order or of the purchase in the boutique: conclusion and performance of the contract, making of the Creation, payment, shipping or delivery, Certificate of Origin, order support. Legal basis: performance of the contract (Art. 6(1)(b) GDPR).
- Creation and management of the client account. Legal basis: performance of a service requested by the data subject (Art. 6(1)(b) GDPR).
- Documentation of individual production specifications (including the size agreed upon by email). Legal basis: performance of the contract and the legitimate interest in preserving evidence of what was agreed (Art. 6(1)(b) and 6(1)(f) GDPR).
- Tax, accounting and legal obligations. Legal basis: legal obligation (Art. 6(1)(c) GDPR).
- Pre-sale assistance and responses to inquiries (email, live chat, WhatsApp, telephone, boutique). Legal basis: pre-contractual measures taken at the data subject's request (Art. 6(1)(b) GDPR).
- Newsletter and promotional communications. Legal basis: consent (Art. 6(1)(a) GDPR).
- Communications about an incomplete order (cart recovery), sent only to clients of the Maison or to newsletter subscribers. Legal basis: legitimate interest toward clients (Art. 6(1)(f) GDPR; Article 130(4) of the Italian Privacy Code); consent for newsletter subscribers (Art. 6(1)(a) GDPR).
- Relationship-based after-sales communications (assistance, anniversaries) to existing clients, concerning the Maison's creations and services. Legal basis: legitimate interest (Art. 6(1)(f) GDPR; Article 130(4) of the Italian Privacy Code).
- Statistical analysis of the use of the Site. Legal basis: consent to measurement cookies (see Cookie Policy).
- Advertising through third-party platforms. Legal basis: consent to marketing cookies (see Cookie Policy).
- Defense of the Maison's rights in or out of court. Legal basis: legitimate interest (Art. 6(1)(f) GDPR).
3.2 Providing the data needed to manage the order is essential to concluding the contract; providing data for marketing purposes is always optional and may be revoked.
3.3 The Maison does not make decisions based solely on automated processing, including profiling, that produce legal effects concerning the data subject or similarly significantly affect them (Article 22 GDPR). The communications described in Section 7 may be selected on the basis of the data subject's preferences and purchases, within the limits of the consents given.
4. Recipients of the data
4.1 Personal data are processed by the Maison's authorized personnel and disclosed, to the extent of their respective functions, to the following categories of recipients, which act as processors or as independent controllers according to their respective roles:
- E-commerce platform: Shopify International Ltd (hosting of the Site, order and customer management, the platform's own visit statistics, subject to consent to measurement cookies, and synchronisation of the cart with the Shop app);
- Payment service providers: Mollie B.V. (payment cards), PayPal (Europe) S.à r.l. et Cie, S.C.A.; for bank transfers, the Maison's bank;
- Carriers: DHL Express and FedEx, for the delivery of the Creations (contact details and shipping address);
- Live chat: Chatra (Roger Wilco LLC), for chat support on the Site;
- Email marketing: Klaviyo, Inc. and Shopify Email, for sending the newsletter and the communications described in Section 3; subject to consent to measurement and marketing cookies, Klaviyo also records browsing on the Site and associates it with the profile of newsletter subscribers and of clients signed in to their account, so that communications are relevant;
- Measurement and advertising tools: Google (Google Analytics 4, Google Ads, Google Merchant Center) and Meta Platforms (Meta pixel and Conversions API, through which the same events are also transmitted to Meta by Shopify's servers), according to the consents given through the cookie banner or the preferences panel; for purchases, subject to consent to marketing cookies, the contact details provided by the Client may be transmitted to Google and Meta in pseudonymised (hashed) form, solely for the measurement and attribution of conversions;
- Functional content: Google (Google Maps), for the map on the Contact page, subject to consent to preference cookies;
- Internal management system: the Maison's management software for the administration of orders, purchases and clientele;
- The Maison's advisors (accounting, tax, legal), where necessary;
- Competent authorities, in the cases provided for by law.
4.2 An up-to-date list of processors is available on request at info@torrinijewels.com.
5. Transfers outside the EU
5.1 Some of the providers listed in Section 4 are established or have servers outside the European Union, in particular in the United States. In such cases, the transfer takes place on the basis of an adequacy decision of the European Commission or of the Standard Contractual Clauses adopted by the Commission, supplemented where necessary by additional safeguards.
6. Retention periods
6.1 Personal data are retained for the periods indicated below:
- Data relating to orders, purchases, contracts and accounting and tax records: 10 years from the conclusion of the contract, in compliance with legal obligations.
- Conversations (email, live chat, WhatsApp) connected to an order, including those documenting the size or other individual production specifications: up to 10 years, together with the order documentation.
- Pre-sale conversations not followed by an order: up to 24 months from the last contact.
- Data for newsletter and marketing purposes: until consent is withdrawn or an objection is raised; the list is reviewed periodically, at least every five years, and inactive contacts are deleted.
- Browsing data and cookies: as indicated in the Cookie Policy.
- Data needed for legal defense: for the duration of the dispute and the applicable limitation periods.
6.2 Once these periods have elapsed, data are deleted or anonymized.
7. Newsletter and promotional communications
7.1 Subscription to the newsletter takes place by entering one's email address in the dedicated form on the Site or, in the boutique, in the manner described in Section 10.3. Consent is given at the time of subscription and recorded by the Maison together with the date and method of collection. Subscription through the form on the Site is completed only after the data subject confirms the link sent to the email address provided (double opt-in).
7.2 Data subjects may withdraw consent at any time through the unsubscribe link in every email or by writing to info@torrinijewels.com, without affecting the lawfulness of the processing carried out before withdrawal.
7.3 The Maison may send its clients communications concerning creations and services similar to those purchased, under Article 130(4) of the Italian Privacy Code; clients may object at any time in the same manner described in Section 7.2.
8. Live chat and email
8.1 The Site offers a live chat service for pre- and post-sale assistance; conversations are retained within the periods set out in Section 6.
8.2 Email or live chat conversations in which individual production specifications are agreed upon, in particular a non-standard size agreed upon by email under Article 4.3 of the Terms and Conditions of Sale, are retained together with the order documentation as evidence of the agreed specifications.
9. WhatsApp
9.1 At the Client's request or initiative, the Maison may use WhatsApp for communications relating to orders, inquiries and assistance. The service is provided by WhatsApp Ireland Ltd. (Meta group), which processes data in accordance with its own privacy policy. The Maison uses WhatsApp for individual communications and not for mass promotional mailings.
10. Boutique
10.1 In connection with purchases and inquiries made at the boutique at Piazza del Duomo 12/R, Florence, the Maison collects the Client's identification and contact details, data relating to the purchase and the Creation (including those shown on the Certificate of Origin) and the data needed for invoicing, collected manually at the time of purchase and recorded in its management system. This policy is made available to the Client in the boutique at the time the data are collected.
10.2 Such data are processed for the purposes and on the legal bases described in Section 3 and retained within the periods set out in Section 6.
10.3 Subscription to the newsletter in the boutique takes place solely on the Client's initiative, by providing an email address for that purpose; consent is recorded together with the date and method of collection, as provided in Section 7.
10.4 Information about personal occasions (anniversaries, events) that the Client may choose to share is treated with discretion, solely to personalize the relationship with the Maison, and is not disclosed to third parties for other purposes.
11. Reviews and Site features
11.1 The Site does not integrate any review application: reviews concerning the Maison are published on the business's Google profile, in accordance with Google's privacy policy. The wishlist feature is built into the Site's theme, without third-party applications: saved items are stored only in the browser of the device in use, are not associated with the client account and are not transmitted to the Maison or to any third party. Any other features provided by third-party applications, and the related processing, are indicated in the Cookie Policy.
12. Cookies
12.1 The Site uses cookies and similar technologies, described in the Cookie Policy published on the Site, which forms an integral part of this policy. For access from the European Economic Area and the United Kingdom, non-essential cookies are installed only with the user's consent, given through the banner or the preferences panel; for access from other countries, paragraph 3.5 of the Cookie Policy applies. The choice may be changed or withdrawn at any time through the "Cookie preferences" control in the footer.
13. Rights of the data subject
13.1 Data subjects may at any time exercise the rights provided for in Articles 15 to 22 of the GDPR: access to their data, rectification, erasure, restriction of processing, portability, objection to processing based on legitimate interest (including objection to marketing, which is always possible), and withdrawal of consent.
13.2 Requests may be sent to info@torrinijewels.com. The Maison responds within one month of receipt, extendable in the cases provided for by law.
13.3 Data subjects also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali, www.garanteprivacy.it) or with the supervisory authority of their country of habitual residence.
14. United States residents
14.1 For residents of California and of other states that recognize similar rights, the Maison specifies that: (a) the categories of data collected and the purposes are those described in Sections 2 and 3; (b) the Maison does not sell personal data; (c) the use of third-party advertising tools (Google Ads, Meta, Klaviyo) may constitute "sharing" of personal data for behavioral advertising purposes under California law (CCPA/CPRA).
14.2 Residents of the states concerned may exercise their right to opt out of sharing, in addition to their rights of access, deletion and correction, by refusing or revoking marketing cookies through the "Cookie preferences" control in the footer, through the Your Privacy Choices page linked in the footer or by enabling the Global Privacy Control signal in their browser, or by writing to info@torrinijewels.com with the subject line "Privacy Request." The Maison does not discriminate against data subjects who exercise their rights.
15. Minors
15.1 The Site and its services are intended exclusively for adults. The Maison does not knowingly collect personal data from anyone under the age of 18; should it become aware of any such processing, it will delete the data.
16. Security
16.1 The Maison adopts appropriate technical and organizational measures to protect personal data from unauthorized access, loss, disclosure or alteration, relying on providers that guarantee GDPR-compliant security standards. Transactions on the Site take place over an encrypted connection; full payment card details are not stored by the Maison.
17. Amendments and versions
17.1 The Maison may amend this policy at any time. The version in force is the one published on the Site, with its version number and date of last update; previous versions are archived by the Maison. This policy is drawn up in Italian; the English version is a translation and, in the event of any discrepancy, the Italian version prevails.