Privacy Policy
Version 1.4 — Last updated: September 15, 2026
Versione italiana1. Data controller
1.1 The controller of the personal data collected through the website torrini1369.com (the "Site") and in the course of the relationship with the customers 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, Florence Companies Register (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@torrini1369.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 such an appointment are not met.
2. Categories of data processed
2.1 Data provided directly by the Customer, 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;
- order or purchase details: the Creation selected, its configuration, size or length, any engraving text, and the details recorded in the Certificate of Origin;
- payment data: handled by the payment service providers referred to in section 4 — the Maison does not store full payment card details;
- the content of communications with the Maison;
- optional information shared in the course of the relationship with the Maison: preferences, personal occasions (e.g., anniversaries), custom requests.
2.2 Third-party data: engravings and recipients. The engraving text chosen by the Customer may contain personal data of third parties (names, initials, dates); where the Customer designates a delivery recipient other than themselves, the Maison processes the recipient's identification and contact details provided by the Customer. The Customer warrants that such data are provided lawfully and that the recipient has been informed, where appropriate; the Maison processes them exclusively 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, source of the visit) collected through cookies and similar technologies, as described in the Cookie Policy (section 12).
2.4 The Maison does not request or intentionally process special categories of data (Article 9 GDPR). Data subjects should not include such data 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 at the boutique: conclusion and performance of the contract, making of the Creation, payment, shipping or delivery, Certificate of Origin, order assistance. Legal basis: Article 6(1)(b) GDPR — performance of a contract.
- Creation and management of the customer account and of saved preferences (wishlist). Legal basis: Article 6(1)(b) GDPR — performance of a service requested by the data subject.
- Documentation of individual production specifications (including any size agreed by email). Legal basis: Articles 6(1)(b) and 6(1)(f) GDPR — performance of a contract and legitimate interest in preserving evidence.
- Tax, accounting and legal obligations. Legal basis: Article 6(1)(c) GDPR — legal obligation.
- Pre-sales assistance and responses to inquiries (email, live chat, WhatsApp, telephone, boutique). Legal basis: Article 6(1)(b) GDPR — pre-contractual steps taken at the data subject's request.
- Newsletter and promotional communications. Legal basis: Article 6(1)(a) GDPR — consent.
- Communications regarding an uncompleted order (abandoned cart), sent exclusively to the Maison's customers or to newsletter subscribers. Legal basis: Article 6(1)(f) GDPR — legitimate interest with respect to customers (Article 130(4) of the Italian Privacy Code); Article 6(1)(a) GDPR — consent for newsletter subscribers.
- Relationship-based after-sales communications (assistance, anniversaries) to existing customers, concerning the Maison's creations and services. Legal basis: Article 6(1)(f) GDPR — legitimate interest (Article 130(4) of the Italian Privacy Code).
- Statistical analysis of the use of the Site. Legal basis: consent to measurement cookies (see the Cookie Policy).
- Advertising through third-party platforms. Legal basis: consent to marketing cookies (see the Cookie Policy).
- Defense of the Maison's rights in or out of court. Legal basis: Article 6(1)(f) GDPR — legitimate interest.
3.2 Providing the data required to manage the order is necessary for the conclusion of the contract; providing data for marketing purposes is always optional and consent may be withdrawn at any time.
3.3 The Maison does not make decisions based solely on automated processing, including profiling, which produce legal effects concerning the data subject or similarly significantly affect them (Article 22 GDPR). The communications referred to 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 staff and disclosed, within the limits 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);
- 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 Creations (contact details and shipping address);
- Live chat: Chatra (Roger Wilco LLC), for chat assistance on the Site;
- Email marketing: Klaviyo, Inc. and Shopify Email, for sending the newsletter and the communications referred to in section 3;
- Measurement and advertising tools: Google (Google Analytics 4, Google Ads, Google Fonts, Google Maps) and Meta Platforms (Meta pixel), according to the consents given through the cookie banner;
- Internal management system: the Maison's management software for the administration of orders, purchases and customers;
- The Maison's advisors (accounting, tax, legal), where necessary;
- Competent authorities, in the cases provided by law.
4.2 The updated list of processors is available on request at info@torrini1369.com.
5. Transfers outside the EU
5.1 Some of the providers referred to 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 measures.
6. Retention periods
6.1 Personal data are retained for the periods set out 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.
- Communications (email, live chat, WhatsApp) linked to an order, including those documenting the size or other individual production specifications: up to 10 years, together with the order records.
- Pre-sales communications 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 required for legal defense: for the duration of the dispute and the applicable limitation periods.
6.2 Once the above 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, at 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.
7.2 Data subjects may withdraw consent at any time through the unsubscribe link in every email or by writing to info@torrini1369.com, without affecting the lawfulness of processing carried out before withdrawal.
7.3 The Maison may send its customers communications concerning creations and services similar to those purchased, pursuant to Article 130(4) of the Italian Privacy Code; customers may object at any time in the manner described in section 7.2.
8. Live chat and email
8.1 The Site offers a live chat service for pre- and after-sales assistance; conversations are retained in accordance with section 6.
8.2 Email or live chat conversations in which individual production specifications are agreed — in particular a size not listed on the product page, agreed by email pursuant to Article 4.3 of the Terms and Conditions of Sale — are retained together with the order records, as evidence of the agreed specifications.
9. WhatsApp
9.1 At the Customer's request or initiative, the Maison may use WhatsApp for communications concerning orders, inquiries and assistance. The service is provided by WhatsApp Ireland Ltd. (Meta group), which processes data in accordance with its own privacy notice. The Maison uses WhatsApp for individual communications and not for bulk 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 Customer's identification and contact details, the details of the purchase and of the Creation (including those recorded in the Certificate of Origin) and the details required for invoicing, which are collected manually at the time of purchase and recorded in the Maison's management system. This notice is made available to the Customer at the boutique at the time the data are collected.
10.2 Such data are processed for the purposes and on the legal bases set out in section 3 and retained in accordance with section 6.
10.3 Subscription to the newsletter at the boutique takes place exclusively at the Customer's initiative, by providing their 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 Customer may share is treated with discretion, exclusively 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 review applications: reviews of the Maison are published on the Maison's Google Business Profile, in accordance with Google's privacy notice. The wishlist feature is built into the Site's theme, without third-party applications: saved preferences are stored on the user's device or, for registered customers, in their account. 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 notice. Non-essential cookies are installed only with the user's consent, given through the dedicated banner and revocable at any time.
13. Data subjects' rights
13.1 Data subjects may exercise at any time the rights provided by Articles 15 to 22 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 addressed to info@torrini1369.com. The Maison responds within one month of receipt, which may be extended in the cases provided 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) may constitute "sharing" of personal data for cross-context behavioral advertising within the meaning of California law (CCPA/CPRA).
14.2 Residents of the States concerned may exercise the right to opt out of sharing — in addition to the rights of access, deletion and correction — by refusing or withdrawing marketing cookies through the Site's banner, or by writing to info@torrini1369.com with "Privacy Request" as the subject line. 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 persons of legal age. The Maison does not knowingly collect personal data from persons under 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 against 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 notice at any time. The version in force is the one published on the Site, bearing the version number and the date of the last update; previous versions are archived by the Maison.