Privacy Policy
Last updated: 20 August 2026
1. Data controller
1.1 The controller of the personal data collected through the website torrini1369.com (the "Site") 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 set out in Section 12, data subjects may contact the Maison at info@torrini1369.com or +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:
- identification and contact details: first name, surname, email address, telephone number, shipping and billing address
- order details: the Creation selected, its configuration, size or length, and any engraving text
- 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: email, live chat, WhatsApp, telephone
- optional data provided in the course of the relationship with the Maison: preferences, personal occasions (e.g. anniversaries), bespoke requests
2.2 Third-party data contained in engravings. The engraving text chosen by the Client may contain personal data of third parties (names, initials, dates). The Client warrants that such data are provided lawfully; the Maison processes them exclusively for the making of the Creation and the documentation of the order.
2.3 Data collected automatically during browsing: technical data (IP address, browser and device type, pages visited, source of the visit) collected through cookies and similar technologies, as described in Section 11.
2.4 The Maison does not request or intentionally process special categories of data (Article 9 GDPR). Data subjects are invited not to include data of this nature in their communications with the Maison.
3. Purposes and legal bases of processing
| Purpose | Legal basis (GDPR) |
|---|---|
| Order management: conclusion and performance of the contract, making of the Creation, payment, shipping, order assistance | Art. 6(1)(b) — performance of the contract |
| Documentation of individual production specifications (including sizes agreed via live chat or email) | Art. 6(1)(b) and 6(1)(f) — performance of the contract and legitimate interest in preserving evidence |
| Tax, accounting and legal obligations | Art. 6(1)(c) — legal obligation |
| Pre-sale assistance and responses to enquiries (email, live chat, WhatsApp, telephone) | Art. 6(1)(b) — pre-contractual measures taken at the data subject's request |
| Newsletter and promotional communications | Art. 6(1)(a) — consent |
| Communications concerning an uncompleted order (cart recovery) | Art. 6(1)(f) — legitimate interest |
| Relational after-sales communications (assistance, anniversaries) addressed to existing clients and concerning the Maison's creations and services | Art. 6(1)(f) — legitimate interest (Art. 130(4) of the Italian Privacy Code) |
| Statistical analysis of the use of the Site | Consent to measurement cookies (see Section 11) |
| Advertising activities through third-party platforms | Consent to marketing cookies (see Section 11) |
| Defence of the Maison's rights in judicial or extrajudicial proceedings | Art. 6(1)(f) — legitimate interest |
3.2 The provision of the data required for order management is essential to the conclusion of the contract; the provision of data for marketing purposes is always optional and may be withdrawn at any time.
4. Recipients of the data
4.1 Personal data are processed by the Maison's authorised personnel and disclosed, within the limits of their respective functions, to the following categories of recipients, acting as processors or independent controllers according to their respective roles:
- E-commerce platform: Shopify Inc. (hosting of the Site, order and client 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
- Carrier: DHL Express, for the delivery of the 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 and clientele
- The Maison's advisers (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 upon request at info@torrini1369.com.
5. Transfers outside the EU
5.1 Some of the providers listed in Section 4 are established, or maintain servers, in the United States or in other third countries. In such cases, transfers take place on the basis of an adequacy decision of the European Commission — including, for participating US providers, the EU-U.S. Data Privacy Framework — or of the standard contractual clauses (SCCs) adopted by the Commission, supplemented where necessary by additional measures.
5.2 A copy of the applicable safeguards may be requested at info@torrini1369.com.
6. Retention periods
| Category of data | Retention period |
|---|---|
| Data relating to orders, contracts and accounting and tax documentation | 10 years from the conclusion of the contract |
| Conversations (live chat, email) connected to an order, including those documenting the size or other individual production specifications | 10 years, together with the order documentation |
| Pre-sale conversations not followed by an order | 24 months from the last contact |
| Data processed for newsletter and marketing purposes | Until withdrawal of consent or objection; periodic review of inactive contacts |
| Browsing data and cookies | According to the duration of each cookie and the consents given through the banner (see Section 11) |
| Data necessary for the defence of legal claims | For the duration of the dispute and the applicable limitation periods |
6.2 Upon expiry of the periods indicated, the data are erased or anonymised.
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. Consent is given at the time of subscription and is recorded by the Maison together with the date and method of collection.
7.2 Data subjects may withdraw their consent at any time through the unsubscribe link included in every email or by writing to info@torrini1369.com, without prejudice to 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, pursuant to Article 130(4) of the Italian Privacy Code; clients may object at any time in the same ways described in Section 7.2.
8. Live chat
8.1 The Site offers a live chat service for pre- and after-sales assistance. Conversations are retained in accordance with Section 6; those in which individual production specifications are agreed (in particular the size) 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 concerning orders, enquiries 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 mass promotional mailings.
10. Reviews and Site features
10.1 The Site may integrate features provided by third-party applications (reviews, wishlists). The data processed through such features are described in the privacy notices of the respective providers.
11. Cookies and similar technologies
11.1 The Site uses cookies and similar technologies for its operation and, subject to consent, for personalisation, measurement and marketing purposes.
11.2 On the first visit, a consent management banner allows users to accept or refuse non-essential cookies, divided by category (necessary, personalisation, measurement, marketing). Non-essential cookies are installed only with the user's prior consent, which may be modified or withdrawn at any time through the banner settings accessible from the Site.
11.3 Cookies strictly necessary for the operation of the Site (session management, cart, security) do not require consent and cannot be disabled.
12. Rights of the data subject
12.1 Data subjects may exercise at any time the rights provided for by Articles 15–22 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.
12.2 Requests may be addressed to info@torrini1369.com. The Maison responds within one month of receipt, extendable in the cases provided for by law.
12.3 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.
13. United States residents
13.1 For residents of California and of other States recognising similar rights, the Maison specifies that: (a) the categories of data collected and the purposes of processing 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 behavioural advertising purposes within the meaning of California law (CCPA/CPRA).
13.2 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 withdrawing marketing cookies through the Site's banner, or by writing to info@torrini1369.com with the subject line "Privacy Request". The Maison does not discriminate against data subjects who exercise their rights.
14. Minors
14.1 The Site and its services are addressed exclusively to adults. The Maison does not knowingly collect personal data of persons under 18 years of age; should it become aware of any such processing, it will erase the data.
15. Security
15.1 The Maison adopts appropriate technical and organisational measures to protect personal data against unauthorised access, loss, disclosure or alteration, relying on providers that guarantee security standards compliant with the GDPR. Transactions on the Site take place over an encrypted connection; full payment card details are not stored by the Maison.
16. Amendments and versions
16.1 The Maison may amend this notice at any time. The version in force is the one published on the Site, bearing its version number and date of last update; previous versions are archived by the Maison.