Privacy Policy

This Privacy Policy explains how Fratelli Orsini B.V. (“Fratelli Orsini,” “we,” “us,” or “our”) collects, uses, stores, and shares personal data when you visit our Website, place an order, create an account, contact us, subscribe to marketing communications, leave a review, or otherwise interact with us.

This Privacy Policy applies to the German version of our online store and the related services available through www.fratelli-orsini.com.

1. Who is responsible for your personal data?

Fratelli Orsini B.V. is the controller responsible for the processing of your personal data.

Fratelli Orsini B.V.
Herengracht 420
1017 BZ Amsterdam
The Netherlands
Dutch Chamber of Commerce (KvK) number: 81645007

Email: info@fratelli-orsini.com

If you wish to exercise your privacy rights, please send an email with the subject line “Privacy Request.”

2. When does this Privacy Policy apply?

This Privacy Policy applies, among other things, to personal data that we process through:

  • our Website and online store;
  • customer accounts;
  • orders, payments, delivery, returns, exchanges, and refunds;
  • email contact and live chat with our customer service team;
  • product reviews, photographs, videos, and feedback;
  • newsletters and other email marketing;
  • loyalty and referral programs;
  • analytics, advertising, and audience services;
  • wholesale or B2B inquiries;
  • fraud prevention and verification; and
  • other interactions with Fratelli Orsini.

This Privacy Policy does not apply to third-party websites, apps, or services that are operated independently.

3. What personal data do we process?

The personal data we process depends on how you use our Website and services.

Contact and order information may include:

  • name, email address, telephone number, and address details;
  • billing and delivery address;
  • order number, products ordered, size, color, order value, and order history;
  • information about payments, delivery, returns, exchanges, refunds, and warranty claims; and
  • communications with our customer service team.

Account information may include:

  • login details and account number;
  • saved addresses;
  • order and return history;
  • communication preferences; and
  • information about loyalty and referral programs.

Website and device information may include:

  • IP address;
  • browser and device information;
  • cookie, pixel, and advertising identifiers;
  • pages accessed and products viewed;
  • click, shopping-cart, and checkout activity;
  • referring website or advertising campaign;
  • the date, time, and duration of your visit; and
  • approximate location derived from your IP address.

When you contact us or leave a review, we may also process the content of your message, photographs, videos, product information, and other information you voluntarily share with us.

4. How do we collect your personal data?

We collect personal data:

  • directly from you, for example when you place an order, create an account, contact us, or subscribe to our newsletter;
  • automatically through your browser, device, cookies, pixels, and similar technologies;
  • through Shopify and payment service providers;
  • through customer service, returns, warehouse, fulfillment, and delivery partners;
  • through review, loyalty, and referral partners;
  • through analytics and advertising platforms, where you have provided consent when required; and
  • through other persons acting with your permission.

5. For what purposes and on what legal basis do we use personal data?

We process your personal data only where we have a valid legal basis under the General Data Protection Regulation (GDPR) and, where applicable, German data-protection and telecommunications privacy law.

We use personal data to:

  • accept, process, ship, and deliver orders;
  • handle payments, returns, exchanges, refunds, and warranty claims;
  • manage customer accounts;
  • send order confirmations, delivery updates, and other necessary service messages;
  • answer customer questions and provide sizing or product advice;
  • operate, secure, and improve the Website;
  • prevent, investigate, and combat fraud, misuse, and security incidents;
  • comply with legal, tax, administrative, and accounting obligations;
  • establish, exercise, or defend our rights;
  • carry out statistics and business analysis;
  • manage reviews, loyalty programs, and referral programs; and
  • send or display marketing communications and personalized advertisements where permitted or where you have provided consent.

Depending on the purpose, we base these processing activities on performance of a contract with you, compliance with a legal obligation, our legitimate interests, or your consent.

Our legitimate interests include keeping our Website secure and functioning properly, preventing fraud, improving our products and services, protecting our business interests, and carrying out limited direct-marketing activities for existing customers where permitted by law.

You may withdraw your consent at any time. This does not affect the lawfulness of processing carried out before you withdrew your consent.

6. Shopify

Our online store is hosted and operated using Shopify. Shopify processes personal data when you visit our Website, view products, create an account, place an order, check out, make a payment, or otherwise interact with our online store.

Shopify may process personal data for purposes including hosting, online-store functionality, checkout, payments, customer accounts, fraud prevention, analytics, security, personalization, and other e-commerce services.

More information about Shopify’s processing of personal data is available at privacy.shopify.com.

7. Payments

Payments are processed through Shopify and the payment methods available during checkout, which may include Visa, Mastercard, American Express, PayPal, Klarna, Shop Pay, Apple Pay, Google Pay, and other payment methods offered for the German market.

Your complete payment-card details are generally processed directly by the relevant payment service provider. We do not normally receive your full card number or security code. We may receive limited payment information, such as the selected payment method, transaction number, payment status, card type, and partial card number.

8. Customer Service, Returns, and Reviews

We use Gorgias to manage email contact, live chat, and other customer service activities. When you contact us, we may process information such as your name, email address, order number, message content, previous correspondence, photographs, videos, and other information you provide.

We use ReturnGO to manage returns, exchanges, and related communications. ReturnGO may process information including your contact details, order number, reason for return, return status, tracking information, refund information, and photographs of damaged or defective products.

We use Yotpo to collect, manage, and display product reviews. When you submit a review, we may process your name or chosen display name, email address, product and order information, rating, review text, photographs, videos, and verification status. Reviews and related photographs or videos may be publicly visible on product pages.

9. Warehouse, Fulfillment, and Delivery

We share only the personal data reasonably necessary to process, pack, ship, deliver, track, return, or exchange your order.

This information may include your name, delivery address, email address, telephone number, order number, products ordered, selected delivery method, parcel and tracking information, and return information.

For fulfillment of German orders, we use the following warehouse and fulfillment partner:

Active Ants / Fratelli Orsini
Hoeschstraße 20
46284 Dorsten
Germany

Active Ants may process the personal data reasonably necessary to store, pick, pack, ship, track, return, or exchange your order. For delivery of German orders, we generally use DHL or a relevant local delivery partner. These parties process personal data in accordance with their own privacy policies and legal obligations.

10. Email Marketing

We use Shopify Email and Klaviyo to send and manage marketing emails. These communications may include newsletters, product announcements, promotions, offers, abandoned-cart or checkout reminders, back-in-stock notifications, product recommendations, and communications about loyalty or referral programs.

We send marketing emails only where you have provided consent or where permitted by applicable law, including the requirements applicable to electronic marketing in Germany. You can unsubscribe at any time using the unsubscribe link at the bottom of each marketing email.

Even after unsubscribing from marketing, we may still send necessary messages about your order, payment, account, return, warranty, security, or customer service request.

11. Loyalty and Referral Programs

We may use Yotpo Loyalty & Referrals to manage loyalty and referral programs. Depending on the program, we may process your name, email address, customer account number, order history, points, rewards, discount codes, referral links, and participation information.

The applicable terms, points, benefits, and any expiration dates will be shown with the relevant program. You may end your participation in a program by contacting us. This may result in unused points, rewards, or future benefits expiring, to the extent permitted by the program terms and applicable law.

12. Cookies and Similar Technologies

We and our service providers use cookies, pixels, tags, scripts, local storage, device identifiers, and similar technologies.

These technologies may be used for:

  • the operation of the Website, shopping cart, checkout, and payments;
  • logging into your account;
  • security and fraud prevention;
  • remembering language, country, currency, and cookie preferences;
  • analyzing and improving Website performance;
  • personalization;
  • measuring marketing campaigns; and
  • displaying and measuring personalized advertisements.

Essential cookies and similar technologies may be used where they are strictly necessary to provide the Website or a service you expressly request. For non-essential technologies, including analytics and advertising technologies, we request your prior consent where required under the GDPR and the German Telecommunications Digital Services Data Protection Act (TDDDG).

We use Pandectes GDPR Compliance to manage cookie preferences and consent. You can withdraw or change your consent at any time through the “Cookie Settings” link on our Website.

13. Analytics and Advertising

With your consent, we may use analytics and advertising services including Google Analytics 4, Shopify Analytics, Hotjar, Microsoft Clarity, Google Ads, Meta Pixel, Meta Conversions API, TikTok Pixel, Pinterest Tag, Shopify Audiences, and similar services.

These services may process information about your device, browser, cookie identifiers, approximate location, pages visited, products viewed, clicks, scrolling behavior, shopping-cart and checkout activity, referral sources, and conversions.

We use this information to analyze Website use and performance, identify technical issues, improve the customer experience, measure advertisements, and display relevant advertisements.

Advertising platforms may combine information they receive from us with information they collect themselves through other websites, apps, advertisers, or services. We use such services only where permitted and, where required, after you have provided consent.

14. Customer Lists and Audience Matching

Where you have provided consent or where otherwise lawful, we may share limited customer data with advertising and audience platforms to create audiences, exclude existing customers from campaigns, measure campaigns, or display relevant advertisements.

This may include information such as your email address, telephone number, name, country or region, customer number, and purchase information. Where possible, this information is hashed or otherwise protected before it is shared.

We do not sell your personal data for money. However, data may be shared with advertising and analytics partners as described in this Privacy Policy where you have provided consent or where otherwise lawful.

15. With whom do we share personal data?

We may share personal data with the following categories of recipients:

  • Shopify;
  • payment service providers, banks, and card companies;
  • Gorgias;
  • ReturnGO;
  • Yotpo;
  • Klaviyo;
  • warehouse, fulfillment, and delivery partners, including Active Ants and DHL;
  • analytics, advertising, and social-media platforms;
  • fraud-prevention and security service providers;
  • cloud-hosting and technology partners;
  • accountants, lawyers, insurers, auditors, and advisers;
  • government authorities, regulators, and courts where we are required to do so; and
  • buyers, investors, or advisers in connection with a merger, acquisition, financing, restructuring, or sale of all or part of our business.

We share personal data only where reasonably necessary for the purposes described in this Privacy Policy, where you ask us to do so, or where we are legally required to do so.

16. Fraud Prevention and Automated Assessments

We use fraud-prevention services provided by Shopify, payment service providers, and security partners to identify potentially fraudulent, unauthorized, or high-risk transactions.

These assessments may take into account payment information, IP address, device and browser information, billing and delivery addresses, order value, transaction history, account activity, and unusual ordering patterns.

When an order is identified as high risk, we generally review the relevant signals before making a final decision. For higher-risk transactions, we may request additional verification, such as confirmation by email or proof of address.

We do not make decisions based solely on automated processing that produce legal effects or similarly significant effects for you, unless this is permitted by law.

17. Retention Periods

We do not retain personal data for longer than necessary for the purposes described in this Privacy Policy, unless we are required by law to keep it for a longer period.

The retention period depends, among other things, on:

  • the duration of our relationship with you;
  • the time required to process orders, returns, refunds, and warranty claims;
  • tax, accounting, and statutory retention obligations;
  • fraud prevention and security;
  • ongoing disputes, claims, or investigations;
  • marketing preferences and consent records; and
  • technical backup and deletion cycles.

When personal data is no longer needed, we delete, anonymize, aggregate, or securely isolate it, to the extent technically and legally possible.

18. Security

We take appropriate technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration, destruction, or disclosure.

These measures may include encryption in transit, access restrictions, account authentication, security monitoring, fraud detection, restricted employee access, and agreements with service providers.

However, no internet transmission, storage method, or security measure can be guaranteed to be completely secure. You should therefore also protect your account details and contact us immediately if you suspect that someone has gained unauthorized access to your account.

19. International Transfers

We and our service providers may process personal data in countries outside the European Economic Area, including the United States. The privacy laws in those countries may differ from those within the European Economic Area.

Where personal data is transferred outside the European Economic Area, we implement appropriate safeguards required by the GDPR. These may include an adequacy decision by the European Commission, Standard Contractual Clauses, or other appropriate protective measures.

20. Your Privacy Rights

Where the GDPR applies to you, you have the right to:

  • request access to your personal data;
  • have inaccurate or incomplete personal data corrected;
  • have your personal data deleted;
  • restrict the processing of your personal data;
  • object to the processing of your personal data, including direct marketing;
  • receive your personal data in a structured, commonly used, and machine-readable format or have it transferred;
  • withdraw your consent; and
  • lodge a complaint with a competent data protection supervisory authority, including a competent authority in Germany or the Dutch Data Protection Authority (Autoriteit Persoonsgegevens), as applicable.

You can submit a privacy request via info@fratelli-orsini.com with the subject line “Privacy Request.” Please clearly state which right you wish to exercise and provide sufficient information for us to process your request.

We may ask you for additional information to verify your identity and protect your personal data. We will request only information that is reasonably necessary for this verification.

We generally respond to your request within one month. If your request is complex or if we receive a large number of requests, we may extend this period in accordance with the GDPR.

21. Children’s Privacy

Our Website and services are not intended for persons under 16 years of age. We do not knowingly collect personal data from children under 16 without the required consent of a parent or legal representative.

If you believe that a child under 16 has provided personal data to us, please contact us so that we can investigate and, where necessary, delete the data.

22. Links to Third-Party Websites

Our Website may contain links to third-party websites, apps, payment services, social-media platforms, review services, and other services. These parties have their own privacy policies and practices.

We are not responsible for the privacy, security, availability, or content practices of independently operated third-party services. Please review the relevant third party’s privacy policy before sharing personal data with them.

23. Changes to This Privacy Policy

We may update this Privacy Policy from time to time, for example because of changes to our practices, service providers, technology, Website functionality, privacy choices, legislation, or regulatory guidance.

The most current version will be published on this page with an updated “Last updated” date. If a change is material and the law requires it, we will provide appropriate notice.

24. Contact

If you have questions about this Privacy Policy, our privacy practices, or your privacy rights, please contact us:

Fratelli Orsini B.V.
Herengracht 420
1017 BZ Amsterdam
The Netherlands
Dutch Chamber of Commerce (KvK) number: 81645007

Email: info@fratelli-orsini.com