Introduction

Benelli Armi S.p.A., Franchi Division, based in Via della Stazione 50, 61029 Urbino (PU), as data controller works to ensure the confidentiality of your personal data and guarantees them the necessary protection from any event that may put them at risk of infringement.

Benelli Armi S.p.A., thus also Franchi Division as Benelli Armi S.p.A.’s brand, implements policies and practices regarding the collection and use of personal data and the exercise of the rights that you have under the applicable legislation. Benelli Armi S.p.A. updates its policies and practices for the protection of personal data whenever this becomes necessary and in any case in the event of regulatory and organisational changes that may affect the processing of your personal data.

Benelli Armi S.p.A. has designated an internal privacy representative who you may contact at the following email address privacy@franchi.com should you have questions about the policies and practices implemented by Benelli Armi S.p.A.

 

Types of data collected:

1) browsing data:

The computer systems and software procedures designated for the functioning of this website and of all websites referable to Benelli Armi products and promotions collect certain personal data during their normal operation, the transmission of which is implicit in the use of internet communication protocols.

These data consist of information not collected in order to be associated with identified data subjects, but that by their very nature could allow users to be identified through processing and association with data held by third parties.

This category of data includes IP addresses or domain names of computers used by users who connect to the site, addresses in URI (Uniform Resource Identifier) notation of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the digital code indicating the status of the response given by the server (successfully completed, error, etc.) and other parameters relating to the user’s operating system and computer environment.

These collected data may be used to ascertain liability in the event of potential computer crimes to the detriment of the website.

2) data provided by the user:

The optional, explicit and voluntary transmission of data as requested by various sections of the above website are used to perform requests made by the user, with special reference to the data entered by the companies and the professionals in the registration pages required for the request and candidacy for training. (by way of example but not limitation: when the user requests information or more details by writing to the email addresses appearing on the homepage or in the internal pages of the website, or else when an unsolicited CV is sent in search of employment, or when direct telephone calls or fax communications are made to the numbers indicated in the “Contacts” section). The above website contains specific information for special services requested by the user.

 

Computer security

Benelli Armi S.p.A. and its suppliers (third parties and/or recipients) process your personal data, your digital data (e.g. accesses), traffic data or other data obtained for services made available through Benelli Armi S.p.A. websites to the extent strictly necessary to ensure the security and ability of a network or servers connected to it to withstand at a given level of security unforeseen events or illicit or malicious acts that compromise the availability, authenticity, integrity and confidentiality of stored or submitted personal data.

For these purposes, Benelli Armi S.p.A. provides procedures for the management of data breaches in compliance with legal obligations.

 

Nature of data provision?

Browsing data are processed for the purposes of performing computer protocols: users are free to give their personal data and their provision is optional.

 

Third parties and recipients?

The processing of your personal data takes place depending on the contract and the legal and/or regulatory obligations deriving from it.

Your data will not be disclosed to third parties/recipients for their own purposes unless:

  • you give your consent;
  • it is necessary for the fulfilment of the obligations associated with the contract and by the laws that govern it (e.g. for the defence of your rights, for a complaint to the supervisory authorities, etc.);
  • disclosure is made to companies of the group to which Benelli Armi S.p.A. belongs for administrative purposes; data processing and IT service companies (e.g. web hosting, data entry, management and maintenance of infrastructure and IT services, etc.);
  • disclosure is made to financial administration and public supervisory and control bodies with respect to which Benelli Armi S.p.A. must fulfil specific obligations deriving from the specific nature of the business.

 

Cookies?

The Data Controller uses cookies as described in detail in the Cookie Policy on the company’s website and on all websites referable to Benelli Armi products and promotions.

 

Where?

Data are stored in paper, computerized and electronic archives located in the European Economic Area where proper measures are ensured to maintain their security.

 

How?

The processing of data is performed through paper supports or computerized procedures by internal, specially authorised and trained, personnel. This personnel is allowed to access your personal data in the measure and within the limits necessary for performing the processing procedures that regard you.

The Data Controller periodically verifies the tools through which your data are processed as well as the related security measures that are constantly updated; verification, also through persons authorised to process the data, that personal data not necessary for collection are not collected, processed or stored; verification that the data are stored with the guarantee of integrity and authenticity and their use for the purposes of processing actually performed.

 

For how long?

Personal data are stored for 1 (one) year in electronic databases protected by means of effective and adequate security measures to counter the risks of violation considered by the Data Controller.

 

What are your rights?

Without prejudice to the limits established above for the processing of your personal data, you have the right to always be in control of your data. You have the following rights with regard to your data:

  • access;
  • correction;
  • erasure;
  • restriction of processing;
  • opposition to processing;

 

Your rights are guaranteed without any particular obligations or procedures for their exercise, which is essentially understood to be free of charge. You have the right:

  • to obtain a copy of the data you have requested access to, even in electronic format. If you need to request additional copies, the Controller can charge you a reasonable fee;
  • to obtain the erasure of the data or the restriction of their processing, or even the updating and correction of your personal data, and that upon your request any data disclosed to third parties/recipients will also be updated unless there are legitimate reasons that take precedence over your request (e.g. environmental investigations and risk containment due to an emergency managed by the Data Controller);
  • to obtain any useful communication regarding the activities carried out following the exercise of your rights, without delay and in any case within one month of your request, unless justifiably extended up to two months, which must be duly communicated to you.

For further information or to submit your request, please contact privacy@franchi.com.

 

Who can you submit complaints to?

Without prejudice to any other administrative or judicial proceedings, you may lodge a complaint with the competent supervisory authority, i.e. the one having jurisdiction where you reside or work in Italy or in a different Member Nation where the violation of Regulation (EU) 2016/679 occurred.

Introduction
Benelli Armi S.p.A., Franchi Division, based in Via della Stazione 50, 61029 Urbino (PU), as data controller works to ensure the confidentiality of your personal data and guarantees them the necessary protection from any event that may put them at risk of infringement. Benelli Armi S.p.A., thus also Franchi Division as Benelli Armi S.p.A.’s brand, implements policies and practices regarding the collection and use of personal data and the exercise of the rights that you have under the applicable legislation. Benelli Armi S.p.A. updates its policies and practices for the protection of personal data whenever this becomes necessary and in any case in the event of regulatory and organisational changes that may affect the processing of your personal data.
Benelli Armi S.p.A. has designated an internal privacy representative who you can contact at the following email address privacy@franchi.com if you have questions about the policies and practices implemented by Benelli Armi S.p.A.

What types of data do we collect?
Your data are the IP address and the cookies as indicated in the table below.

What are cookies and for what purposes are they used?
A “cookie” is a small text file created by some websites on the user’s computer when s/he accesses a certain site. Their purpose is to store and transport information. Cookies are sent by a web server (which is the computer being used to visit the website) to the user’s browser (Internet Explorer, Mozilla Firefox, Google Chrome, etc.) and stored on the computer of the user; they are resent to the website when the user makes later visits.
Some operations may not be executed without the use of cookies, in some cases which are technically necessary. In other cases, the site uses cookies to facilitate browsing by the user or to allow him/her to make use of the specifically requested services.
Cookies can remain in the system even for long periods of time and can also contain a unique ID code. This allows websites that use them to keep track of the user’s browsing of the site for statistical or advertising purposes, i.e., to create a personalised profile of the user starting from the pages the user has visited and show and/or send him/herbehavioural advertising.

Which cookies are used and for what purposes?

This website (like all the sites referable to Benelli Armi products and promotions) use different types of technical cookies, but does not use profiling cookies.
In the section below, the Controller outlines the specific categories of cookies utilised, their purpose and what happens when you opt out of them.

COOKIE TYPE PURPOSES COOKIE RETENTION RESULT IN CASE OF OPTING OUT
Technical cookies Site management. They allow the operation and safe and efficient browsing of the website. Valid for the browsing session. These cookies are necessary for visiting the website. Disabling them will not allow the site to operate.
Functional cookies They facilitate browsing and the service provided to the user according to a set of criteria selected by the user. Valid for the browsing session. Without them, choices made by the user while visiting the site cannot be saved.
Third-party analytics cookies They collect information in aggregate form on browsing by the user to optimise the browsing experience and the actual services. Established by the third party. Without them, the Controller would no longer be able to acquire aggregate information.

 

Which and what are third-party cookies?

This website (like all the websites referable to Benelli Armi products and promotions) also contain third-party cookies, i.e. cookies created by a website other than the site the user is currently visiting.
Pursuant to the Privacy Regulation of 8 May 2014, the Controller has the obligation to provide the updated link to the privacy policies and the consent forms of the third parties with which they have stipulated agreements for the installation of cookies through their site.
Specifically, users should take note that the website uses the following services that leave cookies:
– “Google Analytics”, the web analysis service provided by Google, Inc. Google Analytics is a web analysis service that uses cookies stored on the user’s computer to allow the visited website to analyse how visitors use it. The information generated by the cookie on the use of the website visited (including IP address) will be transmitted to Google and stored on Google servers in the United States. Google will use this information for the purposes of tracking and examining the use of the website by the user, compile reports on the activities of the website for operators of the site and provide other services related to the activities of the website and the use of the internet. To consult the Google privacy policy regarding the Google Analytics service, and to express consent for the use of the cookies described above, please visit the website http://www.google.com/intl/en/analytics/privacyoverview.html , and click on the following link: https://www.google.com/policies/privacy/.

 

What are Social buttons?

The website www.franchi.com and www.benelli.it (like all the sites referable to Benelli Armi products and promotions) feature social buttons/widgets in the form of graphic icons of the social networks (Facebook, Linkedin, etc.) and other web services (Youtube, etc.). These buttons allow the users who are browsing the site to interact by means of a click directly with the social networks and web services indicated there and to share the information collected on the website being visited. In this case, the social network and web services acquire the data regarding the visit of the user, whereas the Controller will not share any browsing information or data of the user acquired through its site with the social networks and web services accessed via the social buttons/widgets. These services leave third-party cookies. Below are the links to the privacy policies of the social networks most commonly used and the websites which the buttons connect to:

Third parties and recipients?

The processing of your personal data takes place depending on the contract and the legal and/or regulatory obligations deriving from it.

Your data will not be disclosed to third parties/recipients for their own purposes unless:

  • you give your consent;
  • it is necessary for the fulfilment of the obligations associated with the contract and by the laws that govern it (e.g. for the defence of your rights, for a complaint to the supervisory authorities, etc.);
  • disclosure is made to companies of the group to which Benelli Armi S.p.A. belongs for administrative purposes; data processing and IT service companies (e.g. web hosting, data entry, management and maintenance of infrastructure and IT services, etc.);
  • disclosure is made to financial administration and public supervisory and control bodies with respect to which Benelli Armi S.p.A. must fulfil specific obligations deriving from the specific nature of the business.

What happens if you do not provide your data?

Please see the table referred to above for information on the consequences of not providing your personal data. The Controller reminds you that you may opt out of cookies at any time by following the instructions below.

Disabling and enabling cookies

By accessing the site and continuing after the banner containing a short version of the cookie policy appears, the user has given his/her express consent to the use of cookies in the present document.
The user may freely enable or disable the individual cookies through his/her browser (selecting the settings menu, clicking on internet options, opening the tab regarding privacy and choosing the desired setting for blocking cookies). For more information, please consult the following links: Google Chrome, Mozilla FirefoxApple Safari and Microsoft Windows Explorer.
In addition, the user can enable the option Do Not Track in the latest generation of browsers.
Third-party cookies can be disabled by accessing the privacy policy of the third party through the above link or by contacting the third party directly. Disabling third-party cookies will not affect browsing of the site in any way.

Where?
Data are stored in paper, computerized and electronic archives located in the European Economic Area where proper measures are ensured to maintain their security.

How?
The processing of data is performed through paper supports or computerized procedures by internal, specially authorised and trained, personnel. This personnel is allowed to access your personal data in the measure and within the limits necessary for performing the processing procedures that regard you.
The Data Controller periodically verifies the tools through which your data are processed as well as the related security measures that are constantly updated; verification, also through persons authorised to process the data, that personal data not necessary for collection are not collected, processed or stored; verification that the data are stored with the guarantee of integrity and authenticity and their use for the purposes of processing actually performed.

Computer security
Benelli Armi S.p.A. and its suppliers (third parties and/or recipients) process your personal data, your digital data (e.g. accesses), traffic data or other data obtained for services made available through Benelli Armi S.p.A. websites to the extent strictly necessary to ensure the security and ability of a network or servers connected to it to withstand at a given level of security unforeseen events or illicit or malicious acts that compromise the availability, authenticity, integrity and confidentiality of stored or submitted personal data.
For these purposes, Benelli Armi S.p.A. provides procedures for the management of data breaches in compliance with legal obligations.

For how long?
Personal data are stored as needed in electronic archives protected by means of effective and adequate security measures to counter the risks of violation considered by the Data Controller. Please see the table referred to above for information on the retention of the different types of cookies.

What are your rights?
Without prejudice to the limits established above for the processing of your personal data, you have the right to always be in control of your data. You have the following rights with regard to your data:

  • access;
  • correction;
  • erasure;
  • restriction of processing;
  • opposition to processing;
  • portability.

Your rights are guaranteed without any particular obligations or procedures for their exercise, which is essentially understood to be free of charge. You have the right:

  • to obtain a copy of the data you have requested access to, even in electronic format. If you need to request additional copies, the Controller can charge you a reasonable fee;
  • to obtain the erasure of the data or the restriction of their processing, or even the updating and correction of your personal data, and that upon your request any data disclosed to third parties/recipients will also be updated unless there are legitimate reasons that take precedence over your request (e.g. environmental investigations and risk containment due to an emergency managed by the Data Controller);
  • to obtain any useful communication regarding the activities carried out following the exercise of your rights, without delay and in any case within one month of your request, unless justifiably extended up to two months, which must be duly communicated to you.

For further information and in any case to submit any requests, please contact privacy@franchi.com.

Who can you submit complaints to?
Without prejudice to any other administrative or judicial proceedings, you may lodge a complaint with the competent supervisory authority, i.e. the one having jurisdiction where you reside or work in Italy or in a different Member Nation where the violation of Regulation (EU) 2016/679 occurred.

Who are we and what do we do with your personal data?
Benelli Armi S.p.A., Franchi Division, with registered office in Via della Stazione 50, 61029 Urbino (PU), as data controller works to ensure the confidentiality of your personal data and guarantees them the necessary protection from any event that may put them at risk of infringement.
Benelli Armi S.p.A. thus also Franchi Division as Benelli Armi S.p.A.’s brand, implements policies and practices regarding the collection and use of personal data and the exercise of the rights that you have under the applicable legislation. Benelli Armi S.p.A. updates its policies and practices for the protection of personal data whenever this becomes necessary and in any case in the event of regulatory and organisational changes that may affect the processing of your personal data.
Benelli Armi S.p.A. has designated an internal privacy representative who you can contact at the following email address privacy@franchi.com if you have questions about the policies and practices implemented by Benelli Armi S.p.A.

How does Benelli Armi S.p.A. Franchi Division collect and process your data?
Benelli Armi S.p.A. collects and/or receives information about you, like: name, surname, tax code, place and date of birth, physical and digital address, telephone and/or cell phone number, bank account number, firearms licence number, firearm model and serial number. This information is used by Benelli Armi S.p.A. to respond to your request for the issuance of the Certificate of Warranty for the product purchased from Benelli Armi S.p.A. or the authorised armoury and for the fulfilment of the legal and regulatory obligations Benelli Armi S.p.A. is subject to due to its line of business. Your personal data is primarily disclosed to third parties and/or recipients whose activity is necessary for the proper performance of the service (firearms repairs) or to improve the products (armoury and similar) that Benelli Armi S.p.A. offers you and also to respond to specific legal obligations or prescribed for the control and supervision of the activities performed by Benelli Armi Spa. Any disclosure that does not correspond to these purposes requires your consent. Your data (like name, surname, physical or digital address, mobile phone number and/or telephone number) may also be processed for the purposes of commercial promotion, profiling, surveys and market research with regard to products and services that Benelli Armi S.p.A. offers you only if you consent to the processing and/or if you do not object to it.
Benelli Armi S.p.A. does not transfer your personal data outside the European Union. Your personal data will not be disseminated or disclosed to indeterminate and non-identifiable parties, even as third parties.
Your personal information will be processed:
1) For the management of your warranty claim on the Benelli Armi S.p.A. Franchi Division product
Your data will be processed to respond to your request for the issuance of the Certificate of Warranty for the product purchased from Benelli Armi S.p.A. or the authorised armoury and for the fulfilment of the legal and regulatory obligations Benelli Armi S.p.A. is subject to due to its line of business.
Your personal data are also collected from third parties like, for example:

  • Other data controllers, e.g. the companies belonging to the same group as Benelli Armi S.p.A.
  • Sales representatives, agents, and dealers.
  • Private and public bodies operating in the industry nationally and internationally with which the data controller has established informative relationships.

The personal data that Benelli Armi S.p.A. deals with for this purpose are, among others: name, surname, physical and digital address, telephone number and/or cell phone number, model of firearm and serial number of the firearm.
The obligations with which Benelli Armi S.p.A. must comply based on the contract and specific pertinent regulations include, among other things:

  • Keeping accounting records.
  • The monitoring of the activity and its control and supervision in compliance with the provisions deriving from national and international regulations and/or laws (e.g. TULPS – Consolidated Text of Laws on Public Security, Law no. 185/90, United Nations Charter, etc.) in force in the specific industry and with which Benelli Armi S.p.A. must comply.

2) For disclosure to third parties and recipients
The processing of your personal data takes place depending on the contract and the legal and/or regulatory obligations deriving from it.
Your data will not be disclosed to third parties/recipients for their own purposes unless:

  • You give your consent.
  • It is necessary for the fulfilment of the obligations associated with the contract and by the laws that govern it (e.g. for the defence of your rights, for a complaint to the supervisory authorities, etc.).
  • Disclosure is made to companies of the group to which Benelli Armi S.p.A. belongs for administrative purposes; companies and law firms for the protection of contractual rights and/or that deal in debt recovery; transport companies and shippers for the aspects related to freight shipments and customs procedures; data processing and IT service companies (e.g. web hosting, data entry, management and maintenance of IT infrastructure and services, etc.).
  • Disclosure is made to financial administration and public supervisory and control bodies with respect to which Benelli Armi S.p.A. must fulfil specific obligations deriving from the specific nature of the business.

The personal data that Benelli Armi S.p.A. processes for this purpose are, among others:

  • Name, surname, tax code or VAT number, place and date of birth, physical and digital address, telephone number and/or cell phone number, firearms licence number, model and serial number.
  • Data relating to the commercial activity and/or work activity and/or the family condition of the customer.

3) For business promotion
The processing of your personal data takes place to offer you products and services in addition to those related to your purchase, to send you advertising material. The processing of your data (like name, surname, physical and digital address, telephone number and/or cell phone number) can be done by:

  • Email.
  • Text message.
  • Telephone contact even without an operator.
  • Mail.

The processing in question can be carried out:

  • If you give your consent for the use of your data also with regard to the methods of communication by which the processing takes place, whether traditional or automated.
  • If you are not in the opt-out register referred to in Italian Presidential Decree no. 178/2010, for processing carried out by a contact via telephone operator.
  • If you did not object to processing and/or if you did not specifically and separately object to the sending of communications through traditional and/or automatic methods.

During processing your data may be disclosed to third parties like: marketing services companies, companies that provide advice or solutions for business information, direct marketing, geomarketing, etc. These parties process your data (name, surname, physical address, email, phone number and cell phone number) for marketing purposes on behalf of the Data Controller.
4) For the disclosure of data to partners and/or the companies of the group to which Benelli Armi S.p.A. Franchi Division belongs for marketing activities (direct marketing, research and market surveys) autonomously carried out by them.
The disclosure of your personal data (like name, surname, physical and digital address, cell phone number and/or telephone number) to Benelli Armi S.p.A.’s commercial partners (agents, companies operating in the same sector, etc.) and/or the companies of the group to which it belongs may take place for their own marketing purposes, only if you consent to such processing.
5) For profiling
Your personal data may be processed for analysis of consumption habits and choices, defining individual profiles in order to send commercial and promotional information relevant to your latest purchases and preferences.
The processing in question can be carried out:

  • If you give your consent for the use of your data also with regard to the methods of communication by which the processing takes place, whether traditional or automated.
  • If you are not in the opt-out register referred to in Italian Presidential Decree no. 178/2010, for processing carried out by a contact via telephone operator.
  • If you did not object to processing and/or if you did not specifically and separately object to the sending of communications through traditional and/or automatic methods.

In case of processing, your data may be disclosed to third parties like: profiling services companies, companies that provide advice or solutions for business information, direct marketing, etc. These parties process your data (name, surname, physical address, email, telephone number and cell phone number, information related to your commercial and/or work activity and/or family condition, information regarding your last purchases, etc.) for the purpose of profiling on behalf of the Controller.
6) For information security purposes
Benelli Armi S.p.A. and its suppliers (third parties and/or recipients) process your personal data, your digital data (e.g. accesses), traffic data or other data obtained for services made available through the Benelli Armi S.p.A. website to the extent strictly necessary to ensure the security and ability of a network or servers connected to it to withstand at a given level of security unforeseen events or illicit or malicious acts that compromise the availability, authenticity, integrity and confidentiality of stored or submitted personal data.
For these purposes, Benelli Armi S.p.A. provides procedures for the management of data breaches in compliance with legal obligations.

What happens if you do not provide your data?
If you do not provide your personal data, Benelli Armi S.p.A. will not be able to issue the Certificate of Warranty, and it will not be able to proceed with the processing associated with the management of the contract and the services associated with it or with the obligations that depend on them.
Benelli Armi S.p.A. intends to carry out certain processing based on certain legitimate interests that do not affect your right to privacy, like those that:

  • Allow the prevention of IT incidents and the notification of the supervisory authority or, if necessary, the communication to users of the breach of the personal data.
  • Allow disclosure of personal data to the companies belonging to the same group as Benelli Armi S.p.A. for administrative purposes.
  • Allow disclosure to third parties/recipients for activities associated with the management of the contract.

What happens if you do not consent to the processing of personal data for marketing purposes (direct marketing, research and market surveys) by Benelli Armi S.p.A. Franchi Division or to disclosure to third parties/recipients for marketing purposes pursued by them independently or for profiling?
Your personal data will not be processed for these purposes. This will not affect the processing of your data for the main purposes or for which you have already given your consent, if required.
If you have given consent and subsequently withdraw it or chosen not to consent to processing for marketing and/or profiling purposes, your data will no longer be processed for marketing and/or profiling purposes without this having any detrimental consequences or effects for you and for the contract you signed.

How and for how long are your data stored?
The processing of your data is carried out using electronic and manual means and tools made available to parties acting under the authority of Benelli Armi S.p.A. and specifically authorised and trained for this purpose. The paper and especially electronic archives where your data are archived and stored are protected by effective security measures that are able to counter the risks of breach considered by Benelli Armi S.p.A. Benelli Armi S.p.A. provides for periodic and constant verification of the measures implemented, especially for electronic and online tools, to guarantee the confidentiality of personal data that are thereby processed, archived and stored, especially if belonging to particular categories.
Personal data are stored for the time necessary to complete the activities related to the management of the contract with Benelli Armi S.p.A. and for the fulfilment of related obligations, legal or otherwise. For data intended for marketing purposes (direct marketing, research and market surveys) that you have consented to you are always allowed to object to the corresponding processing and/or to withdraw consent,
The computer files are located within the borders of the EU (and EEA) and do not connect or interact with databases located abroad.
How
The processing of data is performed through paper supports or computerized procedures by internal, specially authorised and trained, personnel. This personnel is allowed to access your personal data in the measure and within the limits necessary for performing the processing procedures that regard you.
Benelli Armi S.p.A. periodically verifies the tools through which your data are processed as well as the related security measures that are constantly updated; verification, also through persons authorised to process the data, that personal data not necessary for collection are not collected, processed or stored; verification that the data are stored with the guarantee of integrity and authenticity and their use for the purposes of processing actually performed.
Where
Data are stored in paper, computerized and electronic archives located in the European Economic Area where proper measures are ensured to maintain their security.
How long
The personal data processed by Benelli Armi S.p.A. are kept for the time necessary to complete the activities related to the management of the contract with Benelli Armi S.p.A. and up to ten years after its conclusion (art. 2946 of the Italian Civil Code) or from when the rights that depend on it may be exercised (pursuant to art. 2935 of the Italian Civil Code); as well as for the fulfilment of the obligations (e.g. tax and accounting) that remain after the conclusion of the contract (art. 2220 of the Italian Civil Code), for which Benelli Armi S.p.A. must keep only the data necessary for compliance. Except in cases where the rights deriving from the contract are to be exercised in court, in which case your data – only those necessary for such purposes – will be processed for the time necessary.
The personal data processed by Benelli Armi S.p.A. for marketing purposes (direct marketing, research and market surveys) will be kept for five years by Benelli Armi S.p.A. subject to withdrawal of the consent you have given and/or subject to your opposition to such processing.
The personal data processed by Benelli Armi S.p.A. for profiling will be kept for two years by Benelli Armi S.p.A. subject to withdrawal of the consent you have given and/or subject to your opposition to such processing.
In any case, you retain the right to object to processing at any time based on a legitimate interest for reasons associated with your particular situation.
Personal data processed by Benelli Armi S.p.A. for the purposes of Public Safety will necessarily be kept for at least 50 years as envisaged by TULPS and related regulations, without any possibility for you to withdraw consent pursuant to Italian Legislative Decree no. 204 of 26 October 2010.

What are your rights?
Regulations give you the right to always have control of your data. You have the following rights with regard to your data:

  • Access.
  • Correction.
  • Erasure.
  • Withdrawal of consent.
  • Restriction of processing.
  • Opposition to processing.
  • Portability.

Your rights are guaranteed without any particular obligations or procedures for their exercise, which is essentially understood to be free of charge. You have the right:

  • To obtain a copy of the data you have requested access to, even in electronic format. If you need to request additional copies, Benelli Armi S.p.A. can charge you a reasonable fee.
  • To have them erased or the processing restricted or even obtain the updating and correction of your personal data.
  • If your data have been disclosed to others, in these latter cases you have the right for the other data controllers or recipients to be informed by Benelli Armi S.p.A. of your request and the outcome of the exercise of your rights so that they can also erase, suspend or interrupt the processing or correct your data.
  • To obtain any useful communication regarding the activities carried out following the exercise of your rights, without delay and in any case within one month of your request, unless justifiably extended up to two months, which must be duly communicated to you.

Essentially, at any time and free of charge and without any particular obligations or procedures for your request, you can:

  • Receive confirmation of the processing performed by Benelli Armi S.p.A.
  • Access your personal data and know their origin (when the data are not obtained from you directly), the purposes of the processing, the data of the parties to whom they are disclosed, the storage period for your data or criteria useful for determining it.
  • Withdraw consent at any time if consent is the basis for the processing. However, the withdrawal of consent does not prejudice the lawfulness of the processing based on the consent given before the withdrawal.
  • Update or rectify your personal data so that they are always accurate.
  • Erase your personal data from the databases and/or archives, including backups, of Benelli Armi S.p.A. in the case, among others, where they are no longer necessary for the purposes of the processing or if processing is assumed to be illegitimate and if the conditions established by law exist, and in any case if the processing is not justified by another equally legitimate reason.
  • Restrict the processing of your personal data in certain circumstances, for example where you have challenged their accuracy, for the period necessary for Benelli Armi S.p.A. to verify their accuracy. You must be informed in a reasonable time even when the suspension period has expired or the reason for the restriction of processing no longer exists and therefore the restriction itself is revoked.
  • Obtain your personal data – if received and/or otherwise processed by Benelli Armi S.p.A. with your consent and/or if their processing is done on the basis of a contract and with automated tools – in electronic format, even in order to transmit them to another data controller.

Benelli Armi S.p.A. must respond without delay and, in any case, no later than one month after receiving your request. The deadline may be extended by two months if necessary, considering the complexity and the number of requests received by Benelli Armi S.p.A. In such cases, Benelli Armi S.p.A. will inform you within one month of receiving your request and will inform you of the reasons for the extension.
For further information and in any case to submit any requests, please contact Benelli Armi S.p.A. at the address privacy@franchi.com.

How and when can you object to the processing of your personal data?
For reasons related to your particular situation, you may object at any time to the processing of your personal data if it is based on a legitimate interest or if it is for marketing purposes (direct marketing, research and market surveys), sending your request to Benelli Armi S.p.A. at the address privacy@franchi.com.
You have the right to the erasure of your personal data if there is no other prevailing legitimate reason with respect to your request, and in any case if you object to processing for marketing purposes (direct marketing, research and market surveys).

Who can you submit complaints to?
Without prejudice to any other action in administrative or judicial proceedings, you can lodge a complaint with the competent supervisory authority or with the authority carrying out its duties and exercising its powers in Italy, without prejudice to the cases in which the jurisdiction of the supervisory authority established in another member state is recognised in accordance with the provisions of the law. 
Every update of this privacy policy will be communicated to you promptly and by means of a reasonable means, and you will be notified as well if Benelli Armi S.p.A. processes your data for purposes other than those set out in this policy before proceeding and giving you time to provide your consent if necessary.

Who are we and what do we do with your personal data?
Benelli Armi S.p.A., Franchi Division, based in Via della Stazione 50, 61029 Urbino (PU), as data controller works to ensure the confidentiality of your personal data and guarantees them the necessary protection from any event that may put them at risk of infringement.
Benelli Armi S.p.A., thus also Franchi Division as Benelli Armi S.p.A.’s brand, implements policies and practices regarding the collection and use of personal data and the exercise of the rights that you have under the applicable legislation. Benelli Armi S.p.A. updates its policies and practices for the protection of personal data whenever this becomes necessary and in any case in the event of regulatory and organisational changes that may affect the processing of your personal data.
Benelli Armi S.p.A. has designated an internal privacy representative who you can contact at the following email address privacy@franchi.com if you have questions about the policies and practices implemented by Benelli Armi S.p.A.

How does Benelli Armi S.p.A. Franchi Division collect and process your data?
Benelli Armi S.p.A. collects and/or receives information about you, like: name, surname, tax code, place and date of birth, physical and digital address, telephone number and/or cell phone number, CV data, as well as data relating to your health if disclosed in your CV or if the position you are applying for is reserved for protected categories. The data are used by Benelli Armi S.p.A. to verify the conditions for your hiring and/or for the start of your collaboration with Benelli Armi S.p.A. Your personal data are disclosed primarily to third parties and/or recipients whose involvement is necessary for the performance of activities related to the recruitment of personnel. Any disclosure that does not correspond to these purposes requires your consent.
Benelli Armi S.p.A. does not transfer your personal data abroad. Your personal data will not be disseminated or disclosed to indeterminate and non-identifiable parties, even as third parties.
Specifically, your personal information will be processed:
1) For the recruitment of personnel and/or the start of a collaboration
Your personal data is processed to carry out the activities related to the recruitment of personnel for Benelli Armi S.p.A., like:

  • The search for candidates for jobs initiated by Benelli Armi S.p.A. or other companies in the group of the Data Controller.
  • The collection of applications and CVs that arrive from two sources: internal (job ads posted by Benelli Armi S.p.A., unsolicited CVs) and external to Benelli Armi S.p.A. (job ads posted by recruitment agencies, employment agencies, universities, schools, in newspapers, magazines, trade periodicals).
  • The examination of the CVs received for a first screening.
  • The organisation of job interviews.
  • Benelli Armi S.p.A.’s hiring of the most suitable candidate.
  • The fulfilment of specific obligations and the execution of specific tasks deriving from laws, regulations or collective agreements, corporate or otherwise, in particular for the purpose of establishing the employment relationship and/or a contractual relationship, as well as the identification of any tax relief applicable to the contractual relationship with parties belonging to protected categories.

Your personal data are also collected from third parties like, for example:

  • Other data controllers, e.g. the companies belonging to the same group as Benelli Armi S.p.A.
  • Private and public parties that offer services like temporary workers, brokers, personnel recruitment, job training and support for professional outplacement.
  • Universities and schools.
  • Family members and cohabitants.
  • Information and IT support companies.

The personal data that Benelli Armi S.p.A. processes for these purposes are, among others:

  • Name, surname, tax code, place and date of birth, physical and digital address, telephone number and/or cell phone number.
  • CV data.
  • Health status if required by the type of application or if you disclosed it in your CV.

Where envisaged, you retain the right to rectify the data provided or collected by Benelli Armi S.p.A.
2) For disclosure to third parties and recipients
Your data will not be disclosed to third parties/recipients for their own purposes unless:

  • You give your consent.
  • It is necessary for the fulfilment of the obligations associated with the laws that govern it (e.g. for the defence of your rights etc.).
  • Data are disclosed to companies in the same group as Benelli Armi S.p.A. for administrative purposes; private parties that offer services like temporary workers, brokers, personnel recruitment, job training and support for professional outplacement; universities and schools; family members and cohabitants, and information and IT support companies.

The personal data that Benelli Armi S.p.A. processes for this purpose are, among others:

  • Name, surname, tax code, place and date of birth, physical and digital address, telephone number and/or cell phone number.
  • CV data.

and, if necessary and with all necessary precautions including pseudonymisation, aggregation and/or encryption of data as required:

  • Health status.

3) For information security purposes
Benelli Armi S.p.A. and its suppliers (third parties and/or recipients) process your personal data, your digital data (e.g. accesses), traffic data or other data obtained for services made available (e.g. “Work with us”) through the Benelli Armi S.p.A. website to the extent strictly necessary to ensure the security and ability of a network or servers connected to it to withstand at a given level of security unforeseen events or illicit or malicious acts that compromise the availability, authenticity, integrity and confidentiality of stored or submitted personal data.
For these purposes, Benelli Armi S.p.A. provides procedures for the management of data breaches in compliance with legal obligations.

What happens if you do not provide your data?
The data that Benelli Armi S.p.A. collects or otherwise obtains are considered necessary, and failure to provide them will make it impossible for Benelli Armi S.p.A. to perform the primary processing activities, specifically:

  • Assess your application as part of the recruitment process carried out by Benelli Armi S.p.A., even with the assistance of its suppliers (third parties/recipients).
  • Manage the recruitment process in all its phases.
  • Satisfy the corresponding obligations.

Benelli Armi S.p.A. intends to carry out certain processing based on certain legitimate interests that do not affect your right to privacy, like those that:

  • Allow the prevention of IT incidents and the notification of the supervisory authority or, if necessary, the communication to users of the breach of the personal data.
  • Allow disclosure of personal data to the companies belonging to the same group as Benelli Armi S.p.A. for administrative purposes.
  • Allow disclosure to third parties/recipients for activities associated with the management of the recruitment process.

How and for how long are your data stored?
The processing of your data is carried out using electronic and manual means and tools made available to parties acting under the authority of Benelli Armi S.p.A. and specifically authorised and trained for this purpose. The paper and especially electronic archives where your data are archived and stored are protected by effective security measures that are able to counter the risks of breach considered by Benelli Armi S.p.A. Benelli Armi S.p.A. provides for periodic and constant verification of the measures implemented, especially for electronic and online tools, to guarantee the confidentiality of personal data that are thereby processed, archived and stored, especially if belonging to particular categories.
Personal data are kept for the time necessary to complete the activities related to the recruitment, and in any case no later than 3 years from their collection, except if an employment and/or contractual relationship is established.
The computer files are located within the borders of the EU (and EEA) and do not connect or interact with databases located abroad.
Specifically:

  • How

The processing of data is performed through paper supports or computerized procedures by internal, specially authorised and trained, personnel. This personnel is allowed to access your personal data in the measure and within the limits necessary for performing the processing procedures that regard you. Your data, especially those belonging to particular categories, are processed separately from others, also by means of pseudonymisation or aggregation methods that do not allow you to be easily identified.
Benelli Armi S.p.A. periodically verifies the tools through which your data are processed as well as the related security measures that are constantly updated; verification, also through persons authorised to process the data, that personal data not necessary for collection are not collected, processed or stored; verification that the data are stored with the guarantee of integrity and authenticity and their use for the purposes of processing actually performed.

  • Where

Data are stored in paper, computerized and electronic archives located in the European Economic Area where proper measures are ensured to maintain their security.

  • How long

Personal data processed by Benelli Armi S.p.A. are kept for the time necessary to complete the activities related to the recruitment, and in any case no later than 3 years from their collection, except if an employment and/or contractual relationship is established. Except in cases where the rights deriving from the processing are to be exercised in court, in which case your data – only those necessary for such purposes – will be processed for the time necessary.
In any case, you retain the right to object to processing at any time based on a legitimate interest for reasons associated with your particular situation.

What are your rights?
Without prejudice to the time limits established above for the processing of your personal data, you have the right to always be in control of your data. You have the following rights with regard to your data:

  • Access.
  • Correction.
  • Erasure.
  • Restriction of processing.
  • Opposition to processing.
  • Portability if envisaged.

Your rights are guaranteed without any particular obligations or procedures for their exercise, which is essentially understood to be free of charge. You have the right:

  • To obtain a copy of the data you have requested access to, even in electronic format. If you need to request additional copies, Benelli Armi S.p.A. can charge you a reasonable fee.
  • To have them erased or the processing restricted or even obtain the updating and correction of your personal data.
  • If your data have been disclosed to others, you have the right in these latter cases for the other data controllers or recipients to be informed by Benelli Armi S.p.A. of your request and the outcome of the exercise of your rights so that they can also erase, suspend or interrupt the processing or correct your data.
  • To obtain any useful communication regarding the activities carried out following the exercise of your rights, without delay and in any case within one month of your request, unless justifiably extended up to two months, which must be duly communicated to you.

Essentially, as long as the processing continues, at any time and free of charge and without any particular obligations or procedures for your request, you can:

  • Receive confirmation of the processing performed by Benelli Armi S.p.A.
  • Access your personal data and know their origin (when the data are not obtained from you directly), the purposes of the processing, the data of the parties to whom they are disclosed, the storage period for your data or criteria useful for determining it.
  • Update or rectify your personal data so that they are always accurate.
  • Erase your personal data from the databases and/or archives, including backups, of Benelli Armi S.p.A. in the case, among others, where they are no longer necessary for the purposes of the processing or if processing is assumed to be illegitimate and if the conditions established by law exist, and in any case if the processing is not justified by another equally legitimate reason.
  • Restrict the processing of your personal data in certain circumstances, for example where you have challenged their accuracy, for the period necessary for Benelli Armi S.p.A. to verify their accuracy. You must be informed in a reasonable time even when the suspension period has expired or the reason for the restriction of processing no longer exists and therefore the restriction itself is revoked.
  • Obtain your personal data – if received or processed by Benelli Armi S.p.A. with your consent and/or if their processing is done on the basis of a contract and with automated tools – in electronic format, even in order to transmit them to another data controller.

Benelli Armi S.p.A. must respond without delay and, in any case, no later than one month after receiving your request. The deadline may be extended by two months if necessary, considering the complexity and the number of requests received by Benelli Armi S.p.A. In such cases, Benelli Armi S.p.A. must inform you within one month of receiving your request and inform you of the reasons for the extension.
For further information and in any case to submit any requests, please contact Benelli Armi S.p.A. at the address privacy@franchi.com.

How and when can you object to the processing of your personal data?
For reasons related to your particular situation, you may object at any time to the processing of your personal data if it is based on a legitimate interest, sending your request to Benelli Armi S.p.A. at the address privacy@franchi.com.
You have the right to the erasure of your personal data if there is no legitimate reason that takes precedence over your request.

Who can you submit complaints to?
Without prejudice to any other administrative or judicial actions, you can lodge a complaint with the Personal Data Protection Authority (following the instructions given by the Authority at the link: http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524), unless you reside or work in another member state. In the latter case or if the violation of the legislation on the protection of personal data takes place in another EU country, the local supervisory authorities will have jurisdiction over the complaint.

You will be promptly informed by appropriate means each time this policy is updated, and you will be notified if Benelli Armi S.p.A. processes your data for purposes other than those referred to in this policy before proceeding and in time for you to provide your consent if necessary.

Who are we and what do we do with your personal data?
Benelli Armi S.p.A., Franchi Division, with registered office in Via della Stazione 50, 61029 Urbino (PU), as data controller works to ensure the confidentiality of your personal data and guarantees them the necessary protection from any event that may put them at risk of infringement.
Benelli Armi S.p.A., thus also Franchi Division as Benelli Armi S.p.A.’s brand, implements policies and practices regarding the collection and use of personal data and the exercise of the rights that you have under the applicable legislation. Benelli Armi S.p.A. updates its policies and practices for the protection of personal data whenever this becomes necessary and in any case in the event of regulatory and organisational changes that may affect the processing of your personal data.
Benelli Armi S.p.A. has designated an internal privacy representative who you can contact at the following email address privacy@franchi.com if you have questions about the policies and practices implemented by Benelli Armi S.p.A.

How does Benelli Armi S.p.A. Franchi Division collect and process your data?
Benelli Armi S.p.A. collects and/or receives information about you, like: name, surname, tax code, place and date of birth, physical and digital address, telephone and/or cell phone number, bank account number, firearms licence number. This information is used by Benelli Armi S.p.A. to respond to your request for information on the product and/or service offered by Benelli Armi S.p.A., the management of the purchase agreement and the fulfilment of the legal and regulatory obligations Benelli Armi S.p.A. is subject to due to its line of business. Your personal data is primarily disclosed to third parties and/or recipients whose activity is necessary for the proper performance of the service (firearms repairs) or to improve the products (armoury and similar) that Benelli Armi S.p.A. offers you and also to respond to specific legal obligations or prescribed for the control and supervision of the activities performed by Benelli Armi Spa. Any disclosure that does not correspond to these purposes requires your consent. Your data (like name, surname, physical or digital address, mobile phone number and/or telephone number) may also be processed for the purposes of commercial promotion, profiling, surveys and market research with regard to products and services that Benelli Armi S.p.A. offers you only if you consent to the processing and/or if you do not object to it.
Benelli Armi S.p.A. does not transfer your personal data outside the European Union. Your personal data will not be disseminated or disclosed to indeterminate and non-identifiable parties, even as third parties.
Your personal information will be processed:
1) For the management of your request for information on the product and/or service offered by Benelli Armi S.p.A. Franchi Division
Your data will be processed to provide you with information or documents useful to describe the product or service in question, to send you a quote, contact you to agree on the price, the method of delivery, any additional products or services and for the acquisition of preliminary information on the conclusion of a contract, as well as for the recording and storage of your personal data.
Your personal data are also collected from third parties like, for example:

  • Other data controllers, e.g. the companies belonging to the same group as Benelli Armi S.p.A.
  • Sales representatives, agents, and dealers.
  • Private and public bodies operating in the industry nationally and internationally with which the data controller has established informative relationships.
  • Italian and foreign customers.
  • End users.
  • Data processing, information technology and marketing companies.

The personal data that Benelli Armi S.p.A. processes for this purpose are, among others:

  • name, surname, physical and digital address, telephone number and/or cell phone number.

2) For the management of the contractual relationship and consequent fulfilment, even under regulations
The processing of your personal data takes place to carry out preliminary activities related to your purchase, like order management, production and shipping of the purchased good, for invoicing and payment management, the handling of complaints and/or reports to the technical assistance service, management and settlement of contractual and conventional warranties, as well as for the fulfilment of any other obligations arising from the contract, like recording and storage of your personal data.
The obligations with which Benelli Armi S.p.A. must comply based on the contract and specific pertinent regulations include, among other things:

  • Keeping accounting records.
  • The monitoring of the activity and its control and supervision in compliance with the provisions deriving from national and international regulations and/or laws (e.g. TULPS – Consolidated Text of Laws on Public Security, Law no. 185/90, United Nations Charter, etc.) in force in the specific industry and with which Benelli Armi S.p.A. must comply.

Your personal data are also processed to prevent fraud, even contractual. Finally, your data (like telephone number and/or cell phone number and digital address) will be processed to provide you with assistance on the products covered by the contract with Benelli Armi S.p.A.
Your personal data are also collected from third parties like, for example:

  • Private and public bodies operating in the industry nationally and internationally with which the data controller has established informative relationships.
  • Companies belonging to the same group as Benelli Armi S.p.A.
  • Italian and foreign customers.
  • End users.
  • Data processing, information technology and marketing companies.

The personal data that Benelli Armi S.p.A. processes for this purpose are, among others:

  • name, surname, tax code or VAT number, place and date of birth, physical and digital address, telephone number and/or cell phone number, firearms licence number.
  • Data relating to the commercial activity and/or work activity and/or the family condition of the customer/armoury.

3) For disclosure to third parties and recipients
The processing of your personal data takes place depending on the contract and the legal and/or regulatory obligations deriving from it.
Your data will not be disclosed to third parties/recipients for their own purposes unless:

  • You give your consent.
  • It is necessary for the fulfilment of the obligations associated with the contract and by the laws that govern it (e.g. for the defence of your rights, for a complaint to the supervisory authorities, etc.).
  • The disclosure is made to the companies in the same group as Benelli Armi S.p.A. for administrative purposes; auditing and certification company of the financial statements; quality analysis and certification company; the network of agents that Benelli Armi uses; final consumers; transport companies and freight forwarders for aspects related to shipments of goods and customs procedures; banking institutions for the management of collections and payments; companies and law firms for the protection of contractual rights and/or dealing with debt collection; data processing and IT services companies (e.g. web hosting, data entry, management and maintenance of IT infrastructure and services, etc.) testimonials, trade associations.
  • Disclosure is made to financial administration and public supervisory and control bodies with respect to which Benelli Armi S.p.A. must fulfil specific obligations deriving from the specific nature of the business.

The personal data that Benelli Armi S.p.A. processes for this purpose are, among others:

  • name, surname, tax code or VAT number, place and date of birth, physical and digital address, telephone number and/or cell phone number, firearms licence number.
  • Data relating to the commercial activity and/or work activity and/or the family condition of the customer/armoury.

4) For business promotion
The processing of your personal data takes place to offer you products and services in addition to those related to your purchase, to send you advertising material. The processing of your data (like name, surname, physical and digital address, email, telephone number and/or cell phone number) can be done by:

  • Email.
  • Text message.
  • Telephone contact even without an operator.
  • Mail.

The processing in question can be carried out:

  • If you give your consent for the use of your data also with regard to the methods of communication by which the processing takes place, whether traditional or automated.
  • If you are not in the opt-out register referred to in Italian Presidential Decree no. 178/2010, for processing carried out by a contact via telephone operator.
  • If you did not object to processing and/or if you did not specifically and separately object to the sending of communications through traditional and/or automatic methods.

During processing your data may be disclosed to third parties like: marketing services companies, companies that provide advice or solutions for business information, direct marketing, geomarketing, etc. These parties process your data (name, surname, physical address, phone number and cell phone number) for marketing purposes on behalf of the Data Controller.
5) For the disclosure of data to partners and/or the companies of the group to which Benelli Armi S.p.A. Franchi Division belongs for marketing activities (direct marketing, research and market surveys) autonomously carried out by them.
The disclosure of your personal data (like name, surname, physical and digital address, email, cell phone number and/or telephone number) to Benelli Armi S.p.A.’s commercial partners (agents, companies operating in the same sector, etc.) and/or the companies of the group to which it belongs may take place for their own marketing purposes, only if you consent to such processing.
6) For profiling
Your personal data may be processed for analysis of consumption habits and choices, defining individual profiles in order to send commercial and promotional information relevant to your latest purchases and preferences.
The processing in question can be carried out:

  • If you give your consent for the use of your data also with regard to the methods of communication by which the processing takes place, whether traditional or automated.
  • If you are not in the opt-out register referred to in Italian Presidential Decree no. 178/2010, for processing carried out by a contact via telephone operator.
  • If you did not object to processing and/or if you did not specifically and separately object to the sending of communications through traditional and/or automatic methods.

In case of processing, your data may be disclosed to third parties like: profiling services companies, companies that provide advice or solutions for business information, direct marketing, etc. These parties process your data (name, surname, physical address, telephone number and cell phone number, information related to your commercial and/or work activity and/or family condition, information regarding your last purchases, etc.) for the purpose of profiling on behalf of the Controller.
7) For information security purposes
Benelli Armi S.p.A. and its suppliers (third parties and/or recipients) process your personal data, your digital data (e.g. accesses), traffic data or other data obtained for services made available through the Benelli Armi S.p.A. website to the extent strictly necessary to ensure the security and ability of a network or servers connected to it to withstand at a given level of security unforeseen events or illicit or malicious acts that compromise the availability, authenticity, integrity and confidentiality of stored or submitted personal data.
For these purposes, Benelli Armi S.p.A. provides procedures for the management of data breaches in compliance with legal obligations.

What happens if you do not provide your data?
If you do not provide your personal data, Benelli Armi S.p.A. will not be able to proceed with the processing activities associated with the management of the contract and the services associated with it or with the obligations that depend on them.
Benelli Armi S.p.A. intends to carry out certain processing based on certain legitimate interests that do not affect your right to privacy, like those that:

  • Allow the prevention of IT incidents and the notification of the supervisory authority or, if necessary, the communication to users of the breach of the personal data.
  • Allow disclosure of personal data to the companies belonging to the same group as Benelli Armi S.p.A. for administrative purposes.
  • Allow disclosure to third parties/recipients for activities associated with the management of the contract.

What happens if you do not consent to the processing of personal data for marketing purposes (direct marketing, research and market surveys) by Benelli Armi S.p.A. Franchi Division or to disclosure to third parties/recipients for marketing purposes pursued by them independently or for profiling?
Your personal data will not be processed for these purposes. This will not affect the processing of your data for the main purposes or for which you have already given your consent, if required.
If you have given consent and subsequently withdraw it or chosen not to consent to processing for marketing and/or profiling purposes, your data will no longer be processed for marketing and/or profiling purposes without this having any detrimental consequences or effects for you and for the contract you signed.

How and for how long are your data stored?
The processing of your data is carried out using electronic and manual means and tools made available to parties acting under the authority of Benelli Armi S.p.A. and specifically authorised and trained for this purpose. The paper and especially electronic archives where your data are archived and stored are protected by effective security measures that are able to counter the risks of breach considered by Benelli Armi S.p.A. Benelli Armi S.p.A. provides for periodic and constant verification of the measures implemented, especially for electronic and online tools, to guarantee the confidentiality of personal data that are thereby processed, archived and stored, especially if belonging to particular categories.
Personal data are stored for the time necessary to complete the activities related to the management of the contract with Benelli Armi S.p.A. and for the fulfilment of related obligations, legal or otherwise. For data intended for marketing purposes (direct marketing, research and market surveys) that you have consented to you are always allowed to object to the corresponding processing and/or to withdraw consent,
The computer files are located within the borders of the EU (and EEA) and do not connect or interact with databases located abroad.

How
The processing of data is performed through paper supports or computerized procedures by internal, specially authorised and trained, personnel. This personnel is allowed to access your personal data in the measure and within the limits necessary for performing the processing procedures that regard you.
Benelli Armi S.p.A. periodically verifies the tools through which your data are processed as well as the related security measures that are constantly updated; verification, also through persons authorised to process the data, that personal data not necessary for collection are not collected, processed or stored; verification that the data are stored with the guarantee of integrity and authenticity and their use for the purposes of processing actually performed.
Where
Data are stored in paper, computerized and electronic archives located in the European Economic Area where proper measures are ensured to maintain their security.
How long
The personal data processed by Benelli Armi S.p.A. are kept for the time necessary to complete the activities related to the management of the contract with Benelli Armi S.p.A. and up to ten years after its conclusion (art. 2946 of the Italian Civil Code) or from when the rights that depend on it may be exercised (pursuant to art. 2935 of the Italian Civil Code); as well as for the fulfilment of the obligations (e.g. tax and accounting) that remain after the conclusion of the contract (art. 2220 of the Italian Civil Code), for which Benelli Armi S.p.A. must keep only the data necessary for compliance. Except in cases where the rights deriving from the contract are to be exercised in court, in which case your data – only those necessary for such purposes – will be processed for the time necessary.
The personal data processed by Benelli Armi S.p.A. for marketing purposes (direct marketing, research and market surveys) will be kept for five years by Benelli Armi S.p.A. subject to withdrawal of the consent you have given and/or subject to your opposition to such processing.
The personal data processed by Benelli Armi S.p.A. for profiling will be kept for two years by Benelli Armi S.p.A. subject to withdrawal of the consent you have given and/or subject to your opposition to such processing.
In any case, you retain the right to object to processing at any time based on a legitimate interest for reasons associated with your particular situation.
Personal data processed by Benelli Armi S.p.A. for the purposes of Public Safety will necessarily be kept for at least 50 years as envisaged by TULPS and related regulations, without any possibility for you to withdraw consent pursuant to Italian Legislative Decree no. 204 of 26 October 2010.

What are your rights?
Regulations give you the right to always have control of your data. You have the following rights with regard to your data:

  • Access.
  • Correction.
  • Erasure.
  • Withdrawal of consent.
  • Restriction of processing.
  • Opposition to processing.
  • Portability.

Your rights are guaranteed without any particular obligations or procedures for their exercise, which is essentially understood to be free of charge. You have the right:

  • To obtain a copy of the data you have requested access to, even in electronic format. If you need to request additional copies, Benelli Armi S.p.A. can charge you a reasonable fee.
  • To have them erased or the processing restricted or even obtain the updating and correction of your personal data.
  • If your data have been disclosed to others, in these latter cases you have the right for the other data controllers or recipients to be informed by Benelli Armi S.p.A. of your request and the outcome of the exercise of your rights so that they can also erase, suspend or interrupt the processing or correct your data.
  • To obtain any useful communication regarding the activities carried out following the exercise of your rights, without delay and in any case within one month of your request, unless justifiably extended up to two months, which must be duly communicated to you.

Essentially, at any time and free of charge and without any particular obligations or procedures for your request, you can:

  • Receive confirmation of the processing performed by Benelli Armi S.p.A.
  • Access your personal data and know their origin (when the data are not obtained from you directly), the purposes of the processing, the data of the parties to whom they are disclosed, the storage period for your data or criteria useful for determining it.
  • Withdraw consent at any time if consent is the basis for the processing. However, the withdrawal of consent does not prejudice the lawfulness of the processing based on the consent given before the withdrawal.
  • Update or rectify your personal data so that they are always accurate.
  • Erase your personal data from the databases and/or archives, including backups, of Benelli Armi S.p.A. in the case, among others, where they are no longer necessary for the purposes of the processing or if processing is assumed to be illegitimate and if the conditions established by law exist, and in any case if the processing is not justified by another equally legitimate reason.
  • Restrict the processing of your personal data in certain circumstances, for example where you have challenged their accuracy, for the period necessary for Benelli Armi S.p.A. to verify their accuracy. You must be informed in a reasonable time even when the suspension period has expired or the reason for the restriction of processing no longer exists and therefore the restriction itself is revoked.
  • Obtain your personal data – if received and/or otherwise processed by Benelli Armi S.p.A. with your consent and/or if their processing is done on the basis of a contract and with automated tools – in electronic format, even in order to transmit them to another data controller.

Benelli Armi S.p.A. must respond without delay and, in any case, no later than one month after receiving your request. The deadline may be extended by two months if necessary, considering the complexity and the number of requests received by Benelli Armi S.p.A. In such cases, Benelli Armi S.p.A. will inform you within one month of receiving your request and will inform you of the reasons for the extension.
For further information and in any case to submit any requests, please contact Benelli Armi S.p.A. at the address privacy@franchi.com.

How and when can you object to the processing of your personal data?
For reasons related to your particular situation, you may object at any time to the processing of your personal data if it is based on a legitimate interest or if it is for marketing purposes (direct marketing, research and market surveys), sending your request to Benelli Armi S.p.A. at the address privacy@franchi.com.
You have the right to the erasure of your personal data if there is no other prevailing legitimate reason with respect to your request, and in any case if you object to processing for marketing purposes (direct marketing, research and market surveys).

Who can you submit complaints to?
Without prejudice to any other action in administrative or judicial proceedings, you can lodge a complaint with the competent supervisory authority or with the authority carrying out its duties and exercising its powers in Italy, without prejudice to the cases in which the jurisdiction of the supervisory authority established in another member state is recognised in accordance with the provisions of the law. 
Every update of this privacy policy will be communicated to you promptly and by means of a reasonable means, and you will be notified as well if Benelli Armi S.p.A. processes your data for purposes other than those set out in this policy before proceeding and giving you time to provide your consent if necessary.

Who are we and what do we do with your personal data?
Benelli Armi S.p.A., Franchi Division, with registered office in Via della Stazione 50, 61029 Urbino (PU), as data controller works to ensure the confidentiality of your personal data and guarantees them the necessary protection from any event that may put them at risk of infringement.
Benelli Armi S.p.A., thus also Franchi Division as Benelli Armi S.p.A.’s brand,  implements policies and practices regarding the collection and use of personal data and the exercise of the rights that you have under the applicable legislation. Benelli Armi S.p.A. updates its policies and practices for the protection of personal data whenever this becomes necessary and in any case in the event of regulatory and organisational changes that may affect the processing of your personal data.
Benelli Armi S.p.A. has designated an internal privacy representative who you can contact at the following email address privacy@farnchi.com if you have questions about the policies and practices implemented by Benelli Armi S.p.A.

How does Benelli Armi S.p.A. Franchi Division collect and process your data?
Benelli Armi S.p.A. collects and/or receives information about you, like: name, surname, place and date of birth, residential address and video and photo images, as well as sound recordings involving yourself. They are used by Benelli Armi S.p.A. to document and publicise the event that you participated in and to promote and publicise Benelli Armi S.p.A.’s business. Your personal data is primarily disclosed to third parties and/or recipients whose activity is necessary to allow the collection of data during the event, the event’s promotion and the products and services of Benelli Armi S.p.A. Any disclosure that does not correspond to these purposes requires your consent. Your data may be disseminated for the purposes represented and in any case processed as described above. The dissemination of images and sound/video recordings that include you will occur only if you authorise the processing and/or if you do not object to it. In particular, your personal data may be published on the company’s websites, on the platforms used to stream the event, in magazines or in any other medium intended for dissemination and used to promote the activity carried out by Benelli Armi S.p.A. Benelli Armi S.p.A. does not transfer your personal data abroad.
Specifically, your personal information will be processed:
1) To document, promote and publicise the event you participated in, and Benelli Armi S.p.A. Franchi Division’s business
During the event you participate in, Benelli S.p.A. will be able to acquire images and/or audio/video recordings that include you, directly or through third parties that have been appointed for this purpose.
The acquisition of images is subject to your prior consent to their use. For this purpose, Benelli Armi S.p.A. invites you to sign a specific waiver issued pursuant to the terms of art. 10 and 320 of the Italian Civil Code and articles 96 and 97 of Italian Law no. 633 of 22 April 1941 (Copyright Law).
Your personal data are also collected from third parties like, for example:

  • Other data controllers, e.g. companies and/or professionals in the photographic and/or video business (photographers, professional editors, etc.), the companies in the same group as Benelli Armi S.p.A.

The personal data that Benelli Armi S.p.A. processes for this purpose are, among others: name, surname, place and date of birth, residential address and video and photo images, as well as sound recordings involving yourself.

2) For the dissemination and publication of data on Benelli Armi S.p.A. Franchi Division’s websites and/or in corporate and trade newspapers, also available online and on public and social platforms
Your data may be disseminated for the purposes represented and in any case processed as described above, i.e. for documentation and promotional purposes related to the event organised by Benelli Armi S.p.A. and to the products and services that Benelli Armi S.p.A. offers, and in any case to promote its business, and only if you authorise the processing and/or if you do not object to it. In particular, they can be published and then disseminated on:

  • Company websites and social networks
  • Company brochures, calendars or catalogues
  • Trade magazines and newspapers, periodicals etc.
  • Any other medium in any case intended to disseminate your data and used by Benelli Armi S.p.A. to promote its business.

3) For disclosure to third parties and recipients
Your data will not be disclosed to third parties/recipients for their own purposes unless:

  • You give your consent.
  • It is necessary for the fulfilment of the obligations associated with the authorisation and by the laws that govern it (e.g. for the defence of your rights, for a complaint to the authorities, etc.).
  • Data are disclosed to the companies that are in the same group as Benelli Armi S.p.A. for administrative purposes; advertising companies and/or professionals,  photographers, professional editors, graphics companies, web marketing and/or multimedia publishing companies, marketing companies, companies and law firms for the protection of rights, data processing and IT service companies (e.g. web hosting, data entry, management and maintenance of IT infrastructure and services, web streaming services, etc.).

The personal data that Benelli Armi S.p.A. processes for this purpose are, among others: name, surname, place and date of birth, residential address and video and photo images, as well as sound recordings involving yourself.
4) For information security purposes
Benelli Armi S.p.A. and its suppliers (third parties and/or recipients) process your personal data to the extent strictly necessary to ensure the security and ability of a network or servers connected to it to withstand at a given level of security unforeseen events or illicit or malicious acts that compromise the availability, authenticity, integrity and confidentiality of stored or submitted personal data. For these purposes, Benelli Armi S.p.A. provides procedures for the management of data breaches in compliance with legal obligations.

What happens if you do not provide your data?
If you do not provide your data, including images, Benelli Armi Spa will not process your data as described in the waiver for image use.
Benelli Armi S.p.A. intends to carry out certain processing based on certain legitimate interests that do not affect your right to privacy, like those that:

  • Allow the prevention of IT incidents and the notification of the supervisory authority or, if necessary, the communication to users of the breach of the personal data.
  • Allow disclosure of personal data to the companies belonging to the same group as Benelli Armi S.p.A. for administrative purposes.
  • Allow disclosure to third parties/recipients for activities related to the management of the waiver for image use you signed pursuant to Italian Law no. 633 of 22 April 1941 (Copyright Law).

What happens if you do not give your consent to the disclosure of your personal data for promotional purposes regarding the event organised by Benelli Armi S.p.A. Franchi Division and Benelli Armi S.p.A. Franchi Division’s products and services?
Your personal data will not be processed, which could affect the management of the event you intend to participate in.
If you give your consent and subsequently withdraw it or refuse the dissemination of your data, they will no longer be disseminated by Benelli Armi S.p.A. Benelli Armi S.p.A. specifies that the withdrawal will take effect from the date of receipt of the request. Benelli Armi S.p.A. will be required to certify the removal of photographic images and/or audio/video recordings subject to the withdrawal. It is understood that the withdrawal will have no effect with respect to the processing already carried out or in the event that the erasure/removal of data has become impossible or otherwise excessively difficult, for example in the case of storage by third parties on computers or other media and their publication in company brochures or catalogues.

How and for how long are your data stored?
The processing of your data is carried out using electronic and manual means and tools made available to parties acting under the authority of Benelli Armi S.p.A. and specifically authorised and trained for this purpose. The paper and especially electronic archives where your data are archived and stored are protected by effective security measures that are able to counter the risks of breach considered by Benelli Armi S.p.A. Benelli Armi S.p.A. provides for periodic and constant verification of the measures implemented, especially for electronic and online tools, to guarantee the confidentiality of personal data that are thereby processed, archived and stored, especially if belonging to particular categories.
Personal data are stored for the time necessary to complete the activities related to the management of the authorisation for use of images and their dissemination and for the fulfilment of related obligations, legal or otherwise. For data intended for dissemination that you have consented to you are always allowed to object to the corresponding processing and/or to withdraw consent,
The computer files are located within the borders of the EU (or EEA) and do not connect or interact with databases located abroad.

  • How

The processing of data is performed through paper supports or computerized procedures by internal, specially authorised and trained, personnel. This personnel is allowed to access your personal data in the measure and within the limits necessary for performing the processing procedures that regard you.
Benelli Armi S.p.A. periodically verifies the tools through which your data are processed as well as the related security measures that are constantly updated; verification, also through persons authorised to process the data, that personal data not necessary for collection are not collected, processed or stored; verification that the data are stored with the guarantee of integrity and authenticity and their use for the purposes of processing actually performed.

  • Where

Data are stored in paper, computerized and electronic archives located in the European Economic Area where proper measures are ensured to maintain their security.

  • How long

The personal data processed by Benelli Armi S.p.A. are kept for the time necessary to complete the activities related to the authorisation to use the images and audio/video recordings that include you and that you have released to Benelli Armi S.p.A. pursuant to Italian Law no. 633 of 22 April 1941 (Copyright Law). Specifically, your personal data, including the images and audio/video recordings that include you, will be stored by Benelli Armi S.p.A. for 20 years from the date of realisation as they are considered non-creative works (pursuant to art. 87 et seq. of Italian Law no. 633 of 22 April 1941).
In any case, you retain the right to withdraw your consent and authorisation and to object to processing at any time based on a legitimate interest for reasons associated with your particular situation.

What are your rights?
Regulations give you the right to always have control of your data. You have the following rights with regard to your data:

  • Access.
  • Correction.
  • Erasure.
  • Withdrawal of consent.
  • Restriction of processing.
  • Opposition to processing.
  • Portability.

Your rights are guaranteed without any particular obligations or procedures for their exercise, which is essentially understood to be free of charge. You have the right:

    • To obtain a copy of the data you have requested access to, even in electronic format. If you need to request additional copies, Benelli Armi S.p.A. can charge you a reasonable fee.
    • To have them erased or the processing restricted or even the updating and correction of your personal data.
    • If your data have been disclosed to others, you have the right for the other data controllers or recipients to be informed by Benelli Armi S.p.A. of your request and the outcome of the exercise of your rights so that they can also erase, suspend or interrupt the processing or correct your data.
    • To obtain any useful communication regarding the activities carried out following the exercise of your rights, without delay and in any case within one month of your request, unless justifiably extended up to two months, which must be duly communicated to you.

Essentially, at any time and free of charge and without any particular obligations or procedures for your request, you can:

  • Receive confirmation of the processing performed by Benelli Armi S.p.A.
  • Access your personal data and know their origin (when the data are not obtained from you directly), the purposes of the processing, the data of the parties to whom they are disclosed, the storage period for your data or criteria useful for determining it.
  • Withdraw consent at any time if consent is the basis for the processing. However, the withdrawal of consent does not prejudice the lawfulness of the processing based on the consent given before the withdrawal.
  • Update or rectify your personal data so that they are always accurate.
  • Erase your personal data from the databases and/or archives, including backups, of Benelli Armi S.p.A. in the case, among others, where they are no longer necessary for the purposes of the processing or if processing is assumed to be illegitimate and if the conditions established by law exist, and in any case if the processing is not justified by another equally legitimate reason.
  • Restrict the processing of your personal data in certain circumstances, for example where you have challenged their accuracy, for the period necessary for Benelli Armi S.p.A. to verify their accuracy. You must be informed in a reasonable time even when the suspension period has expired or the reason for the restriction of processing no longer exists and therefore the restriction itself is revoked.
  • Obtain your personal data – if received or processed by Benelli Armi S.p.A. with your consent and/or if their processing is done on the basis of a contract and with automated tools – in electronic format, even in order to transmit them to another data controller.

Benelli Armi S.p.A. must respond without delay and, in any case, no later than one month after receiving your request. The deadline may be extended by two months if necessary, considering the complexity and the number of requests received by Benelli Armi S.p.A. In such cases, Benelli Armi S.p.A. must inform you within one month of receiving your request and inform you of the reasons for the extension.
For further information and in any case to submit any requests, please contact Benelli Armi S.p.A. at the address privacy@franchi.com.

How and when can you object to the processing of your personal data?
For reasons related to your particular situation, you may object at any time to the processing of your personal data if it is based on a legitimate interest, sending your request to Benelli Armi S.p.A. at the address privacy@franchi.com.
You have the right to the erasure of your personal data if there is no legitimate reason that takes precedence over your request, and in any case Benelli Armi S.p.A. notes that the withdrawal will have no effect with respect to the processing already carried out of the images or in the event that their erasure/removal has become impossible or otherwise excessively difficult, for example in the case of storage by third parties on computers or other media and publication of company brochures or catalogues.

 

Who can you submit complaints to?
Without prejudice to any other administrative or judicial actions, you can lodge a complaint with the Personal Data Protection Authority (following the instructions given by the Authority at the link: http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524), unless you reside or work in another member state. In the latter case or if the violation of the legislation on the protection of personal data takes place in another EU country, the local supervisory authorities will have jurisdiction over the complaint.
You will be promptly informed by appropriate means each time this policy is updated, and you will be notified if Benelli Armi S.p.A. processes your data for purposes other than those referred to in this policy before proceeding and in time for you to provide your consent if necessary.