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. 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 email@example.com if you have questions about the policies and practices implemented by Benelli Armi S.p.A.
How does Benelli Armi S.p.A. 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. 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:
- Text message.
- Telephone contact even without an operator.
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.
Your data will be disclosed to third parties, including: marketing services companies, companies that provide business information consulting or solutions, direct marketing, geomarketing, etc. These parties process your data (name, surname, physical address, email address, telephone number and cell phone number) for marketing purposes carried out 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. 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.
The data used for this purpose are your name, surname, physical address, email address, telephone number and cell phone number.
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 consent to the use of the data for the processing just mentioned.
In case of processing, your data may be disclosed to third parties like: profiling services companies, 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 and public 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 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.
Benelli is also required to comply with specific obligations deriving from Public Safety purposes as envisaged by TULPS and related regulations. Based on these obligations, Benelli will process your personal data (like personal data and the firearm’s serial number) to ensure full compliance with the aforementioned regulations.
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, including the proper management of the services and benefits envisaged in the product warranty.
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. 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 (the provision of warranty services) 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.
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.
Data are stored in paper, computerized and electronic archives located in the European Economic Area where proper measures are ensured to maintain their security.
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:
- Withdrawal of consent.
- 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, 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 firstname.lastname@example.org.
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 email@example.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.
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.