PRIVACY INFORMATION PURSUANT TO ART. 13 of the EU Reg. N. 2016/679 (GDPR)

FlorPassion Privacy Policy
1. POLICY COVER
At FlorPassion, your privacy is very important to us and we want to assure you that we take the confidentiality and security of your personal data very seriously. FlorPassion is a company registered in Italy.
This privacy policy covers personal data collected by FlorPassion through the consumer Websites at the domain names: www.florpassionflowers.com, www.florpassionflowers.it, www.florpassion.com as well as any of our consumer apps, mobile websites, and other related subdomain websites and services (collectively, the "Websites"). The term Websites also covers the collection of personal data through FlorPassion's direct mail or coupon campaigns, telephone sales or through social media channels.
Our privacy policy explains the following key topics listed below, as well as many other topics:
A) What personal data we collect and how we collect it
- Personal data you provide when you purchase from us
- Personal data obtained when you use our Websites
- Personal data obtained if you contact us
B) How we use the personal data we collect from you
- To fulfill your order
- For customer care
- For marketing
- For internal business purposes

2. CATEGORIES OF PERSONAL DATA PROCESSED
We collect personal data from you whenever you interact with our Websites, including when you make purchases, when you browse our Websites, when you use our services or when you sign up to receive any of our services. When providing personal data to us through a form, we indicate which personal data is optional. Please note that, when collection of personal data is required or necessary either as needed for us to fulfil your order or based on legal obligation and you elect not to provide the personal data, we may not be able to accept or fulfil your order.
The types of personal data that we will collect, store, maintain or process includes the following. We provide further details regarding the use of the personal data in Clause 8.
A) Personal data you provide when you purchase from us
- Your contact details you provide when placing your order, including name, title, billing address, telephone numbers and e-mail address
- Recipient and delivery details you provide when placing your order, including name, address, contact telephone numbers, delivery instructions and email address
- The occasions for which you purchase our goods and services such as birthdays and anniversaries
- Any personal data contained within the card message (e.g., names and birthdays)
- Details associated with the products you order
- Details of the services you purchase or subscribe to
- When you make a purchase, your payment card details (in accordance with payment card industry standards)
- Your communication and marketing preferences including delivery updates and notifications

B) Additional Personal Data provided through the "My Account" feature
- Customer title, name, preferred name, telephone number and type, email address, email address type and postal address
- Recipient title, name, preferred name, telephone number, email address and postal address
- Any stored payment card details (in accordance with payment card industry standards)
- Stored delivery instructions
C) Additional Personal Data obtained when you use our Websites
- Details of your online browsing activities on our Websites such as the pages visited and the parts of the Websites used
- Details of the type of device used to access our Websites, your device IP address, and your device location
D) Additional Personal Data obtained through contact with us
- Details of your interaction with emails that we send you including links that you click and emails that you open
- If contact occurs between us, we will keep a record of that correspondence, including your name and contact data, and details of your customer care issues or other concerns and our responses (including any recorded telephone calls)
Our Websites are not intended for use by persons under the age of 18 and our terms and conditions require that a person be 18 or older when placing an order with us. If you believe we have collected personal data from a person under the age of 18, please notify us at the information provided in Clause 14.

3. PURPOSES AND LEGAL BASES FOR THE PROCESSING OF PERSONAL DATA
We will use your personal data for the following purposes:
A) To fulfill your order:
- To process your order
- To process payment including payment authorization via payment card, cheque, gift card or other third party payment processor
- To carry out identity verification and fraud prevention checks when purchasing with a payment card and validating personal data you provide via a third party payment processor
- To provide data to any third party supplier or vendor who may fulfill your order on our behalf
- To provide order confirmation, delivery status notifications on any order placed with us

B) For customer care purposes:
- To address any customer care issues that occur either with respect to a product or service, delivery, or a complaint or inquiry that you or your recipient raise with us
- To contact you with any changes, cancellation or other issues with your order
- To manage any registered accounts you have through the Websites
- To obtain customer feedback with respect to an order either from you or your recipient (to the extent permitted under the applicable law)
NOTE: Please note that you will receive communications with respect to fulfilling your order or for customer care purposes even if you opt out of receiving marketing communications.
C) For marketing purposes:
- To keep you up-to-date with new products and services that we think will be of interest to you
- To provide you with promotional offers
- To personalize your experience with FlorPassion by providing products and information tailored to you through your purchasing history with us
- To serve you with marketing advertisements based on your browsing history on our Websites, to the extent you use our Websites, through cookies on our Websites or a registered account with us. See our Cookie Policy
- Notify you of competitions and prize draw offers to enable you to enter and to notify you of any wins
D) For marketing through third parties:
If you use our Websites, then you may receive personalized advertisements of our products and services when browsing other Websites using the same computer or device you used to view our Websites. This marketing is enabled through the cookies collecting data of your online browsing behavior. These cookies are operated either by FlorPassion or by a third party and the advertisements are provided through a third party. Details of our third party providers are available within Clause 9 of this policy.
You can remove or disable cookies at any time, see our Cookie Policy
E) For internal business purposes:
We will use any of the personal data collected to help us to understand how many people visit our Websites, how well the Websites are working and to consider any improvements we may need to make to the Websites to improve your online experience. It also helps us determine what products and services you are interested in and what you or other customers might wish to purchase from us in future.
More specifically, we may use your personal data for the following internal business purposes:
- To analyse your browsing and purchasing activity on our Websites, including any search terms you may have entered into our Websites
- To analyse the demographic data we collect when you place your order or otherwise use our Websites including your title, address, IP address, browser type, and occasions for which you purchase flowers in order to offer you better products and services and improve our business
- To analyse customers shopping with us to understand our target audience for the purposes of selecting similar customers for advertising purposes
- To analyse delivery location data you provide when placing your order to understand the delivery logistics required for our delivery network
- To analyse your responses to our marketing communications
- To ensure our online content is presented in the most effective manner for you and your electronic device(s) i.e. tailored for a desktop computer, tablet, iPhone or Android
- To obtain customer feedback with respect to an order either from you or your recipient (to the extent permitted under the applicable law) to determine the quality of the customer or recipient experience and to improve customer care experiences
- To develop and provide new or improved products or services
- For crime and fraud prevention, detection and related matters, including cooperation with the police and similar authorities with their lawful queries and investigations
- To confirm your identity, as necessary
- To comply with any legal obligation for the purposes of good governance or regulatory guidance with respect to applicable law
- With respect to any legal claims or related guidance by our advisors
- With respect to any mergers or acquisitions or other business or legal affairs as further described in Clause 9

4. MARKETING COMMUNICATION
You have the right to opt out of receiving direct marketing communications at any time. We will address your opt out request as soon as possible, but no longer than one month from the date we receive your request.
You may opt out of marketing communications or change your preferences with respect to marketing communications by:
- Unsubscribing from emails using the unsubscribe link which can be found in all marketing emails
- Updating your preferences within your "My Account"
- Contacting us via the contact information provided in this policy

5. OUR COOKIE POLICY
You are not required to accept cookies in order to make a purchase. For example, you may place an order through a direct mail or coupon campaign or through our customer call centre. However, by making a purchase through our Websites, you agree to our Cookie Policy, which includes more information about disabling cookies. See our Cookie Policy

6. METHODS OF DATA PROCESSING
We are committed to protecting and respecting your privacy rights, and to ensuring that your personal data is safe and secure.
We use administrative, organisational, technical and physical safeguards to protect personal data. Our security controls are designed to protect your personal data from unauthorised alteration, access, disclosure, and use. We regularly test our Websites, data centres, systems, and other assets for security vulnerabilities. In addition, at a minimum, our safeguards involve appropriate technical and organisational measures including, but not limited to, encryption services, review of our data collection, storage and processing practices (including physical security measures, to guard against unauthorised access to systems), scenario planning and crisis management protocols to ensure we are able to respond to cyber security attacks and data security incidents, regular penetration testing of systems, security controls to protect our IT infrastructure from external attack and unauthorised access, and internal policies setting out our data security approach and training for employees.
FlorPassion handles payment card data in a manner consistent with the Payment Card Industry Data Security Standard (PCI-DSS).

7. YOUR PERSONAL DATA PROTECTION
We will never ask you to confirm any bank account or credit card details in writing or via email. If you receive an email or any other written communication claiming to be from us, asking you to provide this data, please ignore it and do not respond.
If you are using a computing device in a public location, you should always log out and close the website browser when you have finished your online session.
If you create an account with us, you must keep your password private and avoid using the same password for multiple online accounts. Any password created should be at least 8 characters long and must include at least one upper case letter, one lower case letter and one symbol. We recommend regularly changing your password, which you can do within your account.

8. OUR LAWFUL BASIS FOR PROCESSING YOUR PERSONAL DATA
FlorPassion relies on different lawful basis for processing personal data. In some cases, more than one lawful basis may apply with respect to the same personal data.
Contract: We collect and process personal data in order to fulfil the order you place with us, and in accordance with our contract with you to fulfil your order. Such personal data includes the items detailed in Clause 3 under the title "To fulfil your order".
Legitimate Interest: We collect and process personal data for our legitimate interests in fulfilling and processing your order, any customer care issues, to conduct research, to send email and direct marketing to you, handling legal claims, and for fraud identification and prevention checks. Such personal data includes the items detailed in Clause 3 under the title "For customer care purposes", "For marketing purposes", "For marketing through third parties" and "For internal business purposes". With respect to any direct marketing we provide on the basis of a legitimate interest, you can unsubscribe as described in Clause 4.
Consent: In addition to the legitimate interests outlined above, we rely on the consent you have provided as the legal basis for our marketing communications. You can unsubscribe to the marketing communications as described in Clause 4. Please note that withdrawing your consent may not be sufficient to cease all communications or for us to delete your personal data since we may have another lawful basis or ongoing reason we need to keep personal data such as a new purchase or recordkeeping legal obligations. Please further note that if you make a purchase with us after you have withdrawn your consent, we may collect and use personal data in accordance with this privacy policy with respect to that purchase and you will be asked for consent for marketing communications again.
Legal Obligations: FlorPassion is required to comply with applicable laws, rules and regulations as well as industry standards and orders by courts with jurisdiction over FlorPassion. In doing so, we may collect and retain personal data. For example, FlorPassion creates and maintains records of your orders to maintain the tax and accounting records required by applicable laws, and to share such records with the tax authorities as and when required.

9. COMMUNICATION AND DISCLOSURE OF YOUR PERSONAL DATA
We will share your personal data with certain third parties in order to fulfil and process your order, enable us to perform our contract to provide your purchase to you, provide our Websites and to provide you with marketing. The following is a list of types of third parties that may receive your personal data. Our third party providers are required to handle your personal data in accordance with appropriate data protection and security controls.
- FlorPassion may shares data with our florists who are independently owned and operated businesses. Our florists are our distributors for the purposes of fulfilling and delivering your purchases. We also use other third party fulfilment partners such as wholesalers for certain products and postal and courier services. Our florists and fulfilment partners may contact you or the recipient to assist in fulfilling your order. More specifically, on some occasions, you or the recipient may be contacted to schedule delivery or verify delivery information and availability. To maintain our high quality standards, we may contact recipients to ensure satisfaction with their gift.
- IT Suppliers and Vendors: In order to manage our operations, FlorPassion contracts with third parties who provide security and technical services to protect our Websites, maintain databases of personal data for the purposes outlined in this privacy policy and present Websites content.
- Financial/Payment Service Providers: In order to process customer orders placed with us, FlorPassion contracts with payment service companies who process payment, ensure security of your transactions, and prevent or detect fraudulent transactions.
- Marketing Service Providers: FlorPassion contracts with third parties who:
provide email marketing, SMS (text) marketing, direct marketing campaigns
provide online advertising campaigns
maintain databases of personal data for marketing campaigns as outlined in this privacy policy
provide to us reporting of our marketing campaigns
provide services to facilitate ‘refer a friend' offers as and when these are promoted
provide affiliate marketing services to us e.g. consumer discount websites
- Market Research Providers: In order to continually improve our customer experience, FlorPassion contracts with third parties who provide market research services which include collating and reporting of customer feedback, and collate and provide customer feedback via customer surveys.
- Website Improvement: In order to improve our online customer experience, FlorPassion contracts with third parties who help us identify and make improvements to our website, provide website traffic data and website performance analysis information, and provide analysis on website performance focused on customer experience.
- Customer Service Providers: In order to provide the best possible customer services to our customers, FlorPassion contracts with third parties who provide call handling services for the purposes of taking customer orders, customer order enquiries and dealing with any customer care issues and provide ‘Live Chat' functionality.

10. HOW LONG DO WE KEEP YOUR PERSONAL DATA
We will only retain your personal data for the purposes set out in this policy and for as long as we have a legal or business requirement to do so. Different retention periods apply for different types of personal data, however, the longest we will normally hold any personal data is 7 years after the last contact with such person or purchase by such person. The time period for retention will depend on applicable laws, rules or regulations that we are required to follow, whether there is an ongoing request or query or other type of legal claim or dispute, the type of information we are holding and whether we are asked by you or a regulatory authority to keep the personal data.

11. TRANSFER YOUR PERSONAL DATA
Your personal data collected are not subject to transfer abroad

12. RIGHTS TO ACCESS PERSONAL DATA AND RECTIFY ANY INACCURACIES
We fully respect that your personal data is owned by you and that you have certain rights with respect to the personal data. Our goal is to respect your rights.
You may have the following additional rights, detailed below:
- Right to Erasure (also known as "the Right to be Forgotten"): For a limited list of reasons, you may request that your personal data is removed from our systems.
- Right to Restrict: For a limited list of reasons, you may request that we cease using or that we suppress your personal data.
- Right to Object: You may object to our use of your personal data.
- Right to Data Portability: Where we use your personal data based on your consent or to enter or perform a contract with you, and our processing is carried out by automated means, you may request that any personal data you have provided to us be transmitted electronically to you or to another supplier (to the extent feasible).
Please note that if we erase all information about you and you make a future purchase or otherwise become a future customer, then we will not be aware of your prior requests or objections.
In respect of the additional rights outlined above, we request that you contact us via the Contact Details shown in Clause 13 below and we will provide you with additional information regarding your rights in connection with your specific request.
- Right to Lodge a Complaint: You have the right to lodge a complaint with the supervisory authority. FlorPassion's supervisory authority is the Information Commissioner's Office, see website Garante Privacy - www.garanteprivacy.it

13. CONTACT DETAILS
We have appointed a Data Protection Officer whose role is to inform and advise us about and to ensure that we remain compliant with data protection laws. The Data Protection Officer should be your first point of contact if you have any queries or concerns about personal data. Our Data Protection Officer can be contacted at:
Email: [email protected]
Post: FlorPassion Data Protection Officer
Via Montenapoleone 8, 20121, Milano, Italy

14. UPDATES TO THIS POLICY
Our goal is to keep this privacy policy up to date. Therefore, we recommend that you review this privacy policy periodically. At a minimum, we recommend reviewing this policy together with each new purchase you make with us. We will inform you of material changes to this privacy policy in accordance with the applicable law.

Cookie Policy
We may use technology to track the patterns of behaviour of registered and non-registered visitors to our site. This can include using a "cookie" which is a small file stored on your browser. The information collected in this way can be used to identify you unless you modify your browser to prevent this happening - guidance for which is set out below. We also aggregate this data to perform statistical analyses of the characteristics and behaviour of visitors to our Websites. Cookies are also used as a further means of ensuring private and secure purchase sessions are operated within the Websites.
We may use third party advertising companies to serve advertisements on our behalf. These companies may employ cookies and action tags (also known as single pixel gifs or web beacons) to measure advertising effectiveness. Any information that these third parties collect via cookies and action tags is completely anonymous. Your browser can be modified to not accept cookies - guidance for which is provided in the paragraph below.
You have the ability to accept or decline cookies by modifying the settings in your browser (for example, using Internet Explorer select 'internet options' from the 'tools' menu, then click 'security', followed by 'custom level' and select 'disable cookies'). However, you may not be able to use all the interactive features of our Websites if cookies are disabled. For more information about cookies, including how to set your internet browser to reject cookies, please go to www.allaboutcookies.org.