Privacy

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 the necessary protection from any event that may put it at risk of infringement.
Benelli Armi S.p.A., Franchi Division,  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., Franchi Division,  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., Franchi Division,  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. collect and process your data? 1) For the management of the websites belonging to the controller and to follow up on your request for information

The Data Controller collects and / or receives data about you, like: IP address, identifying personal data (like email address) issued while browsing the www.franchi.com site and / or individual with products and promotions of Benelli Armi. They are used by the Data Controller to manage the individual websites and to follow up on your request for information. Your personal data is disclosed primarily to third parties and / or recipients whose involvement is necessary for the performance of activities related to the aforementioned purposes and also to meet certain legal obligations. Any disclosure that does not correspond to these purposes requires your prior consent. Your personal data will not be disseminated or disclosed to indeterminate and non-identifiable parties, even as third parties.

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 be disclosed to third parties/recipients, if:

– it is necessary for the fulfilment of the obligations depending on the contract and by the laws that regulate it (e.g. for the defense of your rights, for the report to the supervisory authorities, etc.);

– the communication is made to the companies of the group which Benelli Armi S.p.A. belongs to for administrative purposes; companies and law firms for the protection of contractual rights and/or dealing with credit recovery; data processing and IT services companies (e.g. web hosting, data entry, management and maintenance of IT infrastructures and services, etc.);

– the communication is made to the financial administration, and to the public supervisory and auditory bodies in relation to which Benelli Armi S.p.A. must fulfil specific obligations deriving from the very nature of the activity carried out.

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

– you give your consent;

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

• IP address, personal identification data (e.g. email address).

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 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.

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 e-mail address) can be done by:

• e-mail

The processing in question can be carried out:

1. 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.
2. If you did not oppose processing and / or if you did not specifically and separately oppose 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 (email) 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. belongs for marketing activities (direct marketing, research and market surveys) autonomously carried out by them

The disclosure of your personal data (e.g. digital address) to Benelli Armi S.p.A.’s commercial partners (agents, representatives, sellers, 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 communication may be made to commercial partners (agents, representatives, sellers, companies operating in the same sector, etc.) and/or companies of the Benelli Armi S.p.A. group located in non-EEA countries (as shown in the link in the paragraph “How and how long your data is stored – Where”), if the Benelli Armi S.p.A. Newsletter is subscribed in one of these countries. The communication will be made only to the partners and/or companies of the group which the Data Controller belongs to located in the non-EEA country where the purchase took place, only if you give your consent to the 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:

1. 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.
2. 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.
3. If you did not oppose processing and / or if you did not specifically and separately oppose 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.

What happens if you do not provide your data?

Your personal identifying data is necessary to fulfil any request you make using the “Contacts” section. If you do not provide such data then it is impossible for the Controller to respond to your request.

What happens if you do not consent to the processing of personal data for marketing purposes (direct marketing, research and market research) 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 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 and/or for communication to third parties/recipients for marketing purposes pursued by them independently, your data will no longer be processed for such purposes with no negative effect on you nor on the contract you have 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 the Data Controller and specifically authorized and trained for this purpose.

The data is stored in paper, computerized and digital archives located within the European Economic Area, with the exception of the cases listed below, and adequate security measures are ensured.

Your personal data (as better specified below) may be stored in paper, computerized and digital archives located outside the European Economic Area only if the subscription to the newsletter took place in one of the non-EEA countries listed at the following link.

Specifically, your personal data will only be transferred to the partners and/or companies of the group the Data Controller belongs to located in the non-EEA country where the subscription took place in order to:

• communicate your personal data to partners and/or companies of the group Benelli Armi S.p.A. belongs to for marketing activities (direct, research and market surveys) carried out by them independently, only if you have given your consent.

The personal data transferred for this purpose is: email address.

Personal data is 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. The data is kept for the time necessary to fulfil the requests for information and for the Data Controller to send communications for this exclusive purpose following your request, and in any case for a term not exceeding a maximum of 5 years, except for events that require the involvement of competent Authorities (also in collaboration with third parties / recipients that are responsible for the Data Controller’s computer security) to carry out any investigations into the causes of the event.
The personal data processed by Benelli Armi S.p.A. for marketing purposes (direct marketing, research and market surveys) will be kept for 5 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 2 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.

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 its 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., Franchi Division, 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., Franchi Division,  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., Franchi Division,  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. collect and process your data?

Benelli Armi S.p.A., Franchi Division, 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 license 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 S.p.A. Any disclosure that does not correspond to these purposes requires your consent. Your data (name, surname, physical or digital address, landline or mobile phone number) may also be processed for the purposes of commercial promotion, surveys and market research with regard to products and services that Benelli Armi S.p.A. offers. Your data may be communicated to partners and/or companies of the group to which Benelli Armi S.p.A. belongs for marketing activities (direct, research and market surveys) carried out by them independently, or profiling (name, surname, physical address, landline and mobile phone, information relating to commercial and/or work activity and/or family status, information regarding your latest purchases, etc.) Only if you have given your consent and/or if you do not object to it.

Benelli Armi S.p.A. may transfer your personal data (such as name, surname, physical and logical address, email, mobile and/or landline telephone number) outside the European Economic Area, if the product was purchased from one of the partners and/or companies of the group to which Benelli Armi S.p.A. belongs located in a non-EEA country (as better identified in the dedicated paragraph): your personal data will be disclosed in order to allow the third party to carry out marketing activities (direct, market research and surveys) independently, only if you have given your consent and/or if you do not object to it. Your personal data will in no way be disseminated or disclosed to indeterminate and non-identifiable subjects 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 is also collected from third parties such as:

• commercial agents, representatives and sellers, companies operating in the same sector;
• 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:

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

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 is 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 is also collected from third parties such as:

• 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.
• commercial agents, representatives and sellers, companies operating in the same sector;
• 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:

• name, surname, tax code or VAT number, place and date of birth, physical and digital address, landline and/or mobile phone number, firearms license number;

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 be disclosed to third parties/recipients, if:

• it is necessary for the fulfilment of the obligations depending on the contract and by the laws that regulate it (e.g. for the defence of your rights, for the report to the supervisory authorities, etc.);
• the communication is made to the companies of the group to which Benelli Armi S.p.A. belongs and/or partners (commercial agents, representatives and sellers, companies operating in the same sector) for administrative purposes; auditing and certification firm of the financial statements; quality survey and certification company; network of agents used by Benelli Armi; final consumers; transport companies and freight forwarders for whatever related to shipments of goods and customs procedures; banking institutions for the management of receipts and payments; companies and law firms for the protection of contractual rights and/or dealing with credit recovery; data processing and IT services companies (e.g. web hosting, data entry, management and maintenance of IT infrastructures and services, etc.) testimonials, trade associations;
• the communication is made to the financial administration, and to the public supervisory and auditory bodies in relation to which Benelli Armi S.p.A. must fulfil specific obligations deriving from the very nature of the activity carried out.

Your data will not be disclosed to third parties/recipients, unless:

• you authorize it;

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 license number.

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.

The processing in question can be carried out:

1. 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.
2. 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.
3. 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. 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.

The communication may be made to commercial partners (agents, representatives, sellers, companies operating in the same sector, etc.) and/or companies of the Benelli Armi S.p.A. group located in non-EEA countries (as shown in the link in the paragraph “How and how long your data is stored – Where“), if the purchase of the Benelli Armi S.p.A. product took place in one of these countries. The communication will be made only to the partners and/or companies of the group which the Data Controller belongs to located in the non-EEA country where the purchase took place, only if you give your consent to the 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:

1. 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.
2. 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.
3. 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. 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 choose not to consent the processing for marketing and/or profiling purposes and/or for communication to third parties/recipients for marketing purposes pursued by them independently, your data will not be processed for these purposes, with no negative effect on you nor on the contract you have signed.

How and for how long is 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 authorized and trained for this purpose. The paper and especially electronic archives where your data is archived and stored are protected by effective security measures 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 is thereby processed, archived and stored, especially if belonging to particular categories.
Personal data is 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) profiling or communication to third parties/recipients for marketing purposes pursued independently by them for which you have given consent, you are always allowed to oppose the related processing and/or to revoke consent.

How

The processing of data is performed through paper supports or computerized procedures by internal, specially authorised and trained, personnel. The 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 is 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 is not collected, processed or stored; verification that the data is stored with the guarantee of integrity and authenticity and their use for the purposes of processing actually performed.

Where

Data is stored in paper, computerized and electronic archives located in the European Economic Area with the exception of the cases listed below, and adequate security measures are ensured.

Your personal data (as better specified below) may be stored in paper, computerized and digital archives located outside the European Economic Area only if the purchase of the product and, therefore, the collection of your personal data was carried out at companies of the group Benelli Armi S.p.A. belongs to, and/or partner companies (commercial agents, representatives and sellers, companies operating in the same sector), located in one of the non-EEA countries listed at the following link.

Specifically, your personal data will only be transferred to the partners and/or companies of the group the Data Controller belongs to located in the non-EEA country where the purchase took place and, therefore, the collection of personal data, in order to:

• communicate your personal data to partners and/or companies of the group Benelli Armi S.p.A. belongs to for marketing activities (direct, research and market surveys) carried out by them independently, only if you have given your consent.

The personal data transferred for this purpose are: name, surname, physical and digital address, mobile and/or landline telephone number.

How long

The personal data processed by Benelli Armi S.p.A. is 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 for 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 is 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 recognized 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 it the necessary protection from any event that may put it at risk of infringement.
Benelli Armi S.p.A., Franchi Division, 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., Franchi Division, 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., Franchi Division, 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. collect and process your data?

Benelli Armi S.p.A., Franchi Division, 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 license 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 authorized 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 carrying out aesthetic treatments on the weapon ) 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 S.p.A. Any disclosure that does not correspond to these purposes requires your consent.

Your data (name, surname, physical or digital address, mobile phone number and/or telephone number) may also be processed by the Data Controller for the purposes of commercial promotion, surveys and market research with regard to products and services that Benelli Armi S.p.A. offers, or may be communicated to partners and/or companies of the group Benelli Armi S.p.A. belongs to for marketing activities (direct, research and market surveys) carried out by them independently only if you have given your consent to the processing and/or if you do not object to it. Your data (such as name, surname, physical address, email, landline and mobile phone number, information relating to commercial and/or work activities and/or family conditions, information regarding your latest purchases) may be processed for profiling purposes, only if you have given your consent and/or if you do not object to it.

Benelli Armi S.p.A. may transfer your personal data outside the European Economic Area, if the purchase of the product took place from one of the partners and/or companies of the group Benelli Armi S.p.A. belongs to located in a non-EEA country (such as better identified in the dedicated paragraph), or if the registration on the dedicated site to get the Warranty Certificate on the Benelli Armi S.p.A. product purchased took place in one of these countries, in order to manage and for the fulfilment of legal obligations and consequent regulation and/or if the communication of the data is aimed at allowing the third party to carry out marketing activities (direct, research and market surveys) independently (only for the latter purpose, only if you have given your consent and/or if you do not object to it). Your personal data will in no way be disseminated or disclosed to indeterminate or non-identifiable subjects, not even if they are 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., Franchi Division, or the authorized armoury to give proper execution to the contract and to the services and benefits related to it (e.g. weapon repairs or execution of aesthetic treatments on the weapon), or to improve Benelli Armi S.p.A., Franchi Division, products, as well as for the fulfilment of legal and regulatory obligations to which Benelli Armi S.p.A. is required to obey in relation to the activity carried out.

Your personal data is also collected from third parties such as:

• 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 be disclosed to third parties/recipients, if:

1. 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.).
2. Disclosure is made to companies of the group to which Benelli Armi S.p.A. belongs for administrative purposes and commercial partners (agents, representatives, sellers, companies operating in the same sector, etc.) of Benelli Armi S.p.A. in order to manage the Warranty Certificate and for the fulfilment of the consequent legal and regulatory obligations, as well as to ensure the correct performance of the service (weapon repairs or aesthetic treatments on the weapon), or to improve the products (armoury and similar) of Benelli Armi S.p.A.; companies and law firms for the protection of contractual rights and/or that deal in debt recovery; carriers and shippers for whatever related to freight and customs procedures; data processing and IT service companies (e.g. web hosting, data entry, management and maintenance of IT infrastructure and services, etc.).
3. 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.

Your data will not be disclosed to third parties/recipients, unless:

• you have given consent.

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 license number, model and serial number.

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.

The processing in question can be carried out:

1. 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.
2. 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.
3. 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 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.

5) 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 communication can take place with commercial partners and/or companies of the Benelli Armi S.p.A. group (as identified above) located in non-EEA countries (indicated in the link in the paragraph “How and for how long your data is stored – Where“), if the purchase of the product and/or the registration on the dedicated site to get the Warranty Certificate on the Benelli Armi S.p.A. product purchased took place in one of these countries. The communication will be made only to the partners and/or companies of the group which the Data Controller belongs to located in the non-EEA country where the purchase/registration took place, only if you have given your consent to the processing.

The data used for this purpose are your name, surname, physical address, email address, telephone number and cell phone number.

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 it, 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 and/or for communication to third parties/recipients for marketing purposes pursued by them independently, your data will no longer be processed for such purpose/s , 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 authorized and trained for this purpose. The paper and especially electronic archives where your data is 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 is 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) of communication to third parties/recipients for marketing purposes pursued by them independently and profiling that you have consented to you are always allowed to object to the corresponding processing and/or to withdraw your consent.

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 is 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 is stored with the guarantee of integrity and authenticity and use for the purposes of processing actually performed.

Where

Personal data is stored in paper, computerized and digital archives located in the European Economic Area, with the exception of the cases listed below, where proper measures are ensured to maintain security.

Your personal data (as better specified below) may be stored in paper, computerized and digital archives located outside the European Economic Area only if the purchase of the product and, therefore, the collection of your personal data has taken place from one of the third parties indicated in paragraph 1 (“the management of your warranty request on the Benelli Armi S.p.A. product“), as companies of the Benelli Armi S.p.A. group, and/or partner companies (commercial agents, representatives and sellers, companies operating in same sector), located in one of the non-EEA countries listed at the following link, or if you have registered (in one of these countries) on the site to get the Warranty Certificate on the Benelli Armi S.p.A. product purchased.

Specifically, your personal data will only be transferred to the partners and/or companies of the group the Data Controller belongs to located in the non-EEA country where the purchase took place and, therefore, the collection of personal data, in order to:

• manage your Warranty Certificate on the purchased Benelli Armi S.p.A. product, as well as its correct execution (management of the contract and related services and benefits) and for the fulfilment of the consequent legal and regulatory obligations.

The personal data transferred for this purpose are: name, surname, physical and electronic address, landline and/or mobile telephone number, weapon model and weapon serial number;

• communicate your personal data to partners and/or companies of the group Benelli Armi S.p.A. belongs to for marketing activities (direct, research and market surveys) carried out by them independently, only if you have given your consent.

The personal data transferred for this purpose are: name, surname, physical and digital address, mobile and/or landline telephone number.

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.
• twenty-five years following the purchase of the product in order to guarantee the correct execution of certain services and benefits deriving from the Warranty certificate, such as aesthetic treatments on the weapon.

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 it 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 its origin (when the data is 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 its accuracy, for the period necessary for Benelli Armi S.p.A. to verify its 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 its processing is done on the basis of a contract and with automated tools – in electronic format, even in order to transmit it 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 recognized 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.