Legal Area
Privacy Notice
Betty Blue S.p.A. (owner of the “Elisabetta Franchi” brand and hereinafter referred to as such) and The Level S.r.l. (hereinafter “The Level Group” or “TLG”) care about protecting your personal data and respecting your privacy.
Here we explain what data we use, for what purposes and how you can exercise your choices.
Who this notice is for
This information concerns you if you visit or make purchases on the website https://outlet.elisabettafranchi.com, if you have an account on our outlet, if you receive our communications relating to the official outlet or if you interact with the official social media channels of the Elisabetta Franchi brand. This notice is provided pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 on the protection of personal data (hereinafter the “Regulation”).
Who we are
For registration on the outlet website and the management of purchases, Betty Blue S.p.A., tax code and VAT No. 01842471201, with registered office at Via Viadagola, 30 - 40057 - Quarto Inferiore di Granarolo Emilia (BO), and The Level S.r.l., with registered office at Piazza Arcole 4, 20143 Milano, VAT No. 12627050961, REA MI-1945372, are joint controllers: together they determine the purposes and the essential means by which data is used for these activities. TLG enters into the sales contract with you and manages the platform, orders, payments and customer service; Elisabetta Franchi is responsible for product availability and shipping and assists in the management of orders and returns. The companies have allocated their respective tasks by means of an arrangement pursuant to Article 26 of the Regulation and work together to provide you with information and respond to your requests. You may exercise your rights in respect of and against each of them, regardless of this allocation, and you may request further information from either privacy@elisabettafranchi.com or privacy@thelevelgroup.com.
For the promotional initiatives of the official Elisabetta Franchi outlet, marketing communications and the management of its social media channels, as described below, the controller is Betty Blue S.p.A.: it determines the purposes and means of these activities and engages TLG as its processor, which acts on its instructions. This also applies if you have subscribed to the newsletter without having an account on the website.
Elisabetta Franchi has appointed a Data Protection Officer, whom you can contact at dpo@elisabettafranchi.com.
You can contact TLG’s Data Protection Officer at dpo@thelevelgroup.com.
Each company acts as an independent controller for its own accounting and tax obligations and for the protection of its own rights. The role of the social media platform operators is explained in the section “Our social media pages”.
Our responsibility
We use the data necessary for the purposes described in this notice, in accordance with your choices and the responsibilities set out above. If a service requires further information, we will provide it to you before collecting the data.
When and how we collect your personal data
We collect the data you provide to us when you create an account, make a purchase, request assistance or subscribe to communications relating to the official Elisabetta Franchi outlet. Some technical data is collected automatically while you browse. Cookies, i.e. small files stored on your device, and similar tools are used without consent only when strictly necessary for the technical operation of the website; in all other cases we will first ask for your consent through the cookie preferences panel. More information about cookies is available in the Cookie Policy , which can always be accessed via the link in the footer of every page of the Site.
This is how data is collected:
Name and contact details: provided by you in forms and requests.
Browsing: collected by the service: technical data and, according to your cookie choices, other data.
Telephone number: provided by you, if required for the service or if you choose to share it.
Use of the outlet: provided by you: preferences and requests. Collected by the service: interactions, within the limits described.
Purchases: provided by you: order and contact details. Collected by the service: payment and delivery outcomes.
Customer service: provided by you: requests and messages. Collected by the service: the order data needed to assist you.
Promotional communications: provided by you: contact details and choices. Collected by the service, with your consent: e-mail opens and clicks.
The types of data we collect:
a. Contact details, purchases and requests
Your first name and surname, shipping and billing addresses, e-mail address and, where necessary for the service requested or provided optionally, your telephone number. We also use account data, the products purchased and amounts spent, payment outcomes, information on deliveries, returns and refunds, your customer service requests and the preferences you share with us. Mandatory fields are identified as such in the forms; all other fields are optional.
b. Browsing data
Your IP address, i.e. the address used by your device to communicate over the network, the type of device and software used to browse, the dates and times of access and the technical information necessary for the operation and security of the website.
c. Data relating to the use of the outlet website and to communications
The pages and products viewed, interactions with the outlet and, with the consent described below, e-mail opens and clicks on the links they contain. The information collected through cookies and similar tools, their respective purposes and the choices available are described in the Cookie Policy , which can always be accessed via the link in the footer of every page of the Site.
d. What about more sensitive and special data?
We will not ask you for data concerning your health, religious or political beliefs, ethnic origin, sex life or other data belonging to the special categories referred to in Article 9 of the Regulation, and we will never use such data for advertising or to analyse your preferences. We ask you not to include such data in messages or comments.
Why do we collect your data?
Every use of data must have a specific purpose and a basis provided for by law, known as the “legal basis”. Below you will find the purposes, the activities carried out and their respective legal bases.
i. Use of the outlet website and management of services
We process your data to enable you to create and manage your account, receive orders and perform the sales contract entered into with TLG, including payments, delivery, returns, refunds and warranties. The legal basis is the performance of the contract or of pre-contractual measures requested before entering into it, pursuant to Article 6(1)(b) of the Regulation. For accounting and tax compliance and other legal obligations, the legal basis is Article 6(1)(c); for establishing, exercising or defending the rights of the joint controllers, including in relation to complaints or disputes, it is legitimate interest, pursuant to point (f) of the same Article.
ii. Monitoring and fraud prevention activities
We use order data, payment outcomes and relevant technical information to prevent fraud, unauthorised access and unlawful use of the website www.outlet.elisabettafranchi.com. The legal basis is our legitimate interest in protecting transactions and systems, taking your rights into account. If further checks are necessary, we will tell you what information is needed (for example, the authorisation code, which is not shown in the confirmation e-mail but can be requested from your bank) and through which secure channel to provide it; failure to provide the strictly necessary information or the additional information requested for verification purposes may prevent the order from being completed. We will never ask you to send us by e-mail a full copy of your credit or debit card, its security code or the login credentials for your banking services.
iii. Customer support
We use your contact details, order data and the content of your requests to assist you through the available contact channels and to send you the necessary service communications. The legal basis is the performance of the contract or of the measures requested before purchase.
iv. Marketing
With your consent, Elisabetta Franchi uses the contact details you provide to send you news, offers, invitations and other commercial communications about its products, as well as, where applicable, optional customer satisfaction surveys. Elisabetta Franchi may select the communications sent using simple spending brackets based on purchases made in the last 12 months. This selection is used to choose which offers to send you and does not involve building an individual profile of your tastes or predicting your interests. Communications are sent by e-mail and, if you select them through the relevant forms, through the other channels indicated, such as WhatsApp messages, telephone calls or post. The legal basis is consent, pursuant to Article 6(1)(a) of the Regulation. You may refuse or withdraw your consent without any consequences for your purchases or the services requested.
If you have already made a purchase on the outlet website, Elisabetta Franchi may use the e-mail address provided at the time of purchase to offer you other Products from the official Elisabetta Franchi outlet (sold by TLG) similar to those purchased, pursuant to Article 130(4) of the “ Italian Privacy Code ” (Legislative Decree 196/2003, as amended and supplemented). Elisabetta Franchi acts as an independent controller for this marketing purpose.
v. E-mail opens and clicks
E-mail communications relating to our outlet may contain small invisible images, known as “tracking pixels”, and links that record interactions. These make it possible to detect whether and when a message is opened or a link is clicked and to associate these events with the recipient, together with other technical data necessary for detection. Elisabetta Franchi uses this data to measure the effectiveness of its communications and to tailor their content. This detection, which may be affected by the settings of the e-mail program you use, may take place on the various devices on which you read the messages sent to the address you provided to us.
Consent to the use of tracking pixels is requested at the time of sign-up, together with consent to our promotional communications, with an explicit indication of their use. Afterwards, you can always deactivate pixel tracking alone, while continuing to receive our e-mails, via the preference management link in the footer of each message. If you unsubscribe from our newsletter services, both the mailings and pixel tracking will cease. The legal basis is consent, pursuant to Article 122 of the Italian Privacy Code. Even after you have withdrawn your consent to the use of tracking pixels within our newsletter service, service communications that are required by law or necessary for orders and the security of your account may still contain pixels used for strictly technical purposes.
vi. Analysis of preferences and purchasing habits for suggestions closer to your style
If you wish, Elisabetta Franchi may get to know your preferences better in order to offer you selections of its Products, suggestions and content closer to your style, on the website and in the communications you have chosen to receive. With your separate consent to profiling (pursuant to Article 6(1)(a) of the Regulation), we analyse and combine your purchase history, the preferences you share with us and your interactions with the Products and content of our outlet website and our related e-mails, collected in accordance with your tracking choices, in order to identify the Products and offers you might like.
For this purpose, we do not in any way use information about your health or other sensitive or special aspects, nor data purchased from third parties, nor the reconstruction of your browsing on websites unrelated to Elisabetta Franchi. We use browsing data only with your consent to the relevant cookies or tools; interactions with e-mails may contribute to this purpose only if you have also consented to their use.
You can choose marketing without profiling, or profiling without receiving promotional e-mails, and likewise you can withdraw these consents separately via the dedicated preference management links or by writing to privacy@elisabettafranchi.com or privacy@thelevelgroup.com. We also produce sales statistics on the basis of our legitimate interest in organising our product ranges and improving our services.
We do not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you.
Our social media pages and the social media campaigns we may run
Elisabetta Franchi uses its own pages on Instagram, Facebook, TikTok, X (Twitter), YouTube and Snapchat and its own WhatsApp channels to share content and manage messages, comments and requests. It may therefore process your profile name, the content of your interactions and the information you choose to make visible, to the extent necessary to respond to you and manage the pages, including by moderating unlawful, offensive or unwanted messages. The legal basis is our legitimate interest in communicating with the public and maintaining orderly and secure channels; for requests relating to a purchase or a service, the (pre-)contractual legal basis applies.
The platforms also provide us with aggregate statistics on visits, interactions and content performance, which we use to understand how our pages are performing. For the operations we help to determine, such as the production of certain statistics and standard campaigns (so-called retargeting), Elisabetta Franchi and the platform operator may be joint controllers. Other operations carried out independently by the platforms remain governed by their own privacy notices.
For retargetingactivities, Elisabetta Franchi may use, with the consent collected through the cookie management mechanisms, data on visits to the website to show again on social media the products viewed or similar products; or it may match the e-mail addresses or telephone numbers of those who have consented to profiling against those of the social media platform’s users, in order to show adverts to a selected audience (“personalised audience” or “custom audience”). In the latter case, contact details are protected by converting them into codes (hashing) before matching. In addition, we may ask social media platforms to identify new recipients with characteristics similar to the target audience we have described, in order to introduce the Elisabetta Franchi brand to potential new audiences. These latter activities (so-called prospecting) may result in the social media platform, acting as controller, combining the descriptive information received from Elisabetta Franchi with information it already holds.
For advertising tracking on the website, you can always choose and change your consent in the cookie panel. You may also exercise the rights described in this notice against Elisabetta Franchi in respect of social media activities. In addition, you can manage your advertising preferences in the platforms’ own settings. To find out about and be aware of the other processing activities carried out independently by the social media platform operators, we suggest that you consult the respective privacy notices of Instagram, Facebook, TikTok, X (Twitter), YouTube and Snapchat.
Minors
Purchases on the website are reserved for adults. We do not intentionally direct our promotional initiatives at minors. If you believe that a minor has provided us with data in a manner that is not permitted, you can report this to us using the contact details given in this notice, so that we can verify it and take the necessary measures.
What we mean by legal basis:
Consent
This is the authorisation to process your personal data for a specific purpose.
When we ask for your consent, you can give it freely through an active choice, for example by ticking a box that is not pre-ticked. You can change your mind whenever you wish.
You can withdraw your consent at any time by writing to privacy@elisabettafranchi.com or privacy@thelevelgroup.com or by using the links in our communications or in the reserved area for managing your account. You can manage your marketing and profiling consents separately and also deactivate e-mail tracking alone.
Withdrawal does not affect the lawfulness of processing carried out before it. After withdrawal, we stop processing for that purpose; we may retain data needed for other purposes, such as tax obligations or the protection of rights, but only where there is a corresponding legal basis.
The contract
The processing of your data is necessary to perform the contract or to carry out the activities you ask us to carry out before entering into it, such as responding to a request about a purchase.
Legal obligations
Some data must be processed to comply with obligations laid down by law, for example to issue and retain tax documents or to respond to requests from the competent authorities.
Legitimate interest
We may process the data necessary for a legitimate interest pursued by us or by a third party only if, after balancing it against your interests, rights and freedoms, the latter do not override it. In this notice we expressly state, for each purpose, the interests pursued, the activities to which they relate and how you can object.
Legitimate interests may include, for example:
· providing, developing and improving our services;
· improving, personalising or changing how we provide our services and our offers;
· improving the protection of our data and yours.
How we process your data:
We process data mainly using IT tools and, where necessary, also in paper form. Data is accessed by authorised and trained personnel and by suppliers who need it for the tasks entrusted to them.
Your choices and your rights
Your choices
· You may decide not to provide us with your data
If you do not provide the data necessary for a purchase or for another service requested, we cannot carry it out. Refusing cookies and other optional processing does not prevent normal browsing or purchases; only the technical data essential for the operation of the website remains necessary.
Signing up to promotional communications and personalised advertising is optional and is not a condition for creating an account, making a purchase or requesting assistance.
You can stop promotional communications via the unsubscribe link in every e-mail, by writing to privacy@elisabettafranchi.com or privacy@thelevelgroup.com, or by using the functions in the reserved area for managing your account. Unsubscribing from e-mails does not automatically withdraw profiling on the website, which you can deactivate separately, and vice versa.
Your rights
You can exercise the rights provided for in Articles 15 to 22 of the Regulation by writing to privacy@elisabettafranchi.com or privacy@thelevelgroup.com. For processing carried out under joint controllership, you may contact either company; for other processing, your request will in any case be forwarded to the competent party without undue delay.
· You have the right to access information concerning you.
You can find out whether we process data concerning you, obtain a copy of it and be informed of the purposes, the categories of data, the recipients, the retention periods, any sources and the safeguards for transfers abroad.
We will respond to you without undue delay and, as a rule, within one month. If the request is complex or there are numerous requests, this period may be extended by a maximum of a further thirty days, and we will in any case inform you of this within the first month. Exercising your rights is free of charge, except in the cases provided for by law. If we cannot comply with your request, we will explain why and what remedies are available to you. We may ask you for further information in order to verify and confirm your identity.
· You have the right to have your data rectified or completed if it is inaccurate or incomplete.
· You have the right to request the erasure of your data.
You may request this, for example, when the data is no longer necessary, when you withdraw your consent and there is no other ground for retaining it, or when you withdraw one or more consents you have freely given. This is without prejudice to legal obligations and the other cases in which the Regulation allows the data to be retained.
· You have the right to request restriction of processing.
In the cases provided for by the Regulation, for example while we verify the accuracy of data you contest or the grounds for an objection, you may request that the data be retained while its other uses are restricted.
· You have the right to data portability.
For the data you have provided to us that is processed by automated means on the basis of consent or a contract, you can receive a copy in a structured, commonly used and machine-readable format. Where technically feasible, you can ask us to transmit it directly to another controller, without adversely affecting the rights of others.
· You have the right to object to the processing of your data.
For processing based on legitimate interest, you may object on grounds relating to your particular situation: we will stop the processing unless the conditions laid down in Article 21 of the Regulation for continuing it are met.
You may also lodge a complaint with the Garante per la protezione dei dati personali (the Italian Data Protection Authority), www.garanteprivacy.it, or with the supervisory authority of the European Union Member State in which you reside, work or believe the infringement took place.
For decisions based solely on automated processing that produce legal or similarly significant effects, the Regulation provides for specific safeguards, including, where applicable, human intervention and the right to contest the decision. As stated above, we do not make decisions of this kind.
Your rights in respect of both joint controllers
The allocation of tasks between Elisabetta Franchi and TLG does not limit your rights: for activities carried out jointly, both cooperate in handling requests and ensure that they are answered.
What level of security do we adopt to process your data?
We adopt technical and organisational measures appropriate to the risks in order to protect data against unauthorised access, loss, alteration, unavailability or disclosure. We verify the safeguards offered by our suppliers and limit access to those who need it.
We ask you to keep your account credentials safe and not to share them. If you suspect unauthorised access or a security problem, contact us immediately at privacy@thelevelgroup.com or privacy@elisabettafranchi.com.
Where is your data processed?
Data is processed by the companies and suppliers indicated in this notice. The use of IT services and communication platforms (such as, for example, SaaS cloud services and/or Direct Email Marketing platforms) may involve the transfer of your data, including by means of remote access, to countries outside the European Economic Area, which comprises the European Union, Iceland, Liechtenstein and Norway.
In such cases, we rely on a European Commission decision recognising an adequate level of protection, within the limits of its scope, or on the standard contractual clauses approved by the Commission, together with any additional measures that may be necessary.
How long will we keep your data?
We retain data for as long as necessary for the purposes described, according to the following criteria and limits.
For technical data and information collected through cookies and similar tools, the retention periods are set out in theCookie Policy. Any further retention concerns only the data necessary to establish incidents or unlawful acts or to comply with legal obligations.
For the remaining purposes, we will stop processing your data within:
· 12 months from the last use of the service or from the closure of your account, for the types of processing connected with the use of the official Elisabetta Franchi outlet and for data used to produce internal statistics and analyses.
· 24 months from your last purchase and/or your last contact with you (e.g. opening a link contained in a commercial communication sent by us) for marketing and profiling purposes.
· 10 years from the date of entry in the accounting and tax records, for the issuing of tax documents and the related accounting entries connected with a purchase you made through our outlet.
At the end of the retention periods indicated above, your data will be automatically erased or aggregated or permanently and irreversibly anonymised.
Third parties that may process your data
Data may be disclosed, to the extent necessary, to providers of platforms and IT services, customer service, shipping, payments and communication activities. Suppliers acting on the instructions of the joint controllers and on their behalf are appointed as processors pursuant to Article 28 of the Regulation and are bound by confidentiality and security obligations. Professional advisers, payment service providers and the competent authorities may instead process data as independent controllers for the activities within their remit. For social media platforms, the roles described in the dedicated section apply.
Payment service providers receive the data necessary to carry out the transaction and perform the checks within their remit in accordance with their respective privacy notices, which are available when you choose your payment method. Elisabetta Franchi and TLG receive the information necessary to manage the order, such as the outcome of the transaction, without this involving access to the full card details.
Your data is not disseminated to the public (except for content you choose to publish, such as your comments on the official Elisabetta Franchi social media pages).
Thank you!
We have tried to make this notice clear and useful. If you have any questions or suggestions, you can write to us at privacy@thelevelgroup.com or privacy@elisabettafranchi.com.
This notice may be updated, and any material changes will be brought to your attention by appropriate means, including via the website or by e-mail.
Texts for website forms (to be placed at the respective points of collection)
[ ] I have read the Privacy Notice and wish to create my account.*
[ ] Inspiration and news from the official Elisabetta Franchi outlet
I would like to receive style inspiration, news, invitations and selected offers from the official Elisabetta Franchi outlet. I consent to personalised marketing through the tracking of e-mail opens and clicks, to monitor campaign performance, as described in the Privacy Notice.
[ ] A selection that speaks to you
I would like to discover suggestions closer to my style. I consent to profiling by the Elisabetta Franchi brand, through the combined analysis of my preferences and my interactions with the official outlet and the world of Elisabetta Franchi, in order to better understand my interests and personalise suggestions, as described in the Privacy Notice.