PRIVACY POLICY
DELETTO Studio s.r.l.
Last Updated: June 2025
1. INTRODUCTION
DELETTO Studio s.r.l. ("DELETTO," "we," "our," or "us"), with registered office at Cadore 9 Cap 20135, Milano (MI), Italy, is committed to protecting your privacy and ensuring you have a positive experience when you use our services, visit our website at www.delettomilano.com, or interact with us in any way.
This Privacy Policy explains our practices regarding the collection, use, and disclosure of information in compliance with Regulation (EU) 2016/679 ("GDPR") and applies to all users of DELETTO services, including unregistered visitors, registered users, and clients.
This Privacy Policy applies exclusively to our website and services. It does not extend to other websites, pages, or online services accessible through hyperlinks that may redirect to resources outside our domain.
2. DATA CONTROLLER AND CONTACT INFORMATION
Data Controller:
DELETTO Studio s.r.l.
Cadore 9 Cap 20135
Milano (MI), Italy
Email: info@delettomilano.com
Phone: (917) 669-0212
Data Protection Officer:
Email: info@delettomilano.com
3. INFORMATION WE COLLECT AND PROCESSING PURPOSES
A. Account Registration and User Profiles
Data Collected: Name, surname, email address, telephone number, mailing address, date of birth, biographical information, measurements, style preferences, and lifestyle information.
Legal Basis: Contract execution (Art. 6.1.b GDPR) and pre-contractual measures at your request.
Purpose: To create and maintain your account, provide personalized styling services, and enable access to exclusive features.
Retention Period: Until account closure, subject to other legal obligations.
Mandatory/Optional: Required for account creation and service provision. Refusal to provide this data will prevent account registration and access to our personalized services.
B. Purchase and Transaction Processing
Data Collected: Name, surname, billing and shipping addresses, payment information (processed securely by our payment partners), order details, and purchase history.
Legal Basis: Contract execution (Art. 6.1.b GDPR).
Purpose: To process transactions, fulfill orders, send order confirmations, and provide customer support related to purchases.
Retention Period: For the duration necessary to complete the transaction and fulfill legal obligations, typically up to 10 years for accounting purposes.
Mandatory/Optional: Required for purchase completion. Failure to provide this information will prevent transaction processing.
C. Customer Support and Communications
Data Collected: Contact information, communication history, support requests, and any information you provide when contacting us.
Legal Basis: Pre-contractual measures (Art. 6.1.b GDPR) or legitimate interest (Art. 6.1.f GDPR).
Purpose: To provide customer support, respond to inquiries, handle complaints, and improve our services.
Retention Period: Until resolution of the inquiry and for a reasonable period thereafter for quality assurance.
Mandatory/Optional: Optional, but necessary to receive support services.
D. Legal Compliance and Administrative Obligations
Data Collected: Transaction records, accounting information, and data required for regulatory compliance.
Legal Basis: Legal obligation (Art. 6.1.c GDPR).
Purpose: To comply with accounting, tax, and other legal requirements.
Retention Period: As required by applicable laws, typically up to 10 years.
Mandatory/Optional: Mandatory for legal compliance.
E. Marketing Communications
Data Collected: Name, email address, telephone number, preferences, and interaction history with our communications.
Legal Basis: Explicit consent (Art. 6.1.a GDPR).
Purpose: To send newsletters, promotional materials, event invitations, and personalized offers about our products and services.
Retention Period: Until consent is withdrawn or up to 24 months from registration.
Mandatory/Optional: Entirely optional. You may withdraw consent at any time using the unsubscribe link in our communications or by contacting info@delettomilano.com.
F. Personalization and Profiling
Data Collected: Purchase history, browsing behavior, style preferences, measurements, and interaction patterns.
Legal Basis: Explicit consent (Art. 6.1.a GDPR).
Purpose: To analyze preferences and create personalized styling recommendations, customized product suggestions, and tailored shopping experiences.
Retention Period: Until consent is withdrawn or up to 12 months from last activity.
Mandatory/Optional: Optional. You may object to profiling at any time through your account settings or by contacting us.
G. Website Analytics and Performance
Data Collected: IP addresses, browser information, device identifiers, pages visited, time spent on site, and interaction patterns.
Legal Basis: Legitimate interest (Art. 6.1.f GDPR).
Purpose: To analyze website performance, improve user experience, ensure security, and generate anonymous statistical reports.
Retention Period: Typically 12-24 months, with anonymization applied where possible.
Right to Object: You may object to this processing for reasons related to your particular situation.
H. Security and Fraud Prevention
Data Collected: Device information, IP addresses, transaction patterns, and security-related data.
Legal Basis: Legitimate interest (Art. 6.1.f GDPR) and legal obligation (Art. 6.1.c GDPR).
Purpose: To protect against fraud, ensure platform security, and comply with anti-money laundering regulations.
Retention Period: As necessary for security purposes and legal compliance.
4. AUTOMATED DATA COLLECTION
Browsing Data
Our systems automatically collect certain information during normal website operation, including IP addresses, domain names, URI addresses, request timestamps, server response codes, and technical parameters about your operating system and browser environment.
This data is necessary for website functionality and is used to obtain anonymous usage statistics and ensure proper service operation.
Cookies and Tracking Technologies
We use technical and analytical cookies to enhance your browsing experience. For detailed information about our cookie usage, including types, purposes, and management options, please refer to our Cookie Policy accessible in the website footer.
Profiling cookies are only activated with your explicit consent and are used for content personalization, social media integration, and traffic analysis.
5. DATA SHARING AND RECIPIENTS
We may share your information with the following categories of recipients:
Service Providers
Third-party vendors who provide services on our behalf, including hosting providers, payment processors, shipping companies, email service providers, and customer support platforms.
Business Partners
Selected partners for joint promotions, events, or services, only with your explicit consent.
Legal Requirements
Authorities, law enforcement, or third parties when required by law, court order, or to protect our legal rights and safety.
Business Transactions
In connection with mergers, acquisitions, or asset transfers, your information may be transferred as part of the business transaction.
DELETTO Group Companies
Other entities within our corporate group for administrative, accounting, and service provision purposes based on legitimate interest.
A complete list of data processors is available upon request at info@delettomilano.com.
6. INTERNATIONAL DATA TRANSFERS
Your information may be transferred to and processed in countries outside the European Economic Area. When such transfers occur, we implement appropriate safeguards, including Standard Contractual Clauses approved by the European Commission, to ensure your data remains protected in accordance with this Privacy Policy and applicable data protection laws.
7. YOUR RIGHTS
Under the GDPR, you have the following rights regarding your personal data:
- Access: Request access to your personal information and details about our processing activities
- Rectification: Request correction of inaccurate or incomplete data
- Erasure: Request deletion of your personal data under certain circumstances
- Restriction: Request limitation of processing under specific conditions
- Data Portability: Receive your data in a structured, machine-readable format
- Objection: Object to processing based on legitimate interest or for marketing purposes
- Withdraw Consent: Revoke consent for processing activities that require it
To exercise these rights, contact our Data Protection Officer at info@delettomilano.com. We will respond to your request within one month of receipt.
8. DATA SECURITY
We implement robust technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption, access controls, regular security assessments, and staff training.
While we strive to maintain the highest security standards, no system is completely secure. We cannot guarantee absolute security but commit to promptly addressing any security incidents.
9. DATA RETENTION
We retain your personal data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods are detailed in each processing purpose section above.
When data is no longer needed, we securely delete or anonymize it in accordance with our data retention schedule.
10. CHILDREN'S PRIVACY
Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If we become aware that we have collected such information, we will take immediate steps to delete it and may suspend the related account.
11. UPDATES TO THIS PRIVACY POLICY
We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of significant changes by posting a notice on our website or sending an email notification to registered users.
The "Last Updated" date at the top of this policy indicates when the most recent changes were made. We encourage you to review this Privacy Policy regularly.
12. CONTACT US AND COMPLAINTS
For questions about this Privacy Policy, to exercise your rights, or to file a complaint:
Data Protection Officer
DELETTO Studio s.r.l.
Cadore 9 Cap 20135
Milano (MI), Italy
Email: info@delettomilano.com
Phone: (917) 669-0212
You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) or your local supervisory authority if you believe our processing of your personal data violates applicable data protection laws.
This Privacy Policy demonstrates DELETTO's commitment to transparency and data protection. We encourage you to contact us with any questions or concerns about how we handle your personal information.