Privacy Policy

DATA CONTROLLER AND GENERAL INFORMATION

Tommaso Giordano, with registered office at S.Polo 697 30125 Venezia, VAT No. 04769580277, is the data controller of the personal data provided by users.

Tommaso Giordano is committed to protecting Users’ right to the protection of personal data.

This Privacy Notice is provided to Users pursuant to applicable Italian and EU data protection laws, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), as well as any other data protection legislation applicable in Italy, including provisions and decisions of the Italian Data Protection Authority (Garante).

Users are advised to read the following carefully in order to understand our approach and practices regarding Personal Data and how it will be processed.

DATA PROCESSORS

The Data Controller uses data processors to achieve the purposes set out below and appoints a designated person responsible for personal data protection (Data Protection Officer – DPO) to oversee compliance and safeguards relating to personal data.

Please note that you may contact the Data Protection Officer at any time and submit any question or request concerning your personal data and the protection of your privacy by writing to: info@tommasogiordano.com.

TYPES OF DATA COLLECTED

The Personal Data collected by this Website/Application, either independently or through third parties, may include: email address, first name, last name, date of birth, gender, delivery address, postal/ZIP code, delivery city, mobile phone number, tax code or VAT number, Cookies and Application Usage Data. Where applicable, if the User registers through social media authentication methods, Anagramma Srl will access certain Personal Data (for example, first name, last name, email address, etc.) from the User’s social media account, in accordance with the applicable terms of use of the relevant social media platform.

Personal Data may be provided directly by the User or, in the case of Usage Data, collected automatically when using this Application.

Unless otherwise specified, all Data requested by this Application is mandatory. If the User refuses to provide it, this Application may be unable to provide the Service. Where this Application indicates certain Data as optional, Users are free not to provide such Data, without any consequences on the availability or operation of the Service.

Users who have doubts about which Data is mandatory are encouraged to contact the Data Controller.

Any use of Cookies—or other tracking tools—by this Application or by the owners of third-party services used by this Application, unless otherwise stated, is intended to provide the Service requested by the User, as well as the additional purposes described in this document and in the Cookie Policy.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application and warrants that they have the right to communicate or disseminate such data, releasing the Data Controller from any liability towards third parties.

METHODS AND PLACE OF PROCESSING OF THE DATA COLLECTED

Processing methods

The Data Controller adopts appropriate security measures to prevent unauthorised access, disclosure, modification or destruction of Personal Data.

Processing is carried out using IT and/or telematic tools, with organisational methods and logic strictly related to the purposes indicated.

In addition to the Data Controller, in some cases other parties involved in the organisation of this Application (administrative, sales, marketing, legal staff, system administrators) or external parties (such as administrative and accounting service providers, couriers and logistics operators, hosting providers and system engineering service providers, payment collection service providers, IT companies and online marketing agencies) may have access to the Data. Where necessary, such parties may also be appointed as Data Processors by the Data Controller. An updated list of Data Processors may always be requested from the Data Controller. These providers have access only to the personal data necessary to perform their tasks. We guarantee that they may not use the same Data for other purposes and that they are required to process Personal Data in accordance with this Privacy Notice and applicable data protection laws.

Legal basis for processing

The Data Controller processes the User’s Personal Data where at least one of the following applies:

  • the User has given consent for one or more specific purposes;

  • processing is necessary for the performance of a contract with the User and/or for the implementation of pre-contractual measures;

  • processing is necessary to comply with a legal obligation to which the Data Controller is subject;

  • processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;

  • processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by third parties.

In any case, it is always possible to ask the Data Controller to clarify the specific legal basis for each processing activity and, in particular, to specify whether processing is based on law, required by a contract, or necessary to enter into a contract.

Place of processing

Data is processed at the Data Controller’s operational offices and in any other place where the parties involved in processing are located.

The User’s Personal Data may be transferred to a country different from the one where the User is located, including countries outside the European Union. When such transfers occur, we ensure they are carried out in accordance with this Privacy Notice and that an adequate level of protection is ensured.

Where any of the transfers described above take place, the User may refer to the relevant sections of this document or request information from the Data Controller using the contact details provided at the beginning.

Retention period

Data is processed and stored for as long as required by the purposes for which it was collected. In general terms, data will be retained until:

  • for Users with addresses in geographical areas served by Tommaso Giordano, the later of:

    • the fifth anniversary after the last use of our Platform or the User’s last active interaction with Tommaso Giordano;

    • the fifth anniversary after account closure if the User has benefited from a member-get-member promotion, or has been identified as involved in a transaction suspected of fraud.

  • for Users with addresses in geographical areas not served by Tommaso Giordano, the tenth anniversary after registration on the Platform.

The following categories of data may be retained for longer periods:

  • financial and accounting data (e.g., invoices, payments, refunds, etc.) are retained for the period required by applicable tax and accounting laws;

  • all user-generated content (e.g., purchased products, behavioural patterns) is anonymised but remains available for our aggregated analysis.

At the end of the retention period, Personal Data will be deleted. Therefore, once this period has expired, the rights of access, deletion, rectification and data portability can no longer be exercised.

PURPOSES OF PROCESSING THE DATA COLLECTED

User Data is collected to allow the Data Controller to provide and optimise its Services, and in particular for:

  • identifying the User, as necessary to access the Application and dedicated products and services, and to ensure proper user support;

  • completing orders and managing payment collection with appropriate control and security measures;

  • preparing and delivering orders;

  • managing invoicing and completing related administrative and tax processes;

  • post-sales assistance and handling support and contact requests;

  • developing marketing activities relating to its Services, as well as analysing and understanding our customers to improve our service (including the user interface experience) and optimise the selection of products offered.

To obtain further information on the Personal Data specifically relevant to each purpose, the User may contact the Data Controller using the contact details provided at the beginning.

USER RIGHTS

Users may exercise certain rights with regard to the Data processed by the Data Controller. In particular, Users have the right to:

  • withdraw consent at any time. Users can withdraw consent previously given for the processing of their Personal Data.

  • object to the processing of their Data. Users can object to the processing of their Data where it is carried out on a legal basis other than consent. Further details are provided below.

  • access their Data. Users have the right to obtain information about the Data processed by the Data Controller, certain aspects of the processing, and to receive a copy of the Data.

  • verify and request rectification. Users can verify the accuracy of their Data and request that it be updated or corrected.

  • obtain restriction of processing. Where certain conditions apply, Users may request that processing of their Data be restricted. In this case, the Data Controller will not process the Data for any purpose other than storage.

  • obtain deletion of their Personal Data. Where certain conditions apply, Users may request that their Data be deleted by the Data Controller.

  • receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transmitted to another controller without hindrance. This applies where the Data is processed by automated means and where processing is based on the User’s consent, a contract to which the User is party, or related contractual measures.

  • lodge a complaint. Users may lodge a complaint with the competent data protection supervisory authority or take judicial action.

Details on the right to object

Where Personal Data is processed in the public interest, in the exercise of official authority vested in the Data Controller, or for the purposes of the legitimate interests pursued by the Data Controller, Users have the right to object to processing on grounds relating to their particular situation.

Users are informed that, at any time and without providing any reason, they may stop receiving newsletters from the Data Controller. To do so, Users are invited to visit the “Preferences” subsection within the “Profile” section of the Website.

How to exercise rights

To exercise their rights, Users may submit a request to the Data Controller using the contact details provided in this document. Requests are handled as soon as possible and in any case within one month.

COOKIE POLICY

This Application uses Cookies. To learn more and to view the detailed notice, Users may consult the Cookie Policy.

FURTHER INFORMATION ON PROCESSING

Legal defence

The User’s Personal Data may be used by the Data Controller in court or in the preparatory stages of possible legal action, to defend against misuse of this Application or related Services by the User.

The User acknowledges that the Data Controller may be required to disclose Data by order of public authorities.

Specific notices

Upon the User’s request, in addition to the information contained in this Privacy Policy, this Application may provide the User with additional and contextual notices concerning specific Services, or the collection and processing of Personal Data.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services it uses may collect system logs, i.e., files that record interactions and may also contain Personal Data, such as the User’s IP address.

Information not contained in this policy

Further information regarding the processing of Personal Data may be requested at any time from the Data Controller using the contact details provided.

“Do Not Track” requests

This Application does not support “Do Not Track” requests. Users are invited to consult the privacy policies of any third-party services used to determine whether they support such requests.

Changes to this Privacy Policy

The Data Controller reserves the right to make changes to this Privacy Policy at any time by notifying Users on this page. Users are therefore asked to check this page regularly, referring to the “last updated” date shown at the bottom. If Users do not accept the changes, they must stop using this Application and may request the Data Controller to remove their Personal Data. Unless otherwise specified, the previous Privacy Policy will apply to Personal Data collected up to that point.

LEGAL REFERENCES

This Privacy Notice is drafted pursuant to Regulation (EU) 2016/679 and Directive 2009/136/EC on Cookies.

DEFINITIONS USED

Personal Data (or Data)
Any information that, directly or indirectly, including in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage Data
Information collected automatically through this Application (including from third-party applications integrated into it), including: IP addresses or domain names of the computers used by the User connecting to this Application, URI addresses, the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical status code of the server response (success, error, etc.), country of origin, browser and operating system features, products added to the cart and possibly purchased, time-related characteristics of the visit (e.g., time spent on each page), and details of the path followed within the Application, with particular reference to the sequence of pages visited and parameters relating to the User’s operating system and IT environment.

User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject
The natural person to whom the collected Personal Data relates.

Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes personal data on behalf of the Data Controller, as described in this Privacy Policy.

Data Controller (or Controller)
The natural or legal person, public authority, service or other body which, alone or jointly with others, determines the purposes and means of processing personal data and the tools used, including security measures relating to the operation and use of this Application. Unless otherwise specified, the Data Controller is the owner of this Application.

This Application
The hardware or software tool by which Users’ Personal Data is collected and processed, either through the website or any Tommaso Giordano mobile applications, where applicable.

Service
The service provided by this Application as defined in the relevant terms (if any) on this website/application.

European Union (or EU)
Unless otherwise specified, any reference to the European Union in this document includes all current EU and EEA Member States.

Cookie
A small piece of data stored on the User’s device.

Unless otherwise specified, this Privacy Notice applies exclusively to this Application.

Last updated: 12/02/2026