PRIVACY POLICY

Sofia Italian Furnishings respects your privacy and is committed to protecting

your personal data. This privacy policy will inform you as to how we look after

your personal data when you visit our website and tell you about your privacy

rights and how the law protects you.

Purpose of this privacy policy

This privacy policy aims to give you information on how Sofia Italian

Furnishings collects and processes your personal data through your use of

this website, including any data you may provide through this website when

you sign up to our newsletter or purchase a product or service.

This website is not intended for children and we do not knowingly collect data

relating to children.

It is important that you read this privacy policy together with any other privacy

policy or fair processing policy we may provide on specific occasions when we

are collecting or processing personal data about you so that you are fully

aware of how and why we are using your data. This privacy policy

supplements other notices and privacy policies and is not intended to override

them.

You have the right to make a complaint at any time to the Information

Commissioner’s Office (“ICO”), the UK supervisory authority for data

protection issues (www.ico.org.uk). We would, however, appreciate the

chance to deal with your concerns before you approach the ICO so please

contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

It is important that the personal data we hold about you is accurate and

current. Please keep us informed if your personal data changes during your

relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and

applications. Clicking on those links or enabling those connections may allow

third parties to collect or share data about you. We do not control these third-

party websites and are not responsible for their privacy statements. When you

leave our website, we encourage you to read the privacy policy of every

website you visit.

The data we collect about you

Personal data, or personal information, means any information about an

individual from which that person can be identified. It does not include data

where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about

you which we have grouped together as follows:

“Identity Data” includes first name, maiden name, last name, username or

similar identifier.

“Contact Data” includes billing address, delivery address, email address and

telephone numbers.

“Financial Data” includes bank account and payment card details.

“Transaction Data” includes details about payments to and from you and

other details of products and services you have purchased from us.

“Technical Data” includes internet protocol (IP) address, your login data,

browser type and version, time zone setting and location, browser plug-in

types and versions, operating system and platform, and other technology on

the devices you use to access this website.

“Profile Data”includes your username and password, purchases or orders

made by you, your interests, preferences, feedback and survey responses.

“Usage Data” includes information about how you use our website, products

and services.

“Marketing and Communications Data”includes your preferences in

receiving marketing from us and our third parties and your communication

preferences.

We also collect, use and share aggregated data such as statistical or

demographic data for any purpose. Aggregated data could be derived from

your personal data but is not considered personal data in law as this data will

not directly or indirectly reveal your identity. For example, we may aggregate

your Usage Data to calculate the percentage of users accessing a specific

website feature. However, if we combine or connect aggregated data with

your personal data so that it can directly or indirectly identify you, we treat the

combined data as personal data which will be used in accordance with this

privacy policy.

We do not collect any Special Categories of Personal Data about you (this

includes details about your race or ethnicity, religious or philosophical beliefs,

sex life, sexual orientation, political opinions, trade union membership,

information about your health, and genetic and biometric data). Nor do we

collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a

contract we have with you, and you fail to provide that data when requested,

we may not be able to perform the contract we have or are trying to enter into

with you (for example, to provide you with goods or services). In this case, we

may have to cancel a product or service you have with us but we will notify

you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including

through:

Direct interactions. You may give us your Identity, Contact and Financial

Data by filling in forms or by corresponding with us by post, phone, email or

otherwise. This includes personal data you provide when you:

(a) apply for our products or services;

(b) subscribe to our service or publications;

(c) request marketing to be sent to you;

(d) enter a competition, promotion or survey; or

(e) review a product, give us feedback or contact us.

Automated technologies or interactions. As you interact with our website,

we will automatically collect Technical Data about your equipment, browsing

actions and patterns. We collect this personal data by using cookies, server

logs and other similar technologies. We may also receive Technical Data

about you if you visit other websites employing our cookies. Please see

our cookie policy for further details.

Third parties or publicly available sources. We will receive personal data

about you from various third parties and public sources as set out below:

(a) Contact, Financial and Transaction Data from providers of technical,

payment and delivery services based inside and outside the EU;

(b) Identity and Contact Data from publicly available sources such as

Companies House and the Electoral Register based inside the EU.

How we use your personal data

We will only use your personal data when the law allows us to. Most

commonly, we will use your personal data in the following circumstances:

(a) Where we need to perform the contract we are about to enter into or have

entered into with you;

(b) Where it is necessary for our legitimate interests (or those of a third party)

and your interests and fundamental rights do not override those interests; and

(c) Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your

personal data although we will get your consent before sending third party

direct marketing communications to you via email or text message. You have

the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data:

Note that we may process your personal data for more than one lawful ground

depending on the specific purpose for which we are using your data. Please

contact us if you need details about the specific legal ground we are relying on

to process your personal data where more than one ground has been set out

in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses,

particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form

a view on what we think you may want or need, or what may be of interest to

you. This is how we decide which products, services and offers may be

relevant for you.

You will receive marketing communications from us if you have requested

information from us or purchased goods or services from us and you have not

opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data

with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at

any time by:

(a) following the opt-out links on any marketing message sent to you; or

(b) contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply

to personal data provided to us as a result of a product/service purchase,

warranty registration, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert

you when websites set or access cookies. If you disable or refuse cookies,

please note that some parts of this website may become inaccessible or not

function properly. For more information about the cookies we use, please see

our cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it,

unless we reasonably consider that we need to use it for another reason and

that reason is compatible with the original purpose. If you wish to get an

explanation as to how the processing for the new purpose is compatible with

the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify

you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge

or consent, in compliance with the above rules, where this is required or

permitted by law.

Disclosures of your personal data

We may share your personal data with the following parties:

(a) Internal Third Parties as set out below:

(b) External Third Parties as set out below; and

(c) Third parties to whom we may choose to sell, transfer or merge parts of

our business or our assets. Alternatively, we may seek to acquire other

businesses or merge with them. If a change happens to our business, then the

new owners may use your personal data in the same way as set out in this

privacy policy.

We require all third parties to respect the security of your personal data and to

treat it in accordance with the law. We do not allow our third-party service

providers to use your personal data for their own purposes and only permit

them to process your personal data for specified purposes and in accordance

with our instructions.

International transfers

Whenever we transfer your personal data out of the European Economic Area

(“EEA”), we ensure a similar degree of protection is afforded to it by ensuring

at least one of the following safeguards is implemented:

(a) We will only transfer your personal data to countries that have been

deemed to provide an adequate level of protection for personal data by the

European Commission;

(b) Where we use certain service providers, we may use specific contracts

approved by the European Commission which give personal data the same

protection it has in Europe; and

(c) Where we use providers based in the US, we may transfer data to them if

they are part of the Privacy Shield which requires them to provide similar

protection to personal data shared between Europe and the US.

Please contact us if you want further information on the specific mechanism

used by us when transferring your personal data out of the EEA.

Data security

We have put in place appropriate security measures to prevent your personal

data from being accidentally lost, used or accessed in an unauthorised way,

altered or disclosed. In addition, we limit access to your personal data to those

employees, agents, contractors and other third parties who have a business

need to know. They will only process your personal data on our instructions

and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data

breach and will notify you and any applicable regulator of a breach where we

are legally required to do so.

Data retention

We will only retain your personal data for as long as reasonably necessary to

fulfil the purposes we collected it for, including for the purposes of satisfying

any legal, regulatory, tax, accounting or reporting requirements. We may

retain your personal data for a longer period in the event of a complaint or if

we reasonably believe there is a prospect of litigation in respect to our

relationship with you.

To determine the appropriate retention period for personal data, we consider

the amount, nature and sensitivity of the personal data, the potential risk of

harm from unauthorised use or disclosure of your personal data, the purposes

for which we process your personal data and whether we can achieve those

purposes through other means, and the applicable legal, regulatory, tax,

accounting or other requirements.

Your legal rights

Under certain circumstances, you have rights under data protection laws in

relation to your personal data:

(a) Request access to your personal data;

(b) Request correction of your personal data;

(c) Request erasure of your personal data;

(d) Object to processing of your personal data;

(e) Request restriction of processing your personal data;

(f) Request transfer of your personal data; and

(g) Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any

of the other rights). However, we may charge a reasonable fee if your request

is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to

comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your

identity and ensure your right to access your personal data (or to exercise any

of your other rights). This is a security measure to ensure that personal data is

not disclosed to any person who has no right to receive it. We may also

contact you to ask you for further information in relation to your request to

speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it

could take us longer than a month if your request is particularly complex or

you have made a number of requests. In this case, we will notify you and keep

you updated.