Privacy Policy

Tuscany Quintessence SRL – Privacy Policy

This Privacy Policy of Tuscany Quintessence SRL (T5) describes the types of personal information we obtain through the Channels, how we may use that personal information, with whom we may share it, and how you may exercise your rights regarding our processing of the information. The Policy also describes the measures we take to safeguard the personal information we obtain and how you can contact us about our privacy practices.

Personal Information We Obtain

We may obtain personal information through the Channels. The types of personal information we may obtain include:

• contact information (such as name, phone and fax number, email and postal address) for you or for others (e.g., principals in your business);
• information used to create your online account (such as username, password and security question and answer);
• biographical and demographic information (such as date of birth, age, gender, job title/position, marital status and dependent, spousal and other family information);
• purchase and customer service history;
• financial information (such as payment information, including name, billing address and payment card details (i.e., card number, expiration date and security code); bank account information; financial statements; income; and credit score);
• location data (such as data derived from your IP address, country and zip code) and the precise geolocation of your mobile device where we have provided notice and choice, as appropriate;
• contact information you provide about friends or other people you would like us to contact;
• clickstream data and other information about your online activities (such as information about your devices, browsing actions and usage patterns), including across the Online Channels and third-party websites, that we obtain through the use of cookies, web beacons and similar technologies; and
• other personal information contained in content you submit to us (such as through our “Contact Us” feature).

We use third-party web analytics services in connection with the Online Channels, including Google Analytics, Adobe Analytics etc, which use cookies and similar technologies to collect data (such as IP addresses) to evaluate use of and interaction with the Online Channels.

Cookies and Similar Technologies

Like most companies, T5 uses cookies and similar technologies (“cookies”) on our websites to personalize and enhance your experience on our sites.

How We Use Cookies

Cookies contain small amounts of information which are downloaded to your device when you visit our website. Cookies are sent back to our website to allow us to recognize your device.

Essential Cookies allow us to recognize your device to help you navigate efficiently to obtain the information and services you have requested.

Analytical and Customization Cookies allow our site to remember your preferences such as language selection, and help you to view information that is most relevant to your interests; these cookies also help us to maintain and improve our websites by providing information on how visitors find and use the sites, and how well the sites are performing.

Advertising Cookies may be used in some cases to make advertising messages more relevant to you.

Unless you disable the cookies on our website, by using our website you agree to our use of those cookies.

Making Cookie Choices

If you decide to disable cookies on our site, you may not be able to take full advantage of all our website features once you have done so. Except for cookies that are essential to the operation of this website (Essential Cookies), you may make choices about the cookies on this website. Please note that if you choose to manage cookies on our websites, the Tool will place a cookie on your device to allow your choices to be honored.

Sharing Tools

To enhance your experience on our websites, we sometimes embed content and sharing tools from other third-party sites, such as “like” buttons from social networking sites; these third-party sites may also place and access cookies on your device. T5 does not control the placement or access of these third-party cookies.

How We Use Personal Information

We may use the personal information we obtain to:

• provide and administer our products and services;
• process and fulfill orders and keep you informed about the status of your order;
• communicate about and administer our products, services, events, programs and promotions (such as by sending alerts, promotional materials, newsletters and other marketing communications);
• conduct and facilitate surveys, sweepstakes, contests, focus groups and market research initiatives;
• perform data analytics (such as market research, trend analysis, financial analysis and customer segmentation);
• engage in ad retargeting and evaluate the effectiveness of our marketing efforts (including through our participation in ad networks);
• provide customer support;
• process, evaluate and respond to requests, inquiries and applications;
• create, administer and communicate with you about your account (including any purchases and payments);
• administer and register participants in our courses;
• conduct marketing and sales activities (including generating leads, pursuing marketing prospects, performing market research, determining and managing the effectiveness of our advertising and marketing campaigns and managing our brand);
• operate, evaluate and improve our business (such as by administering, enhancing and improving our products and services; developing new products, services and Online Channels; managing our communications and customer relationships; and performing accounting, auditing, billing, reconciliation and collection activities);
• verify your identity and protect against and prevent fraud and other unlawful activity, unauthorized transactions, claims and other liabilities, and manage risk exposure and quality;
• conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies and terms (such as this Privacy Policy and other Online Channels terms of use); and
• maintain and enhance the safety and security of our products, services, Online Channels, network services, information resources and employees.

We may combine personal information we obtain through Online Channels with information we obtain through Offline Channels, as well as other information, for the purposes described above. We may anonymize or aggregate personal information and use it for the purposes described above and for other purposes to the extent permitted by applicable law. We also may use personal information for additional purposes that we identify at the time of collection. We will obtain your consent for these additional uses to the extent required by applicable law.

Where required by applicable law, we will obtain your consent for the processing of your personal information for direct marketing purposes.

The legal basis for T5 processing your personal information as described above will typically be one of the following:

• Your consent;
• Performance of a contract with you or a relevant party;
• Our legitimate business interests; or
• Compliance with our legal obligations.

Personal Information Sharing

We do not sell or otherwise disclose personal information about you except as described here or at the time of collection.

• Share personal information with service providers we have retained to perform services on our behalf (such as payment processing, order fulfillment, customer support and data analytics). Our service providers are contractually required to comply with legal privacy requirements.
• Disclose personal information about you (1) if we are required or permitted to do so by applicable law or legal process (such as a court order or subpoena), (2) to law enforcement authorities or other government officials to comply with a legitimate legal request, (3) when we believe disclosure is necessary to prevent physical harm or financial loss, (4) to establish, exercise or defend our legal rights, (5) in connection with an investigation of suspected or actual fraud or illegal activity or (6) otherwise with your consent.
• We reserve the right to transfer to relevant third-parties any information we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation) or other business combination. In such case, we will require the relevant third parties to provide comparable levels of protection as the T5 provides with respect to the information we share.

Data Transfers

We may transfer the personal information we collect through the Channels to, and store such data in, other countries, including the U.S., which may have different data protection laws than the country in which the information was provided. If we do so, we will transfer the personal information only for the purposes described in this Privacy Policy. To the extent required by applicable law, when we transfer your personal information to recipients in other countries, we will take measures to protect that information.

Your Choices

We offer you certain choices in connection with the personal information we obtain about you. To update your preferences etc. please contact us as specified in the How To Contact Us section of this Privacy Policy.

How We Protect Personal Information Transmission

We maintain administrative, technical and physical safeguards, consistent with legal requirements where the personal information was obtained, designed to protect against unlawful or unauthorized destruction, loss, alteration, use or disclosure of, or access to, the personal information provided to us through the Channels.

Retention of Personal Information

To the extent permitted by applicable law, we retain personal information we obtain about you as long as (1) it is needed for the purposes for which we obtained it, in accordance with the provisions of this Privacy Policy or (2) we have another lawful basis, stated in this Privacy Policy or at the point of collection, for retaining that information beyond the period for which it is necessary to serve the original purpose for obtaining the personal information.

How to Contact Us

If you have any questions or comments about this Privacy Policy or if you would like us to update information, we have about you or your preferences, please write to us at:

Attn: Chief Privacy Officer
Tuscany Quintessence SRL
Via G. Romagnosi, 20
Firenze – 50134
ITALY

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