Last Updated: March 25, 2018

This privacy policy (the “Privacy Policy”) applies of this website, apps and products and / or services related to it, in relation to the processing of personal data of users / visitors (Users) who consult, and is provided pursuant to section. 13 of Legislative Decree no. 196/2003 ( “Privacy Code”).

This privacy policy (“Privacy Policy”) applies to our website (“Website”), our products and services ( “Felfil Products “), available at our Website,  our software (” Felfil Software”). These devices, Website, software are collectively referred to herein as “Services Felfil”.

The Data manager and Website owner is:

Felfil srl

Via Sant’Ambrogio 28

10139 Torino


Felfil may occasionally and unilaterally change this Privacy Policy, according to any improvement in Felfil services, or to technological and legislative developments. Any changes will become effective only when the new version of this Privacy Policy will be published on the Felfil Website.  All visitor of the Website (“Users”) can refer to the “Last Update” date shown at the beginning of this page, to know the latest version of this Privacy Policy. In order to secure the Users’ consent, if required by law, Any changes will be notified to the Users  by mail or through other means, otherwise will be posted on the Website, before the change becomes effective.

Felfil is constantly striving to protect Users’ personal data; however, no data transmission on   Internet can be considered absolutely safe, thus Felfil is not responsible of the security of any data provided by the Users. All Users’ personal data are exclusively transmitted at their own risk.


When buying  a Product, creating your account on the website, subscribing to a newsletter, or contacting our support staff, Felfil can collect a series of personal data (“Personal Information”) which eventually may include name, postal address, telephone number and e-mail. All Personal Data may be collected and / or treated by Felfil srl in Italy or in another EU member State, according to EU Directive 95/46 / EC



Felfil collects data from all Users who visit the Website, even if they doesn’t have an account.

When a User visits the Website, Felfil collects data from industry-standard registers that store information about the visit, such as: the type of browser, the operating system, the URL of the page from which the visit has been redirected, the actions taken and the IP address of the visited pages, and other similar information.

Felfil uses all the data collected to provide pertinent information about Users’ location, to enhance the experience of visiting the Website and to verify if the Website is working correctly.

Felfil collects data from all the Users who visit the Website also to enhance the purchasing experience, such as:

  • Products the User has viewed: Felfil will use this to, for example, show you products the User has recently viewed;
  • Location, IP address and browser type: Felfil will use this for purposes like estimating taxes and shipping;
  • Shipping address: Felfil will ask you to enter this to, for instance, estimate shipping before the User places an order.

Felfil also collects cookies data. To verify the complete list of the used cookies and how to use it, please see our Cookies Policy.



The Website may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.



To purchase our products from the Felfil Store, Users must create an account on the Website (” Felfil Website Account”). When Creating a Felfil Website Account, some personal data are required, including email address.


When purchasing in the Felfil Store, Felfil will ask you to provide information including the User’s full name, billing address, shipping address, email address, phone number and account information like username and password.

Felfil will use this information for purposes, such as, to:

  • Send information about the User’s account and order
  • Respond to the User requests, including refunds and complaints
  • Process payments and prevent fraud
  • Set up the User’s Felfil Website Account
  • Comply with any legal obligations Felfil has, such as calculating taxes
  • Improve the Felfil Store offerings
  • Send to the User marketing messages, if the User chooses to receive them

If Users are logged in their Felfil Website Account while purchasing a Product in the Felfil Store,  the purchase order is associated to the User’ Felfil Website Account. We store the shipping address information in order enhance the order processing by our partners.

Felfil never view or share, nor stores in any way Users’ credit card information or other similar data. All payment information are managed by a service provided by third parties (Stripe). For more details, please refer to


When Felfil receive a request for assistance, the data shown in the request (i.e.: name, email address and any additional data) are stored on our servers and processed through a third-party service (SupportBee) in order to provide the requested assistance and improve the service. For more details, please refer to:

Our assistance service could be contacted through the social network, (i.e Twitter or Facebook); However, Felfil is not responsible and does not guarantee in any way the confidentiality of the information shared by these channels.




Felfil process all personal data collected by using electronic or automated systems, assuring security and confidentiality of all data collected, in accordance with the provisions of the Privacy Code.

Felfil may use the Users’ personal data for the following purposes:

1 Use by Felfil. Felfil may use Users’ personal data: (a) for statistical or marketing purposes, including measurement and understanding of the common trends to the customers (b) for operational purposes, including location of Users’ devices or other activities for the purpose of improving and protecting our services; (C) to alert Users about any changes to the Privacy Policy, and (d) for any other purpose described in this Privacy Policy or required by regulations or lawsuits.

2 Customer Support. When Users interact with our customer service by e-mail, phone or in person, Felfil may collect: personal information pertinent to the situation, including: name, mailing address, telephone number and contact preferences; information about purchased Felfil products, including: serial numbers, purchase date and (if applicable) event logs useful for diagnosing performance problems for products or applications; information relating to a support or a service issue. Felfil will use this information to provide customer service and product support.

3 Purchasing. If Users are logged in their Felfil Website Account while purchasing a Product in the Felfil Store, the purchase order is associated to the User’ Felfil Website Account. We store the shipping address information in order enhance the order processing by our partners. If you are not logged into your account at the time of purchase, we do not associate that data with your Fitbit account, however we save the data so that we can provide customer service related to the purchase.

4 Promotions. If the User adheres to prize events or promotions activated by Felfil, all information provided will be used for processing purposes. In case of conflicts, related to the processing of personal information, terms and conditions of these prize events or promotions will prevail on the provisions of this Privacy Policy.




Felfil does not sell data to third parties that allow the Users’ identification; however Felfil may share such data with its partners, in de-identified and aggregated form, or for the sole purpose of providing its Services


Personal identifiable information are data that includes the name or another User ID that can be traced back to the name, postal address or email or other information that personally identifies a User. Felfil will share this data only under the following circumstances:

With companies engaged in providing services to Felfil like: process orders, emails or credit card management. These companies are obliged by contract to protect all personal data received from Felfil.

When disclosure is reasonably necessary to comply with a law, regulation, or legal proceedings. In this case, Felfil will do its best to provide Users with notice in advance by email, unless Felfil is prohibited by a court order from doing so or where the request or legal process is directly related to a regulatory investigation. In the latter case, Felfil will ensure User that any information disclosed is treated as confidential.

If Felfil believes that disclosure is necessary in order to prevent serious and imminent damage to persons or property, or to prevent fraud, or to protect the safety of Felfil and User data services.

If it is necessary in connection with the sale, merger, bankruptcy, sale of assets or reorganization of our company, your PII can be sold or transferred as part of that transaction as permitted by law. The promises in this Privacy Policy will apply to your data as transferred to the new entity.


Felfil may sell or share aggregate data, not identifying, that does not identify the identity of the Users, co

No partner or the general public. In providing this information, Felfil will take all legal and technical measures to ensure that the data do not allow to trace the identity of utenti.


Users can agree to share their data with third parties. Felfil is not responsible for the data processing carried out by third parties. Once provided consent to the sharing of data with third parties, the processing of such data falls within the Privacy Policy of such third parties. You should carefully review the privacy policy of any third party and you can revoke your consent to sharing with third parties at any time.



Members of the Felfil team have access to the information you provide us. For example, both Administrators and Shop Managers can access:

  • Order information like what was purchased, when it was purchased and where it should be sent, and
  • Customer information like the User’s full name, email address, and billing and shipping information.

The Sherlock team members have access to this information to help fulfill orders, process refunds and support you.


Felfil store the Users’ personal data of only for the time necessary to provide its services unless a longer period of storage is required by law. For example, Felfil will store order information for 5 years for tax and accounting purposes. This includes your full name, email address and billing and shipping addresses.

After this period, Users’ personal data will be processed anonymously.

If you leave a comment on the Felfil Website, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on the Felfil Website, we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.


The data provided to Felfil through the Website o may be edited in the User preferences. By removing User data from the Account, they will not be visible to the User anymore, who will no longer able to use the Felfil Services. The backups of the User data will remain stored by Felfil, on its servers.


Users can deactivate the Felfil Account by contacting our customer service. In this case, the personal identification data will be removed from the Service, including, among others, email address, and any customizations. Backup copies of this data will be removed from Felfil server based upon an automated schedule, which means it may persist in our archive for a short period of time. Felfil may continue to use Users’ aggregated and de-identified data.


Users can opt-out of receiving Felfil emails by changing the notification preferences in your account settings or unsubscribing via the “Unsubscribe” link present in all emails sent by Felfil. The Opting-out of these emails will not end transmission of important service-related emails that are necessary to your account maintenance or to use the Felfil Services.


At any time Users may exercise their rights under sect. 7 of the Italian Privacy Code – which for convenience is reproduced in full below – in order to obtain confirmation of the existence or not of their personal data, to know their content and origin, verify its accuracy or request its integration updating, or correction. Under the same provision the User may also request cancellation, transformation into anonymous form or blocking of data processed in violation of the law, and oppose any case, for legitimate reasons, their treatment. Requests should be addressed Felfil, in acting as the controller, at the addresses indicated in this statement ut supra.

Section 7

(Right to Access Personal Data and Other Rights)

A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form.

A data subject shall have the right to be informed

a) of the source of the personal data;

b) of the purposes and methods of the processing;

c) of the logic applied to the processing, if the latter is carried out with the help of electronic means;

d) of the identification data concerning data controller, data processors and the representative designated as per Section 5(2); and

e) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing.

A data subject shall have the following rights:

a) to obtain updating, rectification or, where interested therein, integration of the data;

b) to obtain erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;

c) to obtain certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.

A data subject shall have the right to object, in whole or in part,

a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;

b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.



Our services are not intended for persons under 13 years. In compliance with the Italian laws and the UN Convention on the Rights (Convention on the Rights of the Child – CRC) of 11.20.1989, If we learn that we have collected the Personal Information from a child under 13, we will take steps to delete the information as soon as possible. Users who eventually are aware of a User under the age of 13 using a Felfil Website or App are invited to contact us at