Privacy policy

PRIVACY POLICY

Last updated: 1 March 2026

ARTICLE 1 — INTRODUCTION AND SCOPE

This Privacy Policy (hereinafter referred to as "the Policy") is established by H and R Agency FZ-LLC, a Free Zone Limited Liability Company incorporated and registered with the Ras Al Khaimah Economic Zone Authority (RAKEZ), under licence number 17005362 and registration number 0000004065895, with its registered office at Compass Building, Al Hulaila, AL Hulaila Industrial Zone-FZ, Ras Al Khaimah, United Arab Emirates (hereinafter referred to as "the Company", "we" or "H and R Agency").

This Policy sets out in a transparent, comprehensive, and binding manner the conditions under which H and R Agency FZ-LLC collects, processes, retains, protects, and where applicable transfers the personal data of its users, customers, visitors, and business partners (hereinafter collectively referred to as "Data Subjects"), in connection with the operation of the e-commerce platform accessible at https://www.marcomoretti.shop (hereinafter "the Site"), dedicated to the retail sale of premium sunglasses and fashion accessories.

H and R Agency FZ-LLC is fully committed to processing personal data entrusted to it with the highest degree of security, confidentiality, and rigour, in strict compliance with applicable data protection legislation, and in particular:

  • 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 (hereinafter "GDPR"), directly applicable within the European Union;
  • French Act No. 78-17 of 6 January 1978 on Information Technology, Data Files and Civil Liberties, as amended, in its version applicable in France;
  • Any other legislative or regulatory provision applicable in the territories of residence of the Data Subjects.

ARTICLE 2 — IDENTITY AND CONTACT DETAILS OF THE DATA CONTROLLER

In accordance with Article 13 of the GDPR, the details of the data controller are as follows:

  • Company name: H and R Agency FZ-LLC
  • Type: Free Zone Limited Liability Company (FZ-LLC)
  • Supervisory authority: Ras Al Khaimah Economic Zone Authority (RAKEZ)
  • Licence number: 17005362
  • Registration number: 0000004065895
  • Registered office: Compass Building, Al Hulaila, AL Hulaila Industrial Zone-FZ, Ras Al Khaimah, United Arab Emirates
  • Email address: contact@marcomoretti.shop
  • Website: https://www.marcomoretti.shop

For any questions, requests, or complaints regarding the processing of your personal data, you may contact the data controller at: contact@marcomoretti.shop. The service is available 7 days a week, 24 hours a day.

ARTICLE 3 — DATA COLLECTED AND PURPOSES OF PROCESSING

3.1 — Categories of personal data collected

In the course of its activities, H and R Agency FZ-LLC collects and processes the following categories of personal data:

Identification and contact data: first name, surname, full postal address, email address. This data is collected for the purposes of processing and fulfilling orders, shipping products, issuing invoices, and communicating with the Customer.

Transactional data: purchase history on the Site, transaction amounts, payment methods used (without retaining raw banking data), billing information. This data is processed for the purposes of securing transactions, combating fraud, and managing accounting and tax obligations.

Browsing and usage data: IP address, cookie data and similar technologies, session duration and pages visited, interactions with the Site, operating system and browser used. This data is collected for the purposes of behavioural analysis, continuous improvement of the user experience, and technical optimisation of the Site.

Marketing and communication data: communication preferences, history of interactions with electronic communications, customer segments. This data is processed for the purposes of sending targeted commercial communications and optimising advertising campaigns, subject to the prior consent of the Data Subject.

3.2 — Data collection tools and technologies used

H and R Agency FZ-LLC uses the following third-party tools and technologies in connection with data collection and processing:

  • Shopify: Site hosting and management platform, with its registered office at 151 O'Connor Street, Ground Floor, Ottawa, Ontario, Canada K2P 2L8;
  • Google Analytics: audience analysis and Site performance measurement tool, published by Google LLC;
  • Meta Pixel (Facebook/Instagram): advertising conversion tracking tool, published by Meta Platforms Inc.;
  • Apple Pay and Shop Pay: digital payment solutions;
  • PayPal: online payment platform, published by PayPal Holdings Inc.

3.3 — Data not collected

H and R Agency FZ-LLC formally undertakes never to collect or process "sensitive" data within the meaning of Article 9 of the GDPR, such as data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life, or sexual orientation. No raw banking data (card number, expiry date, security code) is stored directly by the Company.

ARTICLE 4 — LEGAL BASES FOR PROCESSING

In accordance with Articles 6 and 7 of the GDPR, each processing activity carried out by H and R Agency FZ-LLC is based on one of the following legal grounds:

  • Performance of a contract: the processing of identification, transactional, and shipping data is necessary for the performance of the sales contract concluded between H and R Agency FZ-LLC and the Customer when placing an order on the Site;
  • Explicit consent of the Data Subject: the processing of data for commercial communications, newsletters, and advertising targeting is based on the free, specific, informed, and unambiguous consent of the Data Subject, obtained prior to any processing;
  • Legitimate interest of the Company: the processing of browsing data for statistical analysis, user experience improvement, and Site security is based on the legitimate interest of H and R Agency FZ-LLC, provided it is not overridden by the interests or fundamental rights of the Data Subject;
  • Compliance with legal obligations: the retention of certain data for accounting, tax, or regulatory purposes is based on the legal obligations to which the Company is subject.

The Data Subject has the right to withdraw their consent at any time for processing activities that rely on it, without this withdrawal affecting the lawfulness of processing carried out prior to the withdrawal. Consent may be withdrawn by sending a request to: contact@marcomoretti.shop.

ARTICLE 5 — RIGHTS OF DATA SUBJECTS

5.1 — Summary of recognised rights

In accordance with the GDPR and applicable national legislation, any Data Subject whose data is processed by H and R Agency FZ-LLC has the following rights:

  • Right of access (Article 15 GDPR): the right to obtain confirmation as to whether or not personal data concerning you is being processed, as well as access to that data and information about the conditions of processing;
  • Right to rectification (Article 16 GDPR): the right to obtain, without undue delay, the rectification of inaccurate personal data concerning you, as well as the right to have incomplete data completed;
  • Right to erasure (Article 17 GDPR): the right to obtain the erasure of your data in the cases provided for by law, in particular where the data is no longer necessary for the purposes for which it was collected;
  • Right to restriction of processing (Article 18 GDPR): the right to obtain restriction of processing of your data in certain circumstances defined by the GDPR;
  • Right to data portability (Article 20 GDPR): the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller;
  • Right to object (Article 21 GDPR): the right to object at any time, on grounds relating to your particular situation, to the processing of your data based on the legitimate interests of the Company, as well as the unconditional right to object to processing for direct marketing purposes;
  • Right not to be subject to automated decision-making (Article 22 GDPR): the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

5.2 — How to exercise your rights

Any request to exercise one of the above rights must be sent by email to: contact@marcomoretti.shop

The request must be clearly and precisely formulated, identify the right(s) being exercised, and be accompanied by a copy of a valid identity document enabling verification of the requester's identity.

H and R Agency FZ-LLC commits to responding to any request within a maximum of one (1) month from receipt of the complete request. This period may be extended by a further two (2) months in the case of complex or multiple requests, provided the Data Subject is informed within the initial one-month period.

In the event of an unsatisfactory response or failure to respond within the prescribed timeframe, Data Subjects residing in France have the right to lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL), located at 3 Place de Fontenoy – TSA 80715 – 75334 Paris Cedex 07, or online at: https://www.cnil.fr.

ARTICLE 6 — DATA RETENTION PERIODS

H and R Agency FZ-LLC commits to retaining personal data only for as long as is strictly necessary for the purposes for which it was collected, in accordance with applicable legal provisions:

  • Order and transaction data: retained for a maximum period of five (5) years from the last commercial or contractual interaction, in accordance with applicable civil and commercial limitation periods;
  • Accounting and tax data: archived for a period of ten (10) years from the close of the relevant accounting year, in accordance with applicable accounting and tax obligations;
  • Marketing and commercial communication data: retained until voluntary unsubscription by the Data Subject or until a period of eighteen (18) consecutive months of inactivity is recorded;
  • Browsing data and cookies: retained for a maximum period of thirteen (13) months from collection, in accordance with CNIL recommendations.

Upon expiry of these retention periods, data is permanently deleted or irreversibly anonymised.

ARTICLE 7 — DATA SECURITY AND INTEGRITY

H and R Agency FZ-LLC implements all appropriate technical and organisational measures, within the meaning of Article 32 of the GDPR, in order to ensure a level of security appropriate to the risk presented by the processing activities carried out, and in particular to ensure the confidentiality, integrity, availability, and resilience of the data processed.

These measures include in particular:

  • Encryption of payment data via PCI-DSS certified providers (Visa, Mastercard, American Express, CB, Apple Pay, PayPal, Shop Pay);
  • Restriction of access to personal data to persons duly authorised within the scope of their functions and subject to a confidentiality obligation;
  • Implementation of regular backup protocols and secure hosting via the Shopify platform;
  • Periodic internal audits of processing activities and third-party sub-processors;
  • Use of the HTTPS protocol for all data exchanges on the Site.

It is expressly noted that no raw banking data (card number, expiry date, security code) is collected or retained directly by H and R Agency FZ-LLC, as all transactions are secured by the certified payment providers mentioned above.

In the event of a personal data breach likely to result in a high risk to the rights and freedoms of Data Subjects, H and R Agency FZ-LLC commits to notifying the affected individuals without undue delay, in accordance with Articles 33 and 34 of the GDPR.

ARTICLE 8 — SHARING AND DISCLOSURE OF DATA TO THIRD PARTIES

The personal data of Data Subjects is never sold, rented, or exchanged for consideration to third parties. It may however be shared with the sub-processors and partners strictly necessary for the provision of the services offered by H and R Agency FZ-LLC, including:

  • Carriers and logistics providers: for the purposes of order fulfilment and delivery;
  • Payment service providers: Visa, Mastercard, American Express, CB, Apple Pay, PayPal, Shop Pay, for the purposes of securing and processing financial transactions;
  • Hosting platform: Shopify Inc., for the purposes of hosting and technically operating the Site;
  • Analytics and advertising tools: Google Analytics, Meta Pixel, for the purposes of analysing Site performance and optimising advertising campaigns.

Each sub-processor or partner is contractually required to maintain the confidentiality of the data entrusted to them and to comply with the requirements of the GDPR and any other applicable data protection regulation. H and R Agency FZ-LLC ensures that every sub-processor provides sufficient guarantees with regard to the implementation of appropriate technical and organisational measures.

ARTICLE 9 — INTERNATIONAL DATA TRANSFERS

Given the international nature of the tools and providers used by H and R Agency FZ-LLC (including Shopify, Google, Meta, and PayPal), certain personal data may be transferred to third countries located outside the European Union or the European Economic Area.

In such cases, H and R Agency FZ-LLC ensures that these transfers are governed by appropriate safeguards in accordance with Articles 44 to 49 of the GDPR, including:

  • Standard contractual clauses approved by the European Commission;
  • Adequacy decisions issued by the European Commission regarding the destination country;
  • Any other mechanism recognised and validated by the competent data protection supervisory authorities.

ARTICLE 10 — COOKIES AND SIMILAR TECHNOLOGIES

When you browse the Site, H and R Agency FZ-LLC and its partners may place cookies or use similar technologies on your device (computer, tablet, smartphone) in order to:

  • Ensure the proper technical functioning of the Site and remember your browsing preferences (strictly necessary cookies);
  • Measure audience, analyse Site performance, and improve the user experience (analytical cookies);
  • Personalise advertising content and track conversions from our marketing campaigns (advertising cookies).

Only strictly necessary cookies may be placed without your prior consent. The placement of all other cookies is subject to your free, specific, informed, and revocable consent, collected via our cookie preference management module accessible on the Site.

You have the right at any time to accept, refuse, or withdraw your consent to all or part of the cookies, either via the preference management module available on the Site or via your browser's privacy settings. Refusing certain cookies may affect the proper functioning of certain Site features.

ARTICLE 11 — AMENDMENTS TO THIS PRIVACY POLICY

This Privacy Policy may be modified, supplemented, or updated at any time, in particular to reflect legislative, regulatory, or case law developments, or to take into account changes in the data processing practices of H and R Agency FZ-LLC.

Any material amendment to this Policy will be brought to the attention of Data Subjects by email or via a visible notification on the Site, within a reasonable period prior to its entry into force.

The version in force is the one published on the Site at the time of consultation. The updated version is permanently accessible at: https://www.marcomoretti.shop

ARTICLE 12 — APPLICABLE LAW AND JURISDICTION

This Privacy Policy is governed by the provisions of the GDPR for all Data Subjects residing within the European Union, as well as by the mandatory provisions of the national law of the Data Subject to the extent that such provisions afford greater protection.

In the event of a dispute relating to the interpretation or application of this Policy, the Data Subject is invited to contact H and R Agency FZ-LLC in the first instance at contact@marcomoretti.shop (available 7 days a week, 24 hours a day) in order to seek an amicable resolution. If this fails, the Data Subject has the right to lodge a complaint with the competent supervisory authority in their country of residence (in France: the CNIL).

LEGAL INFORMATION

  • Company: H and R Agency FZ-LLC
  • Type: Free Zone Limited Liability Company (FZ-LLC)
  • Supervisory authority: Ras Al Khaimah Economic Zone Authority (RAKEZ)
  • Licence number: 17005362
  • Registration number: 0000004065895
  • Registered office: Compass Building, Al Hulaila, AL Hulaila Industrial Zone-FZ, Ras Al Khaimah, United Arab Emirates
  • Email: contact@marcomoretti.shop
  • Website: https://www.marcomoretti.shop
  • Hosting provider: Shopify Inc., 151 O'Connor Street, Ground floor, Ottawa, Ontario, Canada K2P 2L8
  • Customer service: Available 7 days a week, 24 hours a day — contact by email only