Privacy policy
1. Introduction and Who We Are
Carlena Gallery is a trade name of Carlena LLC, a company registered in Richmond, Virginia, United States. We specialize in the acquisition, sale, rental, and expertise of mid-century modern Italian design furniture from the 1950s through 1970s.
Our business model involves sourcing furniture collections from private Italian owners, storing items in secure facilities in Italy, and importing specific pieces to the United States and other destinations on a just-in-time basis when sales are finalized. We serve interior design studios, collectors, and discerning clients primarily in the United States (approximately 75-80% of our customers), with the remainder located internationally.
We are committed to protecting your personal data and handling it responsibly. This Privacy Statement explains how we collect, use, share, and protect your information, and describes your rights regarding your personal data.
Our data is processed and stored on servers located in Italy (European Union). As a U.S. company with international operations, we comply with applicable privacy laws including the General Data Protection Regulation (GDPR) for our European customers, the Virginia Consumer Data Protection Act (VCDPA), the California Consumer Privacy Act (CCPA), and other applicable regulations.
2. Information We Collect
We collect personal information necessary to provide our services, process transactions, and communicate with you. The categories of information we may collect include:
2.1 Identity and Contact Information
• First and last name
• Shipping and billing address, postal code, city, country
• Email address
• Telephone number
• Professional title or company affiliation (for trade clients)
2.2 Transaction and Financial Information
• Payment details (processed securely through third-party payment processors)
• Billing information and invoice records
• VAT number (for business customers)
• Purchase history and transaction records
2.3 Import and Customs Documentation
• Identification documents required for customs clearance
• Import/export documentation
• Delivery authorization forms
2.4 Service-Related Information
• Stylistic preferences and collection interests
• Rental agreement details and insurance information
• Expertise and authentication requests
• Restoration and consultation records
• Communications and correspondence with our team
2.5 Technical and Usage Information
• IP address
• Browser type and device information
• Website activity and browsing patterns on our site
• Marketing and communication preferences
2.6 Sensitive Personal Data
We do not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health information, or biometric data.
3. How We Use Your Information
We use your personal information for the following purposes:
3.1 Providing Our Services
• Processing purchases, rentals, and other transactions
• Managing the import process and customs documentation
• Coordinating shipping and delivery logistics
• Providing authentication, expertise, and restoration services
• Managing rental agreements and associated insurance
• Handling claims and damage assessments
• Creating and managing your account
3.2 Communications
• Responding to inquiries and providing customer support
• Sending transaction confirmations and updates
• Notifying you of changes to our services
• Sending newsletters and marketing communications (with your consent)
• Conducting customer satisfaction surveys
3.3 Business Operations
• Processing payments
• Internal reporting and statistical analysis
• Improving our products, services, and website
• Complying with tax, customs, and other legal obligations
4. Legal Bases for Processing (For EU Customers)
For customers in the European Union, we process your personal data based on the following legal grounds under the GDPR:
• Contract Performance: Processing necessary to fulfill our contractual obligations, including completing sales, managing rentals, coordinating imports, and providing requested services.
• Legal Obligation: Processing required to comply with applicable laws, including tax regulations, customs requirements, and export/import controls.
• Legitimate Interests: Processing necessary for our legitimate business interests, such as improving our services, fraud prevention, and direct marketing to existing customers, where these interests are not overridden by your rights.
• Consent: Where we rely on your consent, such as for marketing communications to prospective customers, you may withdraw consent at any time.
5. Sharing Your Information
We share your personal information with third parties only as necessary to provide our services, comply with legal obligations, or with your consent. Categories of recipients include:
5.1 Service Providers
• Freight forwarders and shipping companies (in Italy and the United States)
• Customs brokers
• Warehouse and storage facilities (in Italy)
• Payment processors
• Website hosting and cloud service providers
• Insurance providers and intermediaries
5.2 Professional Advisors
• Authentication and appraisal experts
• Restoration specialists
• Legal counsel
• Accountants and tax advisors
• Damage assessors and claims investigators
5.3 Government Authorities
• Tax authorities (IRS, Italian tax authorities, and others as applicable)
• Customs agencies (U.S. Customs and Border Protection, Italian Customs)
• Other regulatory bodies as required by law
5.4 Business Transfers
In the event of a merger, acquisition, or sale of all or part of our business, your personal information may be transferred to the successor organization. We will notify you of any such change and ensure continued protection of your data.
5.5 Sale of Personal Information
Carlena Gallery does not sell your personal information as defined by applicable privacy laws, including the CCPA and VCDPA.
6. International Data Transfers
Due to the international nature of our business, your personal data may be transferred between different jurisdictions:
• Our servers are located in Italy (European Union), providing strong data protection under EU law.
• Our company headquarters are in Virginia, United States, where business operations are conducted.
• Our supply chain partners operate in Italy (storage, initial shipping) and the United States (customs clearance, final delivery).
For transfers of personal data from the European Union to the United States, we implement appropriate safeguards including Standard Contractual Clauses (SCCs) approved by the European Commission. We may also rely on the EU-U.S. Data Privacy Framework where applicable.
If you are located outside the United States, please be aware that your information will be transferred to and processed in both Italy and the United States. By using our services, you acknowledge this transfer.
7. Data Retention
We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including satisfying legal, accounting, or reporting requirements. Our general retention periods are:
• Transaction and financial records: 7 years from the end of the fiscal year in which the transaction occurred, to comply with tax and accounting requirements.
• Customs and import documentation: 5 years from the date of import, as required by U.S. Customs and Border Protection.
• Marketing and communication preferences: Until you withdraw consent or request deletion.
• General customer records: Up to 7 years from the last interaction, unless a longer period is required by law or legitimate business need.
After the applicable retention period expires, we will securely delete or anonymize your personal data.
8. Your Privacy Rights
8.1 Rights for All Customers
Regardless of your location, you have the following rights:
• Access: Request information about the personal data we hold about you.
• Correction: Request correction of inaccurate or incomplete data.
• Deletion: Request deletion of your personal data, subject to legal retention requirements.
• Marketing opt-out: Opt out of marketing communications at any time.
8.2 Additional Rights for European Customers (GDPR)
If you are located in the European Economic Area, United Kingdom, or Switzerland, you also have the right to:
• Data portability: Receive your data in a structured, commonly used, machine-readable format.
• Restriction of processing: Request limitation of processing in certain circumstances.
• Object to processing: Object to processing based on legitimate interests or for direct marketing.
• Withdraw consent: Withdraw previously given consent at any time.
• Lodge a complaint: File a complaint with your local data protection authority.
8.3 Rights for Virginia Residents (VCDPA)
If you are a Virginia resident, you have the right to:
• Confirm whether we are processing your personal data and access such data.
• Correct inaccuracies in your personal data.
• Delete personal data you have provided or that we have obtained.
• Obtain a copy of your personal data in a portable format.
• Opt out of targeted advertising, sale of personal data (we do not sell data), and profiling.
• Appeal: If we decline your request, you have the right to appeal our decision. To appeal, contact us at the address below within 45 days of receiving our response. We will respond to your appeal within 60 days.
8.4 Rights for California Residents (CCPA)
If you are a California resident, you have the right to:
• Know what personal information we collect, use, disclose, and sell.
• Request deletion of your personal information.
• Opt out of the sale of personal information (we do not sell personal information).
• Non-discrimination for exercising your privacy rights.
To submit a request, please contact us using the information provided in Section 13. We will verify your identity before processing your request and respond within the timeframes required by applicable law.
9. Cookies and Tracking Technologies
Our website uses cookies and similar technologies to enhance your browsing experience and analyze site usage.
9.1 Types of Cookies We Use
• Essential cookies: Required for the website to function properly, including security and accessibility features.
• Functional cookies: Remember your preferences and settings to enhance your experience.
• Analytics cookies: Help us understand how visitors interact with our website so we can improve it.
• Marketing cookies: Used to deliver relevant advertisements and track campaign effectiveness (with your consent).
9.2 Managing Cookies
You can manage your cookie preferences through our cookie banner when you first visit our website. You may also configure your browser to refuse cookies or alert you when cookies are being sent. Please note that disabling certain cookies may affect website functionality.
For visitors from the European Union, we will obtain your consent before placing non-essential cookies on your device.
10. Marketing Communications
We may send you information about new acquisitions, upcoming collections, events, and services that may interest you. We will only send marketing emails with your prior consent or, for existing customers, based on our legitimate interest in maintaining our business relationship.
Every marketing email includes an unsubscribe link. You may opt out of marketing communications at any time by clicking the unsubscribe link or contacting us directly.
In compliance with the U.S. CAN-SPAM Act, all our marketing emails include our physical mailing address and a clear method to opt out.
11. Data Security
We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:
• Encryption of data in transit (HTTPS/TLS) and at rest
• Access controls limiting data access to authorized personnel only
• Regular security assessments and updates
• Secure backup procedures
While we strive to protect your personal information, no method of transmission over the internet or electronic storage is completely secure. If you have reason to believe that your interaction with us is no longer secure, please contact us immediately.
12. Children's Privacy
Our services are not directed to individuals under 16 years of age. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child under 16, we will take steps to delete such information promptly.
13. Contact Us
If you have questions about this Privacy Statement, wish to exercise your privacy rights, or have concerns about how we handle your personal data, please contact us:
Carlena LLC (d/b/a Carlena Gallery)
General Inquiries: info@carlenagallery.com
For Virginia Residents – Appeals: If we decline your privacy request, you may appeal by emailing info@carlenagallery.com with the subject line "Privacy Appeal" within 45 days of our response.
For EU Residents – Supervisory Authority: You have the right to lodge a complaint with your local data protection authority. For a list of EU data protection authorities, visit:
https://edpb.europa.eu/about-edpb/about-edpb/members_en
14. Changes to This Privacy Statement
We may update this Privacy Statement from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will notify you by posting the updated statement on our website with a new effective date. We encourage you to review this statement periodically.
For significant changes that affect how we process your personal data, we will provide additional notice, such as an email notification to registered customers.
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Ultimo aggiornamento: 02.12.2025