PRIVACY NOTICE ON PROCESSING OF PERSONAL DATA
We wish to inform you that your personal data will be processed by TOD’S S.p.A. (the “Company”) in compliance with the provisions of Legislative Decree No. 196/2003 as subsequently amended (hereinafter, the “Italian Privacy Code”) and EU Regulation No. 679/2016 (the “Regulation”); therefore, pursuant to Article 13 of the Italian Privacy Code and Article 13 of the Regulation, we hereby provide you with the following information:
The Data Controller is TOD’S S.p.A., with registered office at 1, Via Filippo della Valle, Sant’Elpidio a Mare (FM), Italy. The Data Processor is the Company’s Data Protection Officer pursuant to Article 37 of the Regulation, who you may contact by writing to
<a href="mailto:dataprivacyofficer@todsgroup.com">dataprivacyofficer@todsgroup.com</a>, and to whom you may refer to exercise the rights set forth in clause 7 below and to submit any requests regarding the processing of your personal data by the Company.
1. The data you provide will be used exclusively to perform the service or assistance you requested; such data may also be processed for administrative and accounting purposes related to the requests you made to our Company.
The data you provide (only where you provided your prior, free and express consent and based on such consent) may be processed by the Company for the following purposes:
(i) to offer promotions, discounts, benefits and other services and to send out commercial or promotional information and giveaways as well as invitations to events and shows, to carry out market research and to announce any special initiative tailored to clients of the TOD’S Group or third-party products; (optional)
(ii) to carry out customer profiling activities by identifying the type and frequency of purchases made by you online and communicated to TOD’S to provide you with a better service on future purchases at one of the Group’s stores and for the purposes set out above. (optional)
2. The processing of your data will be carried out by using telematic, paper-based and IT tools. The processing of your data, including for profiling purposes, may also take place through automated processes, for instance, by means of assessment and comparative analysis of your purchase choices (types, quantities) during a specific period and/or season and by analyzing the type and number of your requests for information about products made during a predetermined timeframe.
3. Your data will not be disseminated. The data you provide will be made accessible to Company’s employees and co/workers authorised as person in charge for the processing, TOD’S Group companies as external data processors, and service providers the Company collaborates with only if it is strictly necessary to perform any service or performance you may request. They will also be made accessible to third parties engaged with the maintenance/development of our computer system for the period strictly necessary for carrying out such service. The data you provide for marketing and customer profiling purposes will be made accessible to TOD’S S.p.A.’s employees and coworkers – solely and exclusively for the purposes listed therein and to ensure that the said data are accurate at all times and updated whenever you liaise with TOD’S Group in the future. Your data will also be made available to third parties employed by TOD’S Group for the organization and management of its commercial activities, (e.g. service providers such as couriers, freight forwarders and data entry firms, etc.), TOD’S Group companies, operators and franchisees of TOD’S Group stores, based both in Italy or abroad, acting as data processors or as person in charge, as the case may be.
4. Save where storage for a longer period is required to comply with the applicable regulations, including accounting rules, the Company will store your data for the period strictly necessary to achieve the purposes for which they were collected. The data processed by TOD’S S.p.A. for customer profiling and/or marketing purposes (obviously, provided that your express consent has been acquired) will be stored until withdrawal of your consent to the processing of personal data and in any case, as for the data processed for the purposes set out in clause 2(b), for a maximum period of seven years after your last purchase, in compliance with the measure issued by the Italian Data Protection Authority (Garante per la protezione dei dati personali) on 7 November 2013 upholding the preliminary ruling requested by the Company. Upon withdrawal of your consent or upon expiry of the storage period of the data collected for profiling purposes, whichever occurs earlier, such data will be automatically erased or rendered permanently anonymous. Our Company may ask you to renew your consent to the processing of your data or keep them only for anonymous statistical or historical purposes.
5. The provision of your data and consent to their processing is necessary for our Company to perform the service or assistance requested. The provision of your data for marketing and profiling purposes as described above is optional and withholding consent to the data processing will prevent our Company from processing your data for these purposes.
7. Pursuant to Article 7 of the Italian Privacy Code and Article 15 of the Regulation, you are entitled to be informed, any time, about which data are in possession of the Company and which use is made of such data. For further information about the rights you may exercise pursuant to the Regulation and the Italian Privacy Code and in general about processing of your personal data through this website, please refer to the general section “Privacy” available at the following link: https://www.hogan.com/us-en/legal-area/privacy-policy.html.
Having read the information above, I hereby declare to have understood the relevant content and:
I consent to the processing of data by the Company for the purposes of receiving advertising and informational material relating to products and services of the TOD’S Group (newsletters, promotions, discounts, benefits, marketing material, etc.), for the implementation of market surveys by the Company and participation in events and shows, either by e-mail, text messages, telephone and post.
I consent to the use of the data by the Company for the processing and use of my commercial profile, by assessment of the type and frequency of my purchases both online and/or at TOD’S Group stores, in order to be provided with a better service on the occasion of future purchases at a Group’s store. I also consent to receive Company’s advertising material, which I am interested in, by e-mail, text messages, telephone and post.
