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Privacy Policy for WebSite

Revised date: April 2020

The protection of your personal information (hereinafter “personal data”) is important to the TOD’S S.p.A. (“Tod’s Group”, “we” or “us”), and we are committed to safeguarding your privacy and personal data. The purpose of this Privacy Statement is to inform you about the types of personal data we collect, use and disclose, which you may provide to us or that we automatically collect when you navigate any of our websites (hereinafter, “Site”). We are proud to demonstrate our commitment to your privacy, by complying with the laws and regulations under applicable privacy laws in Canada. This Privacy Statement is designed to meet the standards prescribed by the Personal Information Protection and Electronic Documents Act and the regulations thereunder (“PIPEDA”) as well as applicable provincial privacy legislation. This Privacy Statement applies to any information that we collect or receive about you from any source.

1.   Personal Data

We will identify the purposes for which we will use and disclose your personal data at the time we collect such data from you and obtain your consent, in any case, prior to such use and disclosure. We generally use and disclose your personal data for the Purposes as defined below in this Privacy Statement.

We will always collect your personal data by fair and lawful means. We may collect your personal data from you directly and/or from third parties, where we have obtained your consent to do so or as otherwise required or permitted by law.

When you navigate the Site, your personal data will be collected either automatically or when you are asked to provide your personal data to access certain areas of the Site.

Data Collected Automatically from the Site

Web Surfing Data – We may collect standard internet log information about how and when you use the Site. In which case, personal data may be collected by computer systems and software procedures involved in the normal operation of the Site and transmitted as part of the communication protocols of the Internet.

This refers to information that, although not collected to identify you, by its very nature could lead to your identification if it were to be processed and combined with the data held by third parties. This type of data may include IP addresses or domain names of computers used for browsing and that connect to the Site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response given by the server (success, error, etc.) and other parameters relating to the operating system and IT environment.

This data will not be disseminated but used for the sole purpose of obtaining anonymous and aggregate data on the usage of the Site and to check its correct functioning and will be retained for as long as necessary to fulfil the purposes for which the data was collected and as permitted or required by applicable law. The data could, however, be used to ascertain liability in case of possible computer crimes against the Site. Except in the latter case, the data will not be retained longer than as permitted or required by applicable law.

We also ask that you read our Cookie Policy.

Geolocation Data – Data relating to your physical location that is acquired by the built-in search system of the Site to obtain appropriate search results, such as the location of the nearest boutique. This data is collected only if it is used and if you provide your consent.

Data You Voluntarily Provide

So you can avail of the various services offered by the Site, we will ask you, depending on the service in question, to provide us your personal data, such as your personal information, contact information (telephone numbers, email accounts, home or residence address, etc.), data relating to the payment method, information on purchases and transactions, and others. Providing us your data is entirely voluntary but in some cases failure to do so will prevent us from providing the relevant service.

Data relating to Minors

We would like to point out that the protection of children's safety and privacy is very important to the Tod's Group. Therefore, we do not intend to collect and voluntarily use the personal data of individuals below the age of sixteen (16), or below any other minimum legal age limits in force in your country of residence. Consequently, we ask that you refrain from providing us with any personal data if you are below 16 years of age or if you are not of legal age in your country of residence.

Geolocation Data – This is data relating to your physical location that is collected by the built-in search system of the Site to obtain appropriate search results, such as the location of the nearest boutique. This data is collected only if you use the geolocation services and you provide your consent.

Data You Voluntarily Provide

So, you can avail of the various services offered by the Site, we may ask you, depending on the service in question, to provide us your personal data. For clarity, “personal data” is any information that is identifiable with you, as an individual. This data may include, your name, contact information (telephone numbers, email accounts, home, billing or residence address, etc.), data relating to the payment method, information on purchases and transactions, etc. Providing us your data is entirely voluntary but in some cases failure to do so will prevent us from providing the relevant service.

The protection of children's safety and privacy is very important to the Tod's Group. Therefore, we do not intend to collect and voluntarily use the personal data of individuals below the age of nineteen (19), or below any other minimum legal age limits in force in your country of residence. Consequently, we ask that you refrain from providing us with any personal data if you are below 19 years of age or if you are not of legal age in your country of residence.


        2. Purpose and Use

We will generally use and disclose your personal data for the following purposes (collectively, the “Purposes”):

  • i. to administer the Site, to facilitate your access to and navigation of the Site;
  • ii. to provide you the requested services including, but not limited to, purchasing products from the Tod’s Group and using the services offered by the Site;
  • iii. to collect opinions and comments in regard to our operations;
  • iv. to investigate legal claims, in accordance with applicable law;
  • v. to reply to your questions, comments, concerns and other requests;
  • vi. to perform marketing activities, to the extent that you provide consent, both via automatic means (text messages, MMSs, messaging platforms, e-mails, push notifications) and not automatic means (mail, phone with operator);
  • If you opt in to receiving marketing communications, you may, at any time, email our Data Protection Officer (DPO), at the address provided herein, to request that we remove (out-out) your contact information from our contact list. If you opt in, we may:

      1. send marketing communications, including through newsletters, and in connection with promotions; discounts; incentives; and/or other commercial information;
      2. send these marketing communications via: mail; phone call; direct sales; email; automatic voice calls; messaging platforms; SMS and/or MMS.
      3. invite you to shows and events, ask you to participate in market research or to report on special initiatives dedicated to our customers, in the manner and period we believe to be most effective for any of the various initiatives mentioned.
  • vii. conduct customer profiling activities, to the extent that you provide consent
  • Customer profiling can be conducted by analyzing your interests and preferences regarding our products and services, as well as your shopping habits. For example, by understanding the type and frequency of your purchases on our online store when you shop using your personal account or as a "guest,” as well as in our boutiques, we are be able to guarantee a personalized service in your future visits to the Tod's Group boutiques.

    If you also opt in to receiving marketing communications, we may send you promotional information and/or invitations to initiatives that fit best your profile, preferences and expectations as a shopper, as more particularly described above.

  • viii. such other purposes for which we may obtain consent from time to time; and
  • ix. such other uses as may be permitted or required by applicable law.


        3. Disclosure and Dissemination of Personal Data

We identify to whom, and for what purposes, we disclose your personal data, at the time we collect such data from you and obtain your consent to such disclosure.

We may transfer and disclose your personal data, but only for the Purposes, to (a) third party service providers with whom we have a contractual agreement that includes appropriate privacy standards, where such third parties are assisting us with the purposes such as service providers that provide telephone support, data storage, processing, or hosting, as well as to public authorities that make it lawful and legally required; and (b) other companies within the Tod's Group, as well as to companies directly or indirectly controlled or owned by Tod's S.p.A., with headquarters in countries within and outside the European Union (EU).

For clarity, we may send personal data outside of the country for the Purposes, including for processing and storage by service providers in connection with the Purposes. However, you should note that to the extent that any personal data is out of the country, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts, or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.

We ensure that all affiliates and other third parties that are engaged to perform services on our behalf and are provided with personal data are contractually required to observe the intent of this Privacy Statement and our privacy practices.

For written information about our policies and practices regarding service providers and other companies within the Tod’s Group outside of Canada, contact our Data Protection Officer (DPO) at the email address provided herein: dataprivacyofficer@todsgroup.com.

In any event, your personal data will be processed only by parties, duly instructed and able to provide adequate technical and organizational safeguards, as well as contractually required to observe the intent of this Privacy Statement.

        4. Data Retention Period

We may keep a record of your personal data, correspondence or comments, in a file specific to you. We will process your personal data at different times depending on the purpose. In any event, we will retain your personal data only for the period strictly necessary to achieve the Purpose for which it was collected and processed, and as permitted or required by applicable law. Before requesting you to provide your personal information at any area of the Site, we will make available to you first a privacy consent statement so as to make you aware and give you adequate knowledge about how we will process your personal data, as well as information on how long we will store it, in order for you to provide your consent.

        5. Your Rights

You have the right to review your personal data that we have collected, stored, utilized or disclosed. If you make a written request to review such personal data, we will provide you with any such personal data to the extent required by law. We will make such personal data available to you in a form that is generally understandable and will explain any abbreviations or codes. We will ensure that your personal data is kept as accurate, complete and up-to-date as possible. We will not routinely update your personal data, unless such a process is necessary. We expect you, from time to time, to supply us with written updates to your personal data, when required. At any time, you may challenge the accuracy or completeness of your personal data in our records. If you successfully demonstrate that your personal data in our records is inaccurate or incomplete, we will amend the personal data as required. Where appropriate, we will transmit the amended information to a third party of your choosing.

When processing your request, we reserve the right to ask you in ways we deem appropriate for specific information to help us confirm your identity and be reasonably certain that only you can access your personal data and no unauthorized third party can obtain them. Any such identifying information shall only be used for this purpose.

We will not charge any costs for you to access your personal data in our records without first providing you with an estimate of the approximate costs, if any.

We will attempt to respond to each of your written requests not later than 30 days after receipt of such requests. We will advise you in writing if we cannot meet your requests within this time limit.

You may exercise these rights by sending a request to the Data Protection Officer (DPO) at dataprivacyofficer@todsgroup.com, or 1 Via Filippo Della Valle, Sant’Elpidio a Mare (FM), 63811 Italy (EU).

Furthermore, you may at any given time, withdraw (or give) your consent to our use and disclosure of your personal information for purposes of marketing and/or customer profiling through your personal account, if you have activated one, on our Site.

You can also contact the DPO to request further information or clarification, or to obtain specific information about who is authorized to access your personal data.

        6. Updates to this Policy

From time to time, we may make some changes to this Privacy Statement, for example, to fulfill new requirements set by the applicable legislation, meet technical requirements, or as a result of new services provided on the Site or by the Tod’s Group.

The updated Privacy Statement will be published on this website. [The Privacy Statement is current as of the “last revised” date which appears at the top of this page.]

We may also need to contact you, if legally required, to obtain your consent and allow you to continue to use the services of the Site.

We therefore ask that you to visit this page periodically.

Finally, we may also process your personal data to comply with any legal obligations that we may have and to pursue our legitimate interests or that of third parties, in compliance with the conditions and limits set by the current legislation.

4. Processing Procedures

We will process your personal data by means of telematic, paper and computer tools, and such processing will be based on the principles of fairness, lawfulness, and transparency to protect your rights and privacy. In particular, the processing of your data, also for purposes of customer profiling, may be automated, for example through a comparative analysis of your purchases (types, quantities, frequency, timing etc.), and through the analysis of the type and number of your requests for product information within a given timeframe.

We will process your personal data in a manner that will minimize the risk of destruction, loss, and unauthorized access to your data or any unauthorized or non-compliant processing.

5.   Disclosure and Dissemination of Personal Data

We will not disseminate your personal data.

We may disclose your personal data, but only for the purposes described above, to other companies within the Tod's Group, as well as to companies directly or indirectly controlled or owned by Tod's S.p.A., with headquarters in countries within and outside the European Union (EU).

Your data may also be accessible to companies, organizations or associations that perform technical and organizational tasks on our behalf, again consistent to attaining the purposes previously described, as well as to public authorities that make it lawful and legally required.

Any transfers of your personal data to entities outside the European Economic Area (EEA) will be made only if the level of protection of personal data, guaranteed by the Regulation, is not compromised.

Data Transfers to Third Countries

In the event that we have to transfer your personal data to entities outside the European Economic Area (EEA), such as to companies of the Tod's Group and/or to third parties that perform technical and organizational tasks on our behalf, again consistent with the purposes for which your data has been collected and processed, we will do so only if it is possible to guarantee the same level of data protection as that in the European Union (EU).

In fact, we can ensure that data transfers will take place only if it satisfies at least one of the following security measures, as required by the Regulation:

• inclusion of the country in the list of non-EU countries determined by the European Commission to have adequate data protection standards. For more information, please consult the European Commission’s web page on the Adequacy of the protection of personal data in non-EU countries

• existence of specific standard contractual clauses (EU Model Contract Clauses), approved by the European Commission, that ensures that the processing performed by our partners outside the EEA offers the same guarantees of protection of personal data as those within the EU. For more information, please consult the European Commission’s web page on the "Standard contracts for data transfers to third countries"

• for our partners based in the US, adherence to the EU-US Privacy Shield that guarantees the same level of personal data protection as that provided in the EU.

You may contact us for more information on the specific procedures we use to transfer personal data to countries outside the EEA.

You may also contact our Data Protection Officer (DPO) at the email address below to receive additional information on the guarantees protecting your personal data in the event it is transferred to countries outside the EEA.

At any event, your personal data will be processed only by parties, duly instructed and able to provide adequate technical and organizational safeguards, as well as bound to the strictest confidentiality by the Data Controller.

6.   Data Retention Period

We will process your personal data at different times depending on the purpose. At any event, we will retain your personal data only for the period strictly necessary to achieve the purpose for which it was collected and processed, except when specific provisions of the law require longer retention periods.

Data Retention Period

 

●       Data collected and processed for marketing purposes: 7 years from the date you gave consent.

●       Data collected and processed for customer profiling purposes: 7 years from the date you gave consent, automatically renewed each time you make a purchase at any one of the boutiques/points of sale under the Tod’s Group, including its online store.

●       Data collected and processed to access services on the Site: the retention and processing of your data will take place for the time strictly necessary to allow you access to the service requested. Your data will be stored no more than 7 years from the date you used the service in question.

●       Data collected and processed to fulfil your request: the retention and processing of your data will take place for the time strictly necessary to respond to your contact request and/or allow us to perform any task related to such request.

●       Data collected and processed to protect our legitimate interests or that of third parties: the retention and processing of your data will take place for the time strictly necessary to pursue these legitimate interests as they arise.

●       Data collected and processed in compliance with legal provisions: the retention and processing of your data will take place within the time frame set by the applicable law.

Before requesting you to provide your personal information at any area of the Site, we will provide you first with a Privacy Policy so as to make you aware and give you adequate knowledge about how we will process your personal data, as well as information on how long we will store it, should you provide your consent.

7.   Your Rights

You have the right to know which of your personal data we have stored and which ones are being processed, to request to update or correct it, as well as in cases provided for by the law, to delete it, and to restrict or object to the processing even after you have provided your explicit consent. You may also request your personal data to be delivered in electronic format to a third party of your choosing.

Rights of Data Subjects

You may at any time email the Data Protection Officer (DPO) at dataprivacyofficer@todsgroup.com to exercise the following rights provided for by the Regulation regarding the specific processing activities we conduct. Specifically, you have the right to:

a)    request access to your personal data, as well as receive information about the purposes of the processing, types of data processed, parties or types of parties your data will be disclosed to, the expected retention period, and application, if any, of customer profiling techniques and automated decision-making processes;

b)    request to correct your personal data, as well as update any information relating to you, though in some cases you will be asked to verify first the new data that you provided us.

c)    request to delete or remove your personal data when its processing is no longer necessary, when you wish to exercise your right to object to its processing and there are no other legal basis to retain said data, if we have violated any laws related to said processing, or if we are required to delete your personal data to comply with a specific regulatory provision. Please note that due to some legal constraints beyond our control, we may be prevented from satisfying your request at all or to its full extent. In those cases, you will be informed promptly of the reasons behind our complete or partial inability to comply with your request.

d)    request to object to the processing of your personal data or terminate in any way the processing according to your wishes. We would like to point out that should we accommodate such request, there may or may not be a lawful basis for doing so.

If you had given your explicit consent to the processing, we will comply with your request to terminate the processing within the time frame set by the Regulation.

Further, you may also withdraw your consent to processing for marketing and/or customer profiling purposes by emailing the DPO as indicated above, or even do so directly from your personal account (if activated) on the Site. Withdrawing your consent does not negate the legitimacy of the processing you had previously consented to.

We also would like to highlight that withdrawing your consent could prevent us from providing certain services or products in the Site and in the boutiques of the Tod’s Group. In those cases, we will alert you so you can fully evaluate the effects of withdrawing your consent.

Finally, if the processing is performed based on our legitimate interests or that of third parties, we reserve the right to evaluate the reasons for your request. If the purposes of processing legitimately override your interests, rights, and freedoms, or if it is necessary for us to process such data to file a claim, execute legal actions, or defend ourselves in court, we will have to reject your request and let you know of the reasons for such a decision.

e)    request to restrict or suppress the processing of your personal data in the following cases:

           i.        if you request us to verify the accuracy of your data;

         ii.        if the data has been unlawfully processed and you prefer to restrict the processing rather than delete your data;

        iii.        if you want us to retain your data even if we no longer have to so you may establish, exercise, or defend a legal claim;

        iv.        if you object to the processing but we have to retain your data to ascertain if our legitimate interests override yours.

f)     request to receive your personal data or provide them to a third party of your choosing in a structured, commonly used, machine-readable format. This will be carried out only if it is technically possible to do so, if your personal data was processed by automated means, and if the processing was based on your consent or the performance of a contract.

When processing your request, we reserve the right to ask you in ways we deem appropriate for specific information to help us confirm your identity and be reasonably certain that only you can access your personal data and no unauthorized third party can obtain them.

We are committed to accommodating and following up on your request to exercise one or more rights, where possible, within a month of receiving it. Occasionally, but always in compliance with the terms set by the law, we might take longer to process the request if it is particularly complex or if you have submitted several other requests. In those cases, we will let you know and keep you posted.

The processing of your request is free of charge.

However, if your requests are manifestly unfounded, excessive, or repetitive in nature, we reserve the right to:

a)      ask you to pay a reasonable fee based on the administrative costs incurred to action your request;

b)      refuse to comply with your request.

Finally, you may decide at any time to file a complaint with the Supervisory Authority if you believe that one or more of your rights or any rules of the Regulation have been violated.

You may exercise these rights by sending an email to the Data Protection Officer (DPO) at dataprivacyofficer@todsgroup.com.

Withdrawal of Consent

While you may withdraw your consent for processing your personal data for marketing and/or customer profiling purposes by sending an email to this address: dataprivacyofficer@todsgroup.com, through our newsletter, which contains a web link, you may:

             i.        deactivate your subscription to our newsletter;

            ii.        withdraw your consent to processing your personal data for marketing purposes. In which case, we will cease all our advertising and/or promotional communications and automatically deactivate any active subscription to our newsletter (relating to any Tod’s Group brand);

           iii.        withdraw your consent to processing for customer profiling purposes.

Furthermore, you may at any given time, withdraw (or give) your consent to processing for purposes of marketing and/or customer profiling through your personal account, if you have activated one, on our Site.

Withdrawing your consent does not negate the legitimacy of the processing you had previously consented to.

 

  You can also contact the DPO to request further information or clarification, or to obtain specific information about who is authorized to access your personal data.

8.   Updates to this Policy

From time to time, we may make some changes to this Privacy Policy, for example, to fulfill new requirements set by the applicable legislation, meet technical requirements, or as a result of new services provided on the Site or by the Tod’s Group.

The updated Privacy Policy will be published on this website.

We may also need to contact you, if legally required, to obtain your consent and allow you to continue to use the services of the Site.

We therefore ask that you to visit this page periodically.