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Privacy Policy for Online Check Out

Last Udpated In: July 2021

Your Privacy and the security of your personal data/information are very important for the whole of Tod's Group, and that is why we use the utmost care in collecting and processing the personal data  you will provide us with during the purchase process on our Website,  adopting specific provisions in order to ensure the security, confidentiality and integrity thereof, in compliance with Regulation (EU) 2016/679 (from here on, the Regulation), and with the applicable privacy regulations in Switzerland (e.g. Federal Act on Data Protection - FADP), according to the implementation and within the limits of their territorial scope.

You will find below all the information concerning our processing of your personal data to allow you to purchase the products of Tod’s Group products on the online store (hereinafter, “E-Store”).

The Privacy Policy herein supplements the Privacy Policy of the Website, to which you should refer to for additional information.

  1. Data Controller

The Data Controller of your personal data, which will be processed for the purposes described in the following section, is Tod’s S.p.A. (hereinafter referred to as “Tod’s”, “we”, “us” or “our”), having its registered office in Via Filippo Della Valle, 1, Sant’Elpidio a Mare, (FM) - Italy (EU).

  1. Lawfulness and Purposes of Processing

Unless specified otherwise within the Privacy Policy herein, we collect and process the personal data you provide; we shall not obtain your personal data from any third party. “Personal data” pertains to any information concerning an identified or identifiable natural person (the ‘data subject’).

Your personal data (e.g. your name, surname, delivery address, e-mail address, and the like.), shall be processed in order to allow you to purchase products on our E-Store, as well as to fulfil our contractual obligations.

We would like to point out that we shall NOT process your payment information (i.e. your credit card number) in any way.

Failing to disclose your personal data and information will not allow to complete your purchasing process, since such information is necessary to allow us to fulfil our contractual obligations, as well as to comply with the legislation, including the fiscal, bookkeeping and administrative obligations.

Finally, we may also process your personal data in order to comply with any legal obligations that we may have,  or to pursue any legitimate interest, be it ours or belonging to third parties (i.e. optimising the purchasing procedures, preventing frauds, exercising and defending a right of ours, improving the shopping experience),  in compliance with the conditions and limits set by the legislation currently in force.

  1. Personal data Processing and Security

We shall process your personal data both by means of paper- and IT-based tools, and such processing shall be based on the principles of fairness, lawfulness, and transparency, in order to protect your rights and privacy.

We make use of industry-standard physical, organizational, contractual and technological security measures to protect your personal data from unauthorized access, public disclosure, use, modification, damage or loss.

  1. Personal data Disclosure and Transfer

We shall not disseminate your personal data.

To the extent permitted by law and where required with your consent, your Personal information may be disclosed, for the purposes described in the Privacy Policy herein:

  1. to our service providers, including other companies of Tod’s Group, performing technical and organizational tasks on our behalf (i.e. delivery and logistics services, IT technical support, fraud prevention in the electronic payment system [for further information, please see: https://www.forter.com/service-privacy-policy] , customers support, and the like), again pursuant with achieving the purposes described in the Privacy Policy herein;
  2. to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other shift in all or in any given part of our business, assets or stock (also in connection with bankruptcy or similar outcomes);
  3. in connection with the essential purposes described above (that is to say in order to comply with legal obligations or to execute a lawful request of public authorities).

Your personal information shall be transferred from your country to our headquarter in Italy. Please, consider that we are subjects to the Regulation (EU) 2016/679 and the Federal Council has ruled that the Regulation ensure an adequate data protection. Notwithstanding the foregoing, we shall transfer your personal data if you have given your consent or if the transfer is necessary for concluding or executing of a contract of which you are a counterparty or beneficiary.

We also undertake to carry out, in accordance with laws in force, any possible prior risk assessment concerning the data transfer; adopting, if necessary, any additional security measures, complementary to the safeguards guaranteed by the aforementioned transfer mechanisms.

At any rate, we shall transfer your personal information, only if the protection level, guarantee by the privacy laws in force in our countries, is not compromised.

Should an adequacy decision pursuant to art. 45(3), or of appropriate safeguards pursuant to art. 46 of Regulation, including binding corporate rules, be absent, we may transfer your personal data only if:

  1. you have explicitly provided your consent to the proposed transfer   after having been informed of the possible risks of such transfers due to the absence of an adequacy decision and of appropriate safeguards;
  2. the transfer is necessary for the performance of    a contract  you are involved in, or  for  the implementation of pre-contractual measures taken at your request;
  3. the transfer is necessary for the conclusion    or the performance of a contract, concluded in your interest, between us and another natural or legal person.

Your personal data shall only be processed by parties being duly instructed and able to provide adequate technical and organizational safeguards, as well as bound to the strictest confidentiality by us.

  1. Retention of personal data

We shall process your personal data at different times depending on the purpose.

Your personal data that we will process to enable you to complete your purchases on the E-Store shall be stored and processed until we completely fulfil all the obligations arising from the contract.

We would also like to inform you that we are further required to store your personal data in order to comply with specific law provisions dealing with fiscal, accounting and administrative matters, in the manner and   within the  timeframe established by said regulations.

Should the processing of your personal data be based on any legitimate interest, be it ours or belonging to third parties, the processing of your personal data shall be strictly limited to the time required to achieve the legitimate interest, on a case-by-case basis.

  1. Your Rights

You have the right, as detailed within the law in force, to access your personal data, to correct or update it, to delete or to obtain a copy or the transmission in a structured format to any third party thereof. You may also request to limit or object to such processing.

You may exercise these rights at any time, by writing to our Data Protection Officer (DPO) to the following addresses:

  • by e-mail: dataprivacyofficer@todsgroup.com.
  • by post: Data Protection Officer - Tod's S.p.A., Via Filippo Della Valle n. 1, 63811 Sant’Elpidio a Mare (FM) – Italy (EU).

We would like to inform you that we shall not discriminate against you, should you exercise one or more of your privacy rights acknowledged by the relevant legislation; such an exercise shall have no impact on the purchasing of our products or on any existing relationships with the Company.

We will make sure to comply with your request to exercise your rights, always within the terms of the law.

We shall retain the right to ask you, in the 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 seize, change or delete them. The processing of your request is free of charge. However, should your requests be manifestly unfounded, excessive, or repetitive in nature, we shall retain the right to refuse to comply with them or to request suitable economic contributions for them.

Remember that you can file a complaint with the Supervisory Authority if you believe that we have violated any rules concerning the protection of personal data.

  1. Updates to the Privacy Policy herein

We may periodically update the Privacy Policy herein.  Please reference the “LAST UPDATED IN” legend at the top of this page to see when the Privacy Policy herein was last revised.

Privacy Policy for Online Check Out

Revised date: December 2019

We would like to inform you that we will process your personal data in compliance with the provisions of EU Regulation 679/2016 (hereinafter,“Regulation”) and any specific local rules related to the protection of personal data

Below you will find all the information regarding our processing of your personal data to allow you to purchase Tod’s Group products on the online store (hereinafter, “Store”).

This Privacy Policy supplements the Privacy Policy of the Site, which we will refer to for anything not fully explained here.

a) Data Controller

The Data Controller of your personal data, which will be processed for the purposes described in the following section, is Tod’s S.p.A., with registered office in 1, Via Filippo Della Valle, S. Elpidio a Mare (FM) - Italy.

b)   Legal Basis and Purpose of Processing

We will process your personal data to allow you to successfully purchase products from the Store, which necessitates said processing for the performance of a contract and/or adoption of pre-contractual measures at your request.

We will also process your personal data for the purposes of fulfilling legal obligations, including tax and administrative duties, and to pursue any legitimate interest of ours or of third parties, always in compliance with the conditions and limits set by the current legislation.

Not disclosing your personal data will prevent us from completing the sales transaction since your personal information is necessary for us to fulfill the obligations arising from the existing contract, as well as to comply with legal provisions, including those dealing with tax, accounting, and administrative matters.

c)  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.

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

d)   Disclosure and Dissemination of Personal Data

We will not disseminate your personal data.

We will disclose your personal data only for the purposes described above to other companies within the Tod’s Group, with headquarters in countries both within and outside the European Union.

Your data may also be accessible to companies, organizations or associations that perform technical and organizational tasks on our behalf, again consistent with attaining the purposes previously described. For instance, but not limited to the disclosure of your personal data, to the extent strictly necessary, to professional operators who perform checks on our behalf to prevent fraud in electronic payment systems (for more details please read the privacy policy of our service provider, Forter, at: https://www.forter.com/service-privacy-policy/).

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.

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

e)   Duration of Processing

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.

In particular, your personal data that we will process to enable you to complete your purchase on the Store will be stored and processed until we completely fulfill all the obligations arising from the contract.

We are also required to store your personal data for a longer period of time to comply with specific provisions of the law dealing with tax, accounting and administrative matters, in the manner and time frame established by said regulations.

f)    Your Rights

You have the right to access your personal data, to correct or update it, or to delete or transmit it in a structured format to any third party. You may also request to limit or object to its processing.

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

Remember that you can file a complaint with the Supervisory Authority if you believe that we have violated any rules concerning the protection of personal data.