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 as you create your Personal Account, 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 UK (e.g. Data Protection Act 2018, UK General Data Protection Regulation), according to the implementation and within the limits of their territorial scope.
You should not provide us with your personal data if you are not at least 16 years old or not of legal age: the services provided to Personal Account owners are primarily intended for adults. We would like to point out that the protection of safety and privacy for children is very important to Tod's Group. Therefore, we do not intend to collect and voluntarily make use of the personal data belonging to individuals under the age of sixteen (16), or below any other minimum legal age limits being in force in your country of residence. Consequently, we ask that you do not provide us with any personal data if you are below 16 years of age or if you are not of legal age being in force in your country of residence.
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).
Your personal data (e.g. your name, surname, nationality, e-mail account, telephone number, delivery address, and the like) in order to allow you to create your Personal Account on our Website and make use of the related dedicated services . The list of the services reserved for the owners of Personal Accounts s may change and/or be integrated over time, at the option of the Data Controller.
Some of the personal data we ask you about during the creation of your Personal Account creation are essential for us to fulfil the obligations; failure to disclose certain personal data could prevent you from completing the Personal Account activation procedure and / or, in some cases, prevent you from fully using specific services.
Tod’s S.p.A. shall also process your personal data (such as your name, surname, e-mail account, gender, and the like), with your explicit and specific consent to do so, in order to:
We will ask you to provide your explicit consent to the processing of your personal data by ticking the specific boxes concerning marketing purposes and profiling purposes. If you
The provision of any and all personal data is voluntary. However, failure to disclose certain personal data could prevent you from being fully involved in our marketing and profiling initiatives in some cases.
Providing your consent to any such purposes is entirely optional. Likewise, a refusal to provide your consent shall not affect any existing relationship with Tod’s Group, or your Personal Account creation in any way, or with any undergoing relationship with the Company.
Finally, we may also process your personal data in order to comply with any legal obligations that we may have, or to pursue any our legitimate interests (i.e. improving business processes, preventing frauds, exercising and defending a right of ours or optimising our customer contact strategies), in compliance with the conditions and limits set by the legislation currently in force.
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.
In particular, the processing of your data, involving profiling purposes as well, may be automated, for example through a comparative analysis of your purchases (by type, quantity, frequency, timing, and the like), and by analysing the type and number of your requests for product information within a given timeframe.
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.
We shall not disseminate your personal data.
Your personal data shall be transferred from your country to our headquarter in Italy, based on adequacy regulations, pursuant the section 17A of the Data Protection Act 2018.
Data transfers toward countries outside the European Economic Area (EEA): We guarantee that we shall transfer your personal data towards a country outside the European Economic Area (EEA) not having an Adequacy Decision by the European Commission (EC), only after the adoption of at least one of the cross-border transfer mechanisms the Regulation recognizes as being able to ensure an adequate protection of the personal data being transferred:
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.
We would like to stress the fact that the data transfer mechanisms, used to disclose your personal data outside the EU, are coherent with the cross-border data transfer tools stated by the UK laws framework.
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.
We shall process your personal data at different times depending on the purpose.
Your personal data, processed for the creation of your Personal Account and for the usage of services reserved to the owners of company accounts, shall be retained and processed until you delete your Personal Account. We would like to inform you that your personal data shall be automatically erased (or anonymised) once 7 years have passed since your last interaction with your Personal Account (i.e. when you log in to or update your personal data, place new purchases, and the like).
To protect you further, near the end of the 7-year time frame as mentioned above, we will notify you that your account is soon to expire. If you wish to keep your personal account active, you need only to interact with it.
Should you consent to the processing your personal data for marketing purposes, said processing will be performed until your consent withdrawal.
Should you provide your consent to the processing of your personal data for profiling purposes, said processing shall be performed for no longer than 7 years since the date when you provided your consent, and be automatically renewed each time you make a purchase at any boutique/point of sale belonging to Tod’s Group, or at our E-Store.
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, 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.
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.
Concerning the processing of personal data for marketing and/or customer profiling purposes, we would like to stress the fact that you may exercise your right to withdraw the consent you have provided us with at any time.
You may oppose the reception of direct marketing communications (also known as an opt-out) both via automatic means (text messages, MMS, messaging platforms, e-mail messages and push notifications) and traditional means (such as post, phone calls by operators) without prejudice to your possibility of exercising this right only in part, i.e. by opposing only to receive promotional communications via automatic tools at any time.
You may exercise these rights at any time, by writing to our Data Protection Officer (DPO) to the following addresses:
Without prejudice to your right to withdraw (also known as an opt-out) the consent to the processing of your personal data for marketing and/or profiling activities by writing to the aforementioned addresses, please note that each marketing communication contains tools that you can use to:
Moreover, every newsletter of ours features a tool by means of which you can unsubscribe from it. In so doing, you shall no longer receive the periodical newsletter, but you will keep receiving our other marketing updates.
We would like to point out that we shall not discriminate against you, should you exercise one or more privacy rights acknowledged within the legislation; any existing relationships with the Tod’s Group, or your Personal Account creation, or the usage of the services thereof, shall not be affected.
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.