Revised date: April 2020
We would like to inform you that TOD’S S.p.A. will process your personal data in compliance with the provisions of Regulation (EU) 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 provide you our newsletter subscription service.
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., with registered office in 1, Via Filippo della Valle, S. Elpidio a Mare (FM).
2. Legal Basis and Purpose of Processing
We will process your personal data but only with your explicit and specific consent to do so to:
i. conduct marketing activities through newsletters, promotions, discounts, incentives, commercial information, and other related marketing schemes, via paper mail, phone calls, direct sales, email, automatic voice calls or sms/mms, and to send invitations to shows or events, perform market research and send notifications on special initiatives dedicated to TOD’S Group customers;
ii. perform customer profiling activities, such as analyzing your interests and preferences concerning our products and services, and your shopping habits. Also, by looking into the type and frequency of purchases you make online (via your personal account or as guest) and/or at our boutiques/points of sale, we can better guarantee a personalized service for your future visits to the TOD'S Group boutiques. Likewise, if you also have consented to processing your personal data for marketing purposes, we will be able to send you promotional information and/or invitations to initiatives that fit best your profile, preferences and expectations as a shopper.
We would like to inform you that should you decide not to consent to processing your personal data for marketing purposes, we would not be able to provide you our newsletter subscription service.
However, if you decide not to consent to processing your personal data for customer profiling purposes, it would not impact in any way your subscription to the newsletter but would simply prevent us from fulfilling the purposes described in paragraph ii).
If you have previously consented to processing your personal data, you will be requested to provide consent for each purpose (in particular, for marketing and customer profiling activities), by marking the selection box for each specific purpose to allow us to process your personal data accordingly.
If you do not wish to authorize the processing of your personal data for any of the indicated purposes, please do not mark the selection box associated with the specific purpose, and we will assume that:
i. you do not consent to processing your personal data for that specific purpose if you have not previously authorized the Company to do so.
ii. you are withdrawing the consent you have previously given the Company to process your personal data for that specific purpose.
Therefore, the Company (i) will not process in any way your personal data for the specific purpose indicated or (ii) will cease all processing activities that up until then had been lawfully performed.
Finally, we may also process your personal data to comply with any legal obligations that we may have or to pursue any legitimate interests of ours or of third parties, in compliance with the conditions and limits set by the current legislation.
3. 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 also process your 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.
4. Disclosure and Dissemination of Personal Data
We will not disseminate your personal data.
We may disclose your personal data, exclusively for the purposes described above, to other companies within the Tod's Group, to other companies, organizations or associations that perform technical and organizational tasks on our behalf, again consistent with attaining the purposes previously described, as well as to public authorities that make it lawful and legally required. Any transfers of your personal data outside the European Economic Area (EEA) will take place only if the country of destination guarantees the same level of protection of personal data as that in the European Union (EU).
5. Duration of Processing
We will process your personal data for marketing purposes for a term of 7 years starting from the date of consent. Before your consent expires, we will send you an email inviting you to renew your consent so you can continue receiving our newsletters. If you do not respond to said email, you will stop receiving the newsletter and any other type of promotional and/or commercial communication from the Data Controller at the end of the seventh year.
We will process your personal data for customer profiling purposes for a term of 7 years starting from the date of consent. This term will automatically renew each time you make a purchase at any boutique/point of sale under the Tod’s Group, including its online store.
If the processing of your personal data is based on legal provisions or on any legitimate interest of ours or of third parties, the processing of your personal data will be strictly limited to the time required to achieve the purposes for which the data was collected and/or processed.
6. 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.
Especially with regards to processing for marketing and/or customer profiling purposes, we would like to remind you that you may at any time exercise your right to withdraw the consent you have given us.
You may exercise these rights at any time by sending an email to the Data Protection Officer (DPO) at firstname.lastname@example.org.
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 to send you any advertising and/or promotional communications and automatically deactivate your newsletter subscription.
iii. withdraw your consent to processing for customer profiling purposes.
We will make sure to comply with your request to exercise your rights always within the limits of the law.
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.