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Privacy Policy for Online Personal Accounts

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).

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

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.

  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, nationality, e-mail account, telephone number, delivery address, and the like), shall be processed pursuant to art. 6.1 (b) of the Regulation, 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., pursuant to art. 6.1 (a) of Regulation, 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:

  1. perform marketing activities through newsletters, promotions, discounts, incentives, commercial information, and other related marketing schemes, by means of post, phone calls, direct sales, email, automatic voice calls, messaging platforms or SMS/MMS, messages and to send invitations for shows or events, perform market research and send notifications on special initiatives focused on the customers of TOD’S Group. In addition to the email address, in accordance with the marketing procedure that we will adopt, we may use complementary communication channels and tools (such as telephone, post, and the like), corresponding to the contact information you have provided or will provide to us in the future;
  2. perform customer profiling activities, such as analysing 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. Should you provide your consent for us to process your personal data for profiling purpose, you consent that we can obtain from our local subsidiaries the information concerning the purchases you made at their points of sale. Likewise, if you have also given your consent to the processing of your personal data for marketing purposes, we will be able to send you promotional information and/or invitations to initiatives that best fit your profile, preferences and expectations as a shopper.

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

  1. tick the corresponding box, we will process your personal data for the chosen purpose (marketing or profiling);
  2. don’t’ tick the corresponding box, we will comply with the situation previously in force:
    • if you had previously consented to the processing of your personal data (ex through other on-line forms or by means of the coupons available in our boutiques) for such purposes (i.e., marketing or profiling), we will continue to do so;
    • if you never consented to the processing your personal data for such specific purposes (i.e., marketing or profiling), we shall not process your personal data for said purposes (i.e., marketing or profiling).

You have the right to withdraw your consent(s) at any time, (also known as the “right to opt-out”), by following the instructions indicated in the Privacy Policy herein.

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, pursuant to art. 6.1 (c) of Regulation, 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), pursuant to art. 6.1 (f) of  the Regulation, 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.

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.

  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. with our service providers, included other companies belonging to Tod’s Group who perform technical and organizational tasks on our behalf, always in compliance with achieving the purposes described above;
  2. with other belonging to Tod’s Group acting on our behalf:
    1. in order to involve you in local marketing initiatives (marketing purpose);
    2. to provide you with a tailored service and a better purchasing experience when you visit the Tod’s Group shops;
  3. 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);
  4. 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).

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:

  1. specific  “Standard Contractual Clauses” are to be drafted, issued by the European Commission, in order to ensure that the protection level of the personal data processed by our partners outside the EU shall comply with the EU's data protection level;
  2. adoption of Company Binding Rules, approved by the competent Public Authorities, in compliance with the data transfer within a group of undertakings or enterprises is done through binding corporate rules, approved by the competent data protection authority in the UE, pursuant to the consistency mechanism referred to in art. 63 and to the conditions detailed under art. 47 of the Regulation.

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 Regulation, is not compromised.

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, 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.

  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.

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:

  • 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).

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:

  1. inhibit the contact-channel (e.g., e-mail and SMS messages) by means of the which our marketing communications are sent;
  2. withdraw your consent (also known as an opt-out) to the processing of your personal data for marketing purposes. In such cases, we shall not send advertising and/or promotional communication to you anymore and any and all newsletters related to any brand of the Tod's Group shall be automatically disabled;
  3. withdraw your consent to the profiling activities.

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.

  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.