We wish to inform you that your personal data will be processed by TOD’S S.p.A. (the “Company”) in compliance with the provisions of Legislative Decree No. 196/2003 as subsequently amended (the “Italian Privacy Code”) and EU Regulation No. 679/2016 (the “Regulation”); pursuant to Article 13 of the Italian Privacy Code and Article 13 of the Regulation, we hereby provide you with the following information:
1. The Data Controller is TOD’S S.p.A., with registered office at 1, Via Filippo della Valle, Sant’Elpidio a Mare (FM), Italy. The Data Processor is the Company’s Data Protection Officer, pursuant to Article 37 of the Regulation, who you may contact by writing to firstname.lastname@example.org and to whom you may refer to exercise the rights set forth in clause 7 below and to submit any requests regarding the processing of your personal data by the Company.
2. The data you provide will be processed, on the basis of your prior, free and express consent, for the following purposes:
(a) to offer promotions, discounts, benefits and other services by newsletter, to send out commercial or promotional information and giveaways as well as invitation to events or shows, to carry out market researches and to announce any special initiative tailored to clients of the TOD’S Group;
(b) to carry out customer profiling activities by identifying the type and frequency of purchases made by you both online and/or at the stores of TOD’S Group, to provide you with a better service on the occasion of future purchases at one of the Group’s stores and for the purposes set out in the above paragraph.
Your data may also be processed for statistical or historical purposes.
3. The processing of your data will be carried out by using telematic, paper-based and IT tools. In particular, the processing of your data, including for profiling purposes, may also take place by automated processes, for instance, by means of assessment and comparative analysis of your purchase choices (types, quantities) during a specific period and/or season and by analysing the type and number of your requests for information about products made during a predetermined timeframe.
4. Your data will not be disseminated. The data you provide will be accessible to the employees and the co-workers of TOD’S S.p.A. – solely and exclusively for the purposes listed in clauses (a) and (b) above and in order to ensure that such data are accurate at all times and updated whenever you liaise with TOD’S Group. Your data will also be made available to third parties employed by TOD’S Group for the organization and management of its commercial activities, (e.g. service providers such as couriers, freight forwarders and data entry companies, etc.), companies belonging to the TOD’S Group, managers and franchisees of TOD’S Group stores, based both in Italy and abroad, acting as data processors or as person in charge, as the case may be. They will also be made accessible to third parties engaged with the maintenance/development of our computer system for the period strictly necessary for carrying out such service.
5. The Company will store the data collected for the purposes referred to in clause 2 above until withdrawal of your consent to the processing of personal data and in any case, as for the data processed for the purposes set out in clause 2(b), for a maximum period of seven years after your last purchase, in compliance with the measure issued by the Italian Data Protection Authority (Garante per la protezione dei dati personali) on 7 November 2013 upholding the preliminary ruling requested by the Company. Upon withdrawal of your consent or upon expiry of the storage period of the data collected for the purposes set out in clause 2(b), whichever occurs earlier, such data will be automatically erased or rendered permanently anonymous. You may withdraw your consent to your data being processed any time: all commercial correspondence will include a section which can be used to withdraw consent you already provided. Data sent to service providers will be processed by them for a period strictly necessary to perform the tasks entrusted to them.
6. In the event of refusal to provide data or lack of consent to the data processing, our company will not be able to process data for marketing purposes set forth in clause (a) above. In the event of lack of consent to the processing of data for the purposes set forth in clause (b) above, our company will not be able to process data for “profiling” purposes. In no event lack of consent to the processing of your data for “profiling” purposes will prevent you from receiving commercial or promotional information.