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Privacy policy

TOD’S

This notice is addressed to anyone visiting and interacting with this Internet site of TOD’S S.p.A. (hereinafter also “TOD’S” or the “Company”). It only applies to this website and not to any other websites which can be accessed by the user through links on this website; this does not affect the information provided in relation to the web Store where [Roger Vivier] products can be purchased online. The Company shall to no extent be held liable for the unlawful processing of your data by third parties. Therefore, to exercise the rights set out in paragraph ‘Rights of the Data Subject’, please refer to the specific notices that such third parties are required to provide you with as independent data controllers.

This website provides direct access to the e-commerce website of Tod’s S.p.A.’s, referred to as the ‘web Store,’ where you can make online purchases; the web Store is operated on behalf of TOD’S by a subsidiary of Diego Della Valle & C. S.r.l. Group named ItalianTouch S.r.l., a sole shareholder company, with registered office at 171, Corso Umberto I, Civitanova Marche (MC), Italy (“ITALIANTOUCH”), which sells the products bearing the [Roger Vivier] trademarks traded in the Store.

ITALIANTOUCH deals with the management of sales and transactions carried out in the context of TOD’S S.p.A. Store (such as, by way of example, management of the orders, product sales and delivery, management of returned goods and warranties, and any other activities required to sell products through the Store).

The section named ‘Store Privacy Policy’ contains the notice provided by ITALIANTOUCH regarding the data it collects as independent data controller or joint data controller, as the case may be.

To access reserved services, including purchasing products, you need to register with the Store; TOD’S and ITALIANTOUCH will process the personal data provided upon registration and upon conclusion of the purchase agreement through the Store as joint data controllers (each of them a “Joint Data Controller” or “Data Controller,” and together “Joint Data Controllers” or “Data Controllers”), in compliance with Legislative Decree No. 196 dated 30 June 2003 (the “Italian Privacy Code”) and EU Regulation No. 679/2016 (the “Regulation”). The Joint Data Controllers have entered into a specific agreement to define their respective responsibilities regarding compliance with the obligations set forth by the Regulation and the Privacy Code; you can access adequate information on the essential content of the agreement by contacting the Data Controller using the references indicated above. It is understood that, regardless of the agreement, you may in any case exercise your rights under the Regulation and the Privacy Code in respect of and against each Data Controller.

The data required to conclude the purchase agreement and fulfil the legal obligations associated therewith (including tax and administrative ones) will be autonomously processed by ITALIANTOUCH as the Data Controller pursuant to the Privacy Code.

With your express consent, which may be provided to TOD’S separately, the data collected will be used by TOD’S for independent data processing, as specified below.

This privacy policy is also based on Recommendation No. 2/2001 adopted by the European personal data protection authorities, brought together in a working group created in accordance with Article 29 of Directive No. 95/46/EC, on 17 May 2001 in order to identify certain minimum requirements for collecting personal data online and, more specifically, the manner, timescale and nature of the information that data controllers must provide to users when they visit web pages, regardless of the purpose of such visit.

Specific summary privacy notice will be subsequently displayed on or shown in the website pages arranged for specific services on request.

The Company will process your personal data in compliance with the provisions of the Privacy Code and the Regulation.

Data Controller

The independent controller of the processing of any data provided by means of subscription to the newsletter of this website and/or compiling of coupons at one of the Tod’s Group stores is TOD’S S.p.A., with registered office at 1, Via Filippo della Valle, Sant'Elpidio a Mare (FM), which may also be contacted by writing to the following e-mail address:dataprivacyofficer@todsgroup.com

Tod’s S.p.A. is also:

- the joint controller (together with Italian Touch) of the data you provide upon registration with the Store and the conclusion of the purchase agreement through the Store;

- the independent controller of the data you provide for marketing and/or customer profiling set forth in paragraph ‘Browsing and registration with the web Store; consent to marketing and/or customer profiling’.

The Data Processor of your personal data is the Company’s Data Protection Officer pursuant to Article 37 of the Regulation, who you may contact by writing to dataprivacyofficer@todsgroup.com, and to whom you may refer to exercise the rights set forth in the paragraph ‘Rights of the Data Subject’ and to submit any requests regarding the processing of your personal data by the Company.

What are the data collected by TOD’S?

Browsing Data

During their normal operation, the IT systems and software procedures used to run this website acquire personal data; the transmission of this data is an inherent feature of the use of Internet communication protocols.

This information is not collected to be linked to identified individuals. However, when processed and matched with third party data, this information may inherently allow identifying the users.

This category of data includes the IP addresses or domain names of the computers used by users who access the site, the Uniform Resource Identifier addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code that indicates the response status provided by the server (success, error, etc.) and other parameters that relate to the operating system and the user’s IT environment.

This data is only used to gather anonymous statistical information about the use of the website and to check that it is operating correctly and is erased immediately once it has been processed. The data could may be used to ascertain liability if any computer crimes are committed which affect the website: save in those circumstances, web contact data are currently held for no longer than fifteen days.

Cookies

No cookies are used for the transmission of personal information, while persistent cookies are only used for registered users, in encrypted form, for the sole purpose of keeping their navigation sessions active.

The use of session cookies (which are not permanently stored on the user's computer and are automatically erased once the browser session is ended) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to ensure the safe and efficient website navigation.

Persistent cookies (which last longer than a single browsing session) are used exclusively to keep the user’s shopping cart active. No personal data or confidential information is tracked.

The user may always configure the settings of its browser to have it refusing all cookies or reporting the possible sending of a cookie. Each user can find the information necessary to disable cookies on its browser toolbar using the ‘Help’ menu. Please note however that certain websites do not work properly without cookies. If cookies are disabled, the Company will not be able to guarantee the proper functioning of its website.

Session cookies used on this website permit to avoid the use of other data processing techniques potentially compromising user’s confidentiality and do not allow the acquisition of user’s personal identification data.

For more information, please visit the Cookie Policy page.

Personal data you provide to us voluntarily

Personal data we may collect via this website include, by way of example:

a) contact information (e.g. name, mailing address, e-mail address and mobile or other telephone number);

b) username and password in case of registration on the website;

c) information on purchases and transactions (data relating to the value and frequency of purchases as well as to the type of products purchased), only with your prior express consent.

Processing Purposes

“Contacts” section; consent to marketing and/or customer profiling

If you wish, you can contact us to request support in the navigation of our website, for information on collections and ongoing promotions and, in general, for any information about the products of TOD’S Group.

We will use the data you provide in these circumstances to address your specific requests and to perform the service you required.

The data you provide when completing the contact form may be processed (only where you have freely provided your prior express consent and on the basis of such consent) by TOD’S S.p.A., registered office at 1, Via Filippo della Valle, Sant’Elpidio a Mare (FM), for the following purposes:

(i) to offer promotions, discounts, benefits and other services and to send out commercial or promotional information, giveaways and invitations to events and shows, to carry out market research and announce any special initiatives tailored to clients of the TOD’S Group;

(ii) to carry out customer profiling by identifying the type and frequency of purchases made by you online and/or at the stores of TOD’S Group to provide you with a better service on the occasion of future purchases at a Group’s store and for the purposes set out above.

The data may also be processed for statistical or historical purposes.

Signing up for our newsletter and consent to marketing and/or customer profiling; purchase of products in the Tod’s Group stores and completion of coupons for marketing and/or customer profiling purposes.

You can sign up for our newsletter if you wish to do so.

Similarly, when you make a purchase at one of the Tod’s Group stores, you may be given the possibility, completely optional, to provide us with certain data by filling in a specific coupon; in this way, TOD’S Group can improve the service that it intends to offer to its Customers.

The data you provide when filling in the coupons at one of the Group’s stores and/or by signing up for our newsletter will be processed (only where you have provided your prior, free express consent) by TOD’S S.p.A., registered office at 1, Via Filippo della Valle, Sant’Elpidio a Mare (FM), for the following purposes:

(ii) to carry out customer profiling by identifying the type and frequency of purchases made by you online and/or at the stores of TOD’S Group, to provide you with a better service on the occasion of future purchases at a Group’s store and for the purposes set out above.

The data may also be processed for statistical or historical purposes.

Browsing and registration with the web Store; consent to marketing and/or customer profiling

As mentioned previously, this website provides direct access to TOD’S S.p.A.’s e-commerce site, referred to as the web Store, where you can also make purchases online; the web Store is operated by ItalianTouch S.r.l., a Diego Della Valle & C. S.r.l. Group subsidiary, on behalf of TOD’S; in the web Store, from time to time, you will be provided with specific notices in relation to various purposes of processing of the data you will be requested to provide.

The data provided upon registration with the Store and upon online purchase of a product will be processed, on the basis of your prior free and express consent and for performance of the service or assistance you have requested, by TOD’S as the Joint Data Controller together with ITALIANTOUCH S.r.l., a sole shareholder company, subsidiary of Diego Della Valle & C. S.r.l. Group, with registered office at 171, Corso Umberto I, Civitanova Marche (MC), to handle access to the Store’s services and facilitate the purchase of products online.

When visiting the web Store, you may y provide your prior, free and express consent, which will constitute the basis for processing your data exclusively by TOD’S S.p.A. for the following purposes:

(i) to offer promotions, discounts, benefits and other services and to send commercial or promotional information, giveaways and invitations to events and shows, to carry out market research and announce any special initiatives relating to products of TOD’S Group or third parties’ product;

(ii) to carry out customer profiling by identifying the type and frequency of purchases made by you online and communicated to TOD’S, to provide you with a better service on the occasion of future purchases at a Group’s store and for the purposes set out above.

The data may also be processed for statistical or historical purposes.

Methods of processing

The processing of your data will be carried out by using telematic, paper-based and IT tools; this processing will be based on the principles of accuracy, lawfulness and transparency and protection of your rights and your privacy. The processing of your data, including for profiling purposes, may also take place through 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 analyzing the type and number of your requests for information about products made during a predetermined timeframe.

The data will be processed so as to minimize the risks of destruction, loss, unauthorized access or any use that does not comply with the purpose for which the information was collected.

Provision of data and consequences of withholding consent to data processing

Data required to address your requests

If you do not provide the data necessary for completing the contact form, it will be impossible for us to process your requests for information.

Data required to register with the Store

If you do not provide the data requested for registering, using the Store’s services and making any online purchases, it will be impossible for you to register with or make purchases on the web Store, except for such cases in which you can purchase without registration as a ‘guest’.

Information relating to the credit card that you use when purchasing our products will not be recorded or stored by TOD’S (or ITALIANTOUCH) or any other company of the TOD’S Group , but only by the payment services provider.

Consent to marketing and/or customer profiling (always optional)

Your refusal to provide data or lack of consent in relation to data being processed for the purposes of marketing and/or customer profiling as set out in points (i) and (ii) of the ‘Signing up for our newsletter and consent to marketing and/or customer profiling; purchase of products in the Tod’s Group stores and completion of coupons for marketing and/or customer profiling purposes' and ‘Browsing and registration with the web Store; consent to marketing and/or customer profiling’ will prevent our Company from processing your data for these purposes.

In no event lack of consent to the processing of your data for the purposes of “Marketing and/or customer profiling” will prevent you from purchasing the products of TOD’S Group.

Entities or categories of entities to which the data may be disclosed and extent of such data disclosure

Your data will not be disseminated.

Data provided in the “Contacts” section

The data you provide by completing the contact form will be made accessible to Company’s employees and co/workers authorised as person in charge for the processing, TOD’S Group companies as external data processors, and service providers the Company collaborates with only if it is strictly necessary to perform any service or performance you may request. 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.

The data you provide, based on your prior consent, for the purposes set out at points (i) and (ii) of the ‘Contacts section; consent to marketing and/or customer profiling’ paragraph will be made accessible to TOD’S S.p.A.’s employees and coworkers – solely and exclusively for the purposes listed therein and to ensure that the said data are accurate at all times and updated whenever you liaise with TOD’S Group in the future. 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 firms, etc.), TOD’S Group companies, operators and franchisees of TOD’S Group stores, based both in Italy or abroad, acting as data processors or as person in charge, as the case may be.

Please be advised that pursuant to article 13, paragraph 1, letter f of the Regulation, personal data collected may be transferred to a third country or to an international organization outside the European Union for the above-mentioned purposes. The Company has already asked the current data importers to provide suitable safeguards to protect the data transferred and specific data transfer agreements were executed in compliance with the standard data protection clauses adopted by the EU Commission. Any subsequent transfers of personal data to third parties residing in a third country outside the European Union will be carried out in compliance with the provisions of the Regulation. You may access adequate information on the safeguards provided as the protection of the data transferred by contacting the Data Controller using the contact details indicated above.

Data provided by signing up for our newsletter or at Tod’s Group stores

The data you provide, based on your prior consent, for the purposes set out at points (i) and (ii) of the ‘Signing up for our newsletter and consent to marketing and/or customer profiling; purchase of products in the Tod’s Group stores and completion of coupons for marketing and/or customer profiling purposes’ will be made accessible to TOD’S S.p.A.’s employees and coworkers – solely and exclusively for the purposes listed therein and to ensure that the said data are accurate at all times and updated whenever you liaise with TOD’S Group in the future. 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 firms, etc.), TOD’S Group companies, operators and franchisees of TOD’S Group stores, based both in Italy or abroad, acting as data processors or as person in charge, as the case may be. Please be advised that pursuant to article 13, paragraph 1, letter f of the Regulation, personal data collected may be transferred to a third country or to an international organization outside the European Union for the above mentioned purposes. The Company has already asked the current data importers to provide suitable safeguards to protect the data transferred and specific data transfer agreements were executed in compliance with the standard data protection clauses adopted by the EU Commission. Any subsequent transfers of personal data to third parties residing in a third country outside the European Union will be carried out in compliance with the provisions of the Regulation. You may access adequate information on the safeguards provided as the protection of the data transferred by contacting the Data Controller using the contact details indicated above.

Data provided on the web Store

The data you provide for registration and access to the Store services and for execution of the purchase contract through the Store will be accessible to TOD’S employees and collaborators (as joint data controller together with ITALIANTOUCH S.r.l.) and may be communicated, exclusively for administrative purposes, to TOD’S Group companies, its commercial partners, all the suppliers of services and products Tod’s engages, in Italy and abroad.

The data you provide, with your prior consent, for the purposes set out at points (i) and (ii) of the ‘Browsing and online purchases on the web Store; consent to marketing and/or customer profiling’ paragraph will be made accessible to TOD’S S.p.A.’s employees and coworkers – solely and exclusively for the purposes listed therein and to ensure that the said data are accurate at all times and updated whenever you liaise with TOD’S Group in the future. 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 firms, etc.), TOD’S Group companies, operators and franchisees of TOD’S Group stores, based both in Italy or abroad, acting as data processors or as person in charge, as the case may be. They will also be accessible to third parties engaged with the maintenance/development of our computer system for the period strictly necessary for carrying out such service.

For any further information, please refer to the relevant privacy notice published on the web Store upon collection of data.

If required, data may be communicated to the competent authorities, in compliance with legal obligations.

Duration of processing

Save where a longer storage period is required to comply with the applicable regulations, including accounting rules, the Company will store your data for the period strictly necessary to ensure that the services purchased are provided properly.

The data processed by TOD’S S.p.A. for customer profiling and/or marketing purposes (provided that your express consent has been acquired) will be stored until withdrawal of your consent to the processing of personal data and in any case, as for the data processed for profiling purposes, 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 profiling purposes, whichever occurs earlier, such data will be automatically erased or rendered permanently anonymous. Our Company may ask you to renew your consent to the processing of your data or keep them only for anonymous statistical or historical purposes.

You may withdraw consent to your data being processed for customer profiling and/or marketing purposes any time: all commercial correspondence will include a section you may use to withdraw the consent you already provided.

Data sent to service providers will be processed by them within the period strictly necessary for them to provide the services required.

General notice for Suppliers

1. We would like to inform you that TOD’S S.p.A. will process your data in compliance with the provisions of the Italian Privacy Code as subsequently amended and the Regulation; the processing will therefore be carried out in accordance with the principles of accuracy, lawfulness and transparency as well as protection of your privacy and your rights. The Data Controller is TOD’S S.p.A., with registered office at 1, Via Filippo della Valle, Sant’Elpidio a Mare (FM), Italy.

2. You may exercise your rights referred to in the next paragraph towards the processor of your personal data, the Data Protection Officer designated by the Company pursuant to Article 37 of the Regulation, who you may contact by writing to dataprivacyofficer@todsgroup.com.

3. Pursuant to Article 13 of the Italian Privacy Code and Article 13 of the Regulation, we therefore provide you with the following information:

4. The data provided by you will be processed for the following purposes and their processing is necessary for the performance of the commercial agreements between you and the Company:

(a) compliance with obligations pursuant to agreements between you and the Company;

(b) compliance with administrative and accounting requirements (handling/processing of orders, correspondence, invoicing, etc.) connected with the above contracts;

(c) compliance with requirements imposed by laws and regulations and in general by the applicable legislation, including EU laws, in force from time to time.

5. The processing of your data will be carried out by using telematic, paper-based and IT tools.

6. Provision of the data is compulsory for the purposes set out above.

Any refusal to provide the requested data or their inaccuracy may result in the failure or partial execution of the tasks entrusted to the Company and/or inability to continue the relationship established with the Company.

The data will not be disseminated. They will be accessible to employees of the Company authorized to carry out the processing for the purposes set out at points (a), (b) and (c) above; they may be communicated to third parties, including our commercial partners and authorized service providers, solely for administrative and accounting purposes related to the aforementioned contracts with the Company and to better perform the obligations arising out of such contracts; in particular, your data may be communicated to other companies belonging to the TOD’S S.p.A. Group. Please be advised that pursuant to article 13, paragraph 1, letter f of the Regulation, personal data collected may be transferred to a third country or to an international organization outside the European Union for the above-mentioned purposes. Please be advised that pursuant to article 13, paragraph 1, letter f of the Regulation, personal data collected may be transferred to a third country or to an international organization outside the European Union for the above-mentioned purposes. The Company has already asked the current data importers to provide suitable safeguards to protect the data transferred and specific data transfer agreements were executed in compliance with the standard data protection clauses adopted by the EU Commission. Any subsequent transfers of personal data to third parties residing in a third country outside the European Union will be carried out in compliance with the provisions of the Regulation. You may access adequate information on the safeguards provided as the protection of the data transferred by contacting the Data Controller using the contact details indicated above.

7. They may also be communicated / made accessible to third parties engaged with the maintenance/development of our computer system for the period strictly necessary for carrying out the service.

8. Save where a longer storage period is required to comply with the applicable regulations, including accounting rules, the Company will store your data by for the period strictly necessary to ensure that the aforementioned contractual obligations are properly complied with.

9. In compliance with Article 7 of the Italian Privacy Code and Article 13, paragraph 2, letter b of the Regulation, you are entitled to be informed, any time, about which data are in possession of the Company and which use is made of such data. For further information about the rights you may exercise pursuant to the Regulation and the Italian Privacy Code and in general about processing of your personal data through this website, please refer to the following paragraph ‘Rights of the data subject.’

Rights of the data subject

Pursuant to Article 7 of the Italian Privacy Code and Article 13, paragraph 2 , letter(b and Article 13, paragraph 2, letter d of the Regulation, please be advised that:

a) You are entitled to request the Company as the data controller to access your personal data and update, supplement, correct or erase all the data provided, request anonymization of the same or blocking of those data processed in violation of the law, object to their processing for legitimate reasons and require restriction of their processing; the full text of Article 7 of the Italian Privacy Code is available on the website: www.garanteprivacy.it, while the text of the Regulation may be found at: http://eur-lex.europa.eu/homepage.html;

b) You also have all the rights referred to in Articles 16-21 of the Regulation (right to rectification, right to erasure – the so-called “right to be forgotten” - right to restriction of processing, right to data portability, right to object);

c) lodge a complaint with the competent Data Protection Supervisor for the protection of personal data, following the procedures and indications published on the authority’s official website www.garanteprivacy.it.

Please note that you have the right to oppose our “direct” marketing activities, i.e. sending e-mails, text messages, telephone contacts, regular post, etc. and, if necessary, to the related profiling.

Links to third-party sites

During browsing, you could view the content with links to third-party sites. TOD'S may not access, or control cookies or other functions used by third-party sites, and the procedures of such external sites are not subject to our Privacy Policy. You should therefore contact and/or consult directly such third parties for further information about the procedures they implemented to safeguard privacy .

Changes

TOD’S reserves the right to amend or simply update the contents of this Privacy Policy, partially or completely, also following changes in the applicable legislation. TOD’S will inform you of such changes as soon as they are introduced, and they will be binding as soon as they are published on the website. Therefore, TOD’S invites you to regularly visit this section to read the most recent and updated version of the Privacy Policy and be always updated in terms of the data collected and their use by TOD’S.