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 by joining our promotional communications plan, 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).
Below you will find the information regarding the processing of your personal data that we will perform in order to involve you in our marketing and promotional initiatives; and, where we have been allowed to do so, in order to provide you with services more suitable to your preferences and expectations.
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).
Tod’s S.p.A., pursuant to art. 6.1 (a) of Regulation, shall 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.
Please note that, should you decide not to give your consent to the processing of your personal information for marketing purposes, we will not be able to send you our promotional communications, including our periodical newsletter update service.
Should you decide not to give your consent to the processing of your personal data for profiling purposes, this shall have no impact on your involvement in our promotional communications plan, but this would simply not allow us to fulfil the purposes detailed within point ii) above.
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.
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.
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.
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.
We shall process your personal data at different times depending on the purpose.
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 inform you that we shall not discriminate against you, should you exercise one or more of your privacy rights acknowledged by the relevant legislation.
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.