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 marketing and promotional communication
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, Sant'Elpidio a Mare (FM) - Italy (EU).
2. Legal Basis and Purpose of Processing
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, messaing platform or SMSs/MMS, and to send invitations to shows or events, perform market research and send notifications on special initiatives dedicated to TOD’S Group customers;
In addition to the email address, indispensable for your subscription to the newsletter, in accordance with the marketing procedure that we will adopt, we may use complementary channels / tools (telephone, traditional mail, etc.), corresponding to the contact information you have provided or will provide in the future;
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.
Please note that, if you decide not to give your consent to the processing of your personal data for marketing purposes, we will not be able to send you newsletters, promotional communications and provide the marketing service you are subscribing to.
If you decide not to give your consent to the processing of your personal data for profiling purposes, this will not have any impact on your subscription to the promotional communication and marketing newsletter service, but this would not allow us to fulfil the purposes mentioned in the above par. 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 disclosure of your personal data outside the European Economic Space shall be made upon suitable guarantees, such as suitability decisions, Standard Contractual Clauses approved by the European Commission or other guarantees compliant with the regulation on personal data protection.
5. Duration of Processing
We will process your personal data for marketing purposes until your consent withdrawal.
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 oppose at any time to receive direct marketing communications both via automatic means (text messages, MMS, messaging platforms, e-mails and push notifications) and traditional means (mail, 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.
You may exercise these rights at any time, by writing to our Data Protection Officer (DPO) to the following e-mail address: firstname.lastname@example.org. If you have given your consent, you may withdraw it at any time without compromising the lawfulness of the data processing procedure followed until the withdrawal.
Notwithstanding your right to withdraw the consent to the processing of your personal data for marketing and/or profiling activities by writing to the e-mail address email@example.com, please note that each communication contains a link that you can use to:
- i. stop the transmission of the received message - and/or -
- ii. withdraw the consent to the data processing for marketing purposes. In this case we will not send you advertising and/or promotional material anymore and any eventual newsletter will be automatically disabled (related to any brand of the Tod's group) - and/or -
- iii. withdraw the consent to profiling activities.
Furthermore, you may at any given time, withdraw (or give) your consent to processing for purposes of marketing and/or customer profiling through your personal account, if you have activated one, on our Site.
Withdrawing your consent does not negate the legitimacy of the processing you had previously consented to.
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.