Revised date: December 2019
We would like to inform you that we will process your personal data in compliance with the provisions
of EU Regulation 679/2016 (hereinafter: “Regulation”), of California Consumer Privacy Act of 2018
(CCPA) 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 allow you to purchase Tod’s Group products on the online store (hereinafter, “Store”).
1. Data Controller
The data controller of your personal data, which will be processed for the purposes described in the following section, is ItalianTouch USA Inc., with registered office in 450 West 15th Street, New York 10011 NY (USA), a company within the Tod’s Group.
The Store, where products can be purchased, is managed by ItalianTouch USA Inc. on behalf of Tod’s S.p.A. It sells Tod's Group products online, and as data controller, manages the processing of personal data related to the sales and other transactions of the Store (for example: order management, sales and delivery of products, management of returns and warranties, and other activities related to the sale of products).
2. Legal Basis and Purpose of Processing
We will process your personal data to allow you to successfully purchase products from the Store, which necessitates said processing for the performance of a contract and/or adoption of pre-contractual measures at your request.
We will also process your personal data for the purposes of fulfilling legal obligations, including tax and administrative duties, and to pursue any legitimate interest of ours or of third parties, always in compliance with the conditions and limits set by the current legislation.
Not disclosing your personal data will prevent us from completing the sales transaction since your personal information is necessary for us to fulfill the obligations arising from the existing contract, as well as to comply with legal provisions, including those dealing with tax, accounting, and administrative matters.
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.
We will process it 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 will not sell your personal data to third parties.
We will disclose your personal data only for the purposes described above to other companies within the Tod’s Group, with headquarters in countries both within and outside the European Union and the US.
Any transfers of your personal data to entities outside the European Economic Area (EEA) or the US, such transfers will be made only if the level of protection of personal data, guaranteed by the Regulation, is not compromised.
At any event, your personal data will only be processed by parties, duly instructed and able to provide adequate technical and organizational safeguards, as well as bound to the strictest confidentiality.
5. Duration of Processing
We will process your personal data at different times depending on the purpose. At any event, we will retain your personal data only for the period strictly necessary to achieve the purpose for which it was collected and processed, except when specific provisions of the law require longer retention periods.
In particular, your personal data that we will process to enable you to complete your purchase on the Store will be stored and processed until we completely fulfill all the obligations arising from the contract.
We are also required to store your personal data for a longer period of time to comply with specific provisions of the law dealing with tax, accounting and administrative matters, in the manner and time frame established by said regulations.
6. Your Rights
You have the right to access your personal data, to receive additional details on such data and its use purposes, including any third party with which such data may have been shared, to correct or update it, or to delete or transmit it in a readily useable format to you or any third party. You may also request to limit or object to its processing.
You may exercise these rights at any time by sending an email to the Data Protection Officer (DPO) at email@example.com.
Remember that you can file a complaint with competent authorities if you believe that we have violated any rules concerning the protection of personal data.