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PRIVACY POLICY

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 [Tod’s] 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 [Tod’s] 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.

Cookies

Data Controller

During the course of their normal operation, the IT systems and software procedures that are used to run this web site acquire certain personal data; the transmission of this data is an inherent feature of the use of Internet communication protocols.
This information is not collected in order to be linked to identified individuals. However, its very nature dictates that, via processing and matching with data held by third parties, it might enable users to be identified.
This category of data includes the IP addresses or domain names of the computers used by users who connect with 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 in order to gather statistical information in an anonymous form about the use of the site and to check that it is operating correctly, and is deleted immediately once it has been processed. The data could potentially be used in order to establish liability where computer crimes are committed to the prejudice of the site; save in those circumstances, web contact data is currently held for no longer than fifteen days.

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