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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.

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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?

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