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Policy Ecard

Christmas card

November 2020

We would like to inform you that we 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 the service, “TOD’S E-Card Christmas” (hereinafter “Service”).

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

We will process your personal data (name and e-mail address) to comply with your request to avail of the Service, which necessitates said processing for the performance of a contract and/or adoption of pre-contractual measures at your request.

We may also process your personal data to fulfill any legal obligations 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. We will also process your personal 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, always 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 purpose 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 the period strictly necessary for us to comply with your request to avail of the Service.

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.

You may exercise these rights at any time by sending an email to the Data Protection Officer (DPO) at dataprivacyofficer@todsgroup.com.

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.

Christmas eMail

November 2020

We would like to inform you that TOD’S S.p.A. shall process your personal data and information in full compliance with the provisions of the (EU) 679/2016 General Data Protection Regulation (the “Regulation” from here on) as well as with any and all applicable local provisions on the protection of personal data

You will find all the information concerning the processing of your personal data in order to provide you with the “TOD’S E-Card Christmas” service (the “Service” from here on).

1.    Data Controller and Data Protection Officer

Tod’s S.p.A. (from here on, “Tod’s” or the “Controller”), legally headquartered in Via Filippo Della Valle 1, Sant’Elpidio A Mare, Fermo, Italy (EU) shall be the Data Controller for your personal data concerning the purpose of the processing, as detailed below.

You can contact the Data Protection Officer (the “DPO” from here on) by sending e-mail to the following address: dataprivacyofficer@todsgroup.com.

2.    Lawfulness and scope of the processing

Your personal data shall be processed by the Controller when performing the “TOD’S E-Card Christmas” service, in order to:

a)     Process the delivery request of the greeting card the sender requested Tod’s to send you, as detailed in the greeting card you received. The legal basis for such a purpose is detailed in the provisions pursuant to Art. 6, Paragraph 1, letter f) of the Regulation;

b)     Fulfil the legal obligations Tod’s is subject to. The legal basis for such a purpose is detailed in. 6, Paragraph 1, letter. c) of the Regulation;

c)      Safeguard and defend the Controller’s interests, including in a court of law. The legal basis for such a purpose is detailed in. 6, Paragraph 1, letter. f) of the Regulation.

3.    Type and source of the data being processed

In order to perform the Service, the Controller shall use the following so-called common personal data exclusively: name and e-mail address. Such personal data have been provided by the sender of the greeting card.

4.    Data Processing Modalities

We will process your personal data by means of telematic, paper and IT-based tools and such processing will be based on the principles of fairness, lawfulness and transparency in order to protect your rights and privacy. We will also process your personal data in a manner that will minimize the risk of destruction, loss and unauthorized access, or any unauthorized or non-compliant processing thereof.

5.    Disclosure and Dissemination of Personal Data

We will not disseminate your personal data.

We may disclose your personal data, always towards the aforementioned purposes, to other companies within the Tod’s Group, to other Companies, entities or consortia performing technical and organizational tasks on our behalf being consistent with achieving the aforementioned purposes, as well as to Public Authorities, following legitimate and official requests by the latter.

Any and all transfer of your personal data outside the European Economic Area shall be carried out in compliance with the applicable provisions. Indeed, such transfers shall be carried out by means of suitable safeguards, such as suitability decisions, the Standard Contractual Clauses approved by the European Commission, or through other safeguards deemed suitable.

6.    Duration of Data Processing

Your personal data shall be processed for a period not exceeding the time during which the Service is performed
Whenever the processing of your personal data is based on legal provisions or on any legitimate

interest, be it belonging to Tod’s or to third parties, the processing of your personal data shall be

exclusively limited to the time needed in order to achieve the purposes the data have been collected and/or processed for.

7.    Rights of the Data Subject

You may exercise the rights pursuant to Articles 15 – 22 of the Regulation by submitting a request in writing to the Controller. You may, therefore, receive from the Controller the confirmation of the existence of your personal data or otherwise, as well as having said data available in an intelligible form, together with the identifying details belonging to the Controller, to the Data Processors or to the subjects the data may be disclosed to. You may likewise you may obtain the update, rectification and integration of said data, obtain the erasure, the anonymization or the locking of the personal data having been processed by breaching the relevant laws, as well as object, for legitimate reasons, to the processing of your personal data.

You may exercise said rights at any time by sending an email to the Data Protection Officer (DPO) working under the Data Controller at the following address: dataprivacyofficer@todsgroup.com.

We shall implement any and all exercises of your rights within the relevant provisions of law.

Finally, we would like to remind you that you can file a complaint before the relevant Supervisory

Bodies or before the competent Judicial Authority whenever you believe Tod’s has breached any provisions concerning the protection of personal data.

Registration Christmas


November 2020

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”) 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 the service, “TOD’S E-CARD CHRISTMAS” (hereinafter “Service”).

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

Tod’s S.p.A. will process your personal data (name and e-mail address) to provide you the Service which necessitates said processing for the performance of a contract and/or adoption of pre-contractual measures at your request.

Tod’s S.p.A. will also process your personal data, but only with your explicit and specific consent, to do so to:

       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, messaging platforms or SMS/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, 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.

Providing your consent to any or both purposes is entirely optional. Likewise, a refusal to provide consent will not in any way affect  the use of the service "TOD'S E-Card Christmas".

If you decide not to give your consent to the processing of your personal data for marketing purpose, we will not be able to send you newsletters and marketing or promotional communications.

If you decide not to give your consent to the processing of your personal data for profiling purposes, this would not allow us to fulfil the purposes mentioned in the above par. ii).

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, always 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 purpose 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 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.

We will process your personal data for the period strictly necessary for us to comply with your request to avail of the Service.

If you decide to consent to processing your personal data for marketing purposes, said processing will be performed until your consent withdrawal.

If you have consented to processing your personal data for customer profiling purposes, said processing will be performed no more than 7 years from the date of consent, automatically renewed each time you make a purchase at any boutique/point of sale of the Tod’s Group, or at the web-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: dataprivacyofficer@todsgroup.com.

 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.

To learn more about how you can independently manage your data and consent

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 dataprivacyofficer@todsgroup.com, please note that each communication contains a link that you can use to:

·       stop the transmission of the received message                                      - and/or -

·       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 -

·       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.

 

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.

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