Privacy Policy

• 1Privacy Policy Website
  Revised date: April 2020
  
  The protection of your personal data is very important to the Tod’s Group, so we pay great attention to the collection and management of the personal data that you provide us or that we automatically collect when you navigate any of our websites (hereinafter, “Site”). Thus, we adopt specific measures to guarantee its safety, confidentiality and integrity, in compliance with the provisions of EU Regulation 679/2016 (hereinafter, "Regulation"), of California Consumer Privacy Act of 2018 (CCPA) and any other specific local rules applicable to the protection of personal data.
  We will provide you with necessary additional information when we ask for your private information in some areas of the Site to help you evaluate each time if you wish to proceed with providing us your personal data for the indicated purpose of processing.

  • 1.1 Data Controller
    The data controller of your personal data is Tod’s S.p.A., with registered office at 1 Via Filippo Della Valle, Sant’Elpidio a Mare (FM), 63811 Italy (EU).  
    
    Should, concerning specific data processing purposes, Tod’s S.p.A. be joint controller with third parties, or third parties are controller for to the processing of your personal data, you will be provided with all the necessary information prior to you providing us your personal information.
     
  • 1 . 2 Personal Data
    When you navigate the Site, your personal data will be collected either automatically or when you are asked to provide them to access certain areas of the Site.
    ●    Data Collected Automatically from the Site
    Web Surfing Data – Data acquired by computer systems and software procedures involved in the normal operation of the Site and transmitted as part of the communication protocols of the Internet.
    
    To learn more
    
    Web Surfing Data
    This refers to information that, although not collected to identify you, by its very nature could lead to your identification if it were to be processed and combined with the data held by third parties. This type of data includes IP addresses or domain names of computers used for browsing and that connect to the Site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response given by the server (success, error, etc.) and other parameters relating to the operating system and IT environment.
    This data will not be disseminated but used for the sole purpose of obtaining anonymous and aggregate data on the usage of the Site and to check its correct functioning and will be retained for the time defined by the relevant legal regulation. The data could, however, be used to ascertain liability in case of possible computer crimes against the Site. Except in the latter case, the data will not be kept for more than fifteen days.
    We also ask that you read our Cookie Policy .
    
    Geolocation Data – Data relating to your physical location that is acquired by the built-in search system of the Site to obtain appropriate search results, such as the location of the nearest boutique. This data is collected only if it is used and if you provide your consent.
    Data You Voluntarily Provide
    So, you can avail of the various services offered by the Site, we will ask you, depending on the service in question, to provide us your personal data, such as your personal information, contact information (telephone numbers, email accounts, home or residence address, etc.), data relating to the payment method, information on purchases and transactions, and others. Providing us your data is entirely voluntary but in some cases failure to do so will prevent us from providing the relevant service.
    
    To learn more
    
    Data relating to Minors
    We would like to point out that the protection of children's safety and privacy is very important to the Tod's Group. Therefore, we do not intend to collect and voluntarily use the personal data of individuals below the age of sixteen (16), or below any other minimum legal age limits in force in your country of residence. Consequently, we ask that you refrain from providing us with any personal data if you are below 16 years of age or if you are not of legal age in your country of residence.
  • 1 . 3 Purpose and Legal Basis of Processing
    We will acquire and process your personal data always in compliance with the principles of lawfulness established by the law to enable us to:
    i.    guarantee the smooth navigation of the Site, which necessitates processing to navigate the Site and fulfil legal obligations;
    ii.    process your request to purchase products from the Tod’s Group or to use the services offered by the Site, which necessitates processing to execute on contractual and/or pre-contractual measures taken upon your request;
    iii.    reply to your contact requests, which necessitates processing to execute on contractual and/or pre-contractual measures taken upon your request;
    iv.    Performing marketing activities (which do not include the sale of your personal data) both via automatic means (text messages, MMSs, messaging platforms, e-mails, push notifications) and not automatic means (mail, phone with operator) , if you provide your explicit consent;
    
    To learn more
    
    Purpose of Marketing
    Marketing activities (which do not include any selling activities) can be done by sending newsletters, or through promotions, discounts, incentives, commercial information and other related means, by mail, phone call, direct sales, messaging platforms, email, automatic voice calls, text messages and/or MMSs.
    In this context, we might also process your personal data to invite you to shows and events, ask you to participate in market research or to report on special initiatives dedicated to TOD'S Group customers, in the manner and period we believe to be most effective for any of the various initiatives mentioned.
    
    v.    conduct customer profiling activities, if you provide your explicit consent.
    
    To learn more
    
    Purpose of Customer Profiling
    Customer profiling can be conducted by analysing your interests and preferences regarding our products and services, as well as your shopping habits. For example, by understanding the type and frequency of your purchases on our online store when you shop using your personal account or as a "guest,” as well as in our boutiques, we are be able to guarantee a personalized service in your future visits to the TOD'S Group boutiques.
    If you also have consented to processing your personal data for marketing purposes (which do not include the sale of your personal data), 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.
    
    Finally, we may also process your personal data to comply with any legal obligations that we may have and to pursue our rights or those of third parties, in compliance with the conditions and limits set forth by the current applicable laws.
  • 1 . 4 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 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.
  • 1 . 5 Disclosure and Dissemination of Personal Data
    We will not disseminate your personal data.
    We will not sell your personal data to third parties.
    We may disclose your personal data, but only for the purposes described above, to other companies within the Tod's Group, as well as to companies directly or indirectly controlled or owned by Tod's S.p.A., with headquarters in countries within and outside the European Union (EU) and the US.
    
    Your data may also be accessible to companies, organizations or associations that perform technical and organizational tasks on our behalf, again consistent to attaining the purposes previously described, as well as to public authorities that make it lawful and legally required.
    Any transfers of your personal data to entities outside the European Economic Area (EEA) or the US 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 be processed only by parties, duly instructed and able to provide adequate technical and organizational safeguards, as well as bound to the strictest confidentiality by the Data Controller.
  • 1 . 6 Data Retention Period
    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.
    
    To learn more
    
    Data Retention Period
    •    Data collected and processed for marketing purposes: until your consent withdrawal
    •    Data collected and processed for customer profiling purposes: 7 years from the date you gave consent, automatically renewed each time you make a purchase at any one of the boutiques/points of sale under the Tod’s Group, including its online store.
    •    Data collected and processed to access services on the Site: the retention and processing of your data will take place for the time strictly necessary to allow you access to the service requested. Your data will be stored no more than 7 years from the date you used the service in question.
    •    Data collected and processed to fulfil your request: the retention and processing of your data will take place for the time strictly necessary to respond to your contact request and/or allow us to perform any task related to such request.
    •    Data collected and processed to protect our rights or that of third parties: the retention and processing of your data will take place for the time strictly necessary to pursue these rights as they arise.
    •    Data collected and processed in compliance with legal provisions: the retention and processing of your data will take place within the time frame set by the applicable law.
    Before requesting you to provide your personal information at any area of the Site, we will provide you first with a Privacy Policy so as to make you aware and give you adequate knowledge about how we will process your personal data, as well as information on how long we will store it, should you provide your consent.
  • 1 . 7 Your Rights
    
    
    To learn more
     
    
     
  • 1 . 8 Updates to this Policy
    From time to time, we may make some changes to this Privacy Policy, for example, to fulfil new requirements set by the applicable legislation, meet technical requirements, or as a result of new services provided on the Site or by the Tod’s Group. The updated Privacy Policy will be published on this website. We may also need to contact you, if legally required, to obtain your consent and allow you to continue to use the services of the Site. We therefore ask that you to visit this page periodically.

• 2Privacy Policy Check Out
  January 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”), 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”).
  
  This Privacy Policy supplements the Privacy Policy of the Site , which we will refer to for anything not fully explained here.

  • 1. 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.
    
    To learn more about the Store
    
    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. 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.
  • 2. 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.
  • 2. 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 bot
    h within and outside the European Union and the US.
    Your data may also be accessible to companies, organizations or associations that perform technical and organizational tasks on our behalf, again consistent with attaining the purposes previously described. For instance, but not limited to the disclosure of your personal data, to the extent strictly necessary, to professional operators who perform checks on our behalf to prevent fraud in electronic payment systems (for more details please read the privacy policy of our service provider, Forter, at: https://www.forter.com/service-privacy-policy/).
    
    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.
  • 2. 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 o
    f 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.
  • 2. 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 dataprivacyofficer@todsgroup.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.
  • 2.7 Updates to the Privacy Policy herein
    We may periodically update the Privacy Policy herein.  Please reference the “LAST UPDATED IN” legend at the top of this page to see when the Privacy Policy herein was last revised.
    
     

• 3Privacy Policy Personal Accounts
  Revised date: April 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”), of California Consumer Privacy Act of 2018 (CCPA) and any other specific local rules applicable to the protection of personal data.
  
  Below you will find all the information regarding our processing of your personal data to allow you to create your own personal page and avail of the services reserved for account holders on our website (hereinafter, “Site”).
  
  This Privacy Policy supplements the Privacy Policy of the Site , which we will refer to for anything not fully explained here.
  
  Do not provide us your personal data if you are not at least 16 years old or not of legal age
  
  We would like to point out that the protection of children's safety and privacy is very important to the Tod's Group. Therefore, we do not intend to collect and voluntarily use the personal data of individuals below the age of sixteen (16), or below any other minimum legal age limits in force in your country of residence. Consequently, we ask that you refrain from providing us with any personal data if you are below 16 years of age or if you are not of legal age in your country of residence.

  • 3 . 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, S. Elpidio a Mare FM – Italy (EU).
  • 3 . 2 Lawfulness and Purposes of Processing
    Tod’s S.p.A. will process your personal data to provide you the services reserved for personal account holders, which necessitates said processing for the performance of a contract and/or adoption of pre-contractual measures at your request. Failure to disclose certain personal data could in some cases prevent you from using specific services at all or from using them to the full extent.
    
    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 (which do not include the sale of your personal data) 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 (which do not include the sale of your personal data), 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 of these purposes is entirely optional. Likewise, a refusal to provide consent will not in any way affect any existing relationship with the Tod’s Group, or the successful creation of your personal account on our Site.
    
    To learn more about how we ask for consent
    
    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 which do not include the sale of your personal data), 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 and to pursue our rights or those of third parties, in compliance with the conditions and limits set forth by the current applicable laws.
  • 3 . 3 Personal data Processing and Security
    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.
  • 3 . 4 Personal data Disclosure and Transfer
    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, therefore including companies directly or indirectly controlled or owned by Tod’s S.p.A., with headquarters in countries both within and outside the European Union or the US.
    
    Your data may also be accessible to 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 transfers of your personal data to entities outside the European Economic Area (EEA) or the US 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 by the Data Controller.
  • 3 . 5 Retention of personal data
    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.
    
    Your personal data, processed to create a personal account and to use the services reserved for personal account holders will be kept and processed until you close your personal account. Also, your personal data will be deleted automatically (or made anonymous) after 7 years from the last time you interacted with your personal account (for instance, when you access or update your data, create new orders, etc.).
    
    To learn more about the automatic expiration of your account
    
    To protect you further, near the end of the 7-year time frame as mentioned above, we will notify you that your account is soon to expire. If you wish to keep your personal account active, you need only to interact with it.
    
    If you decide to consent to processing your personal data for marketing purposes (which do not include the sale of your personal data), 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 Store.
    
    If the processing of your personal data is based on legal provisions or on any our rights or those 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.
  • 3 . 6 Your Rights
    You have the right to access your personal data, to request disclosure of such data and additional details, including its use purposes and any third parties 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.
    
    Especially with regards to processing for marketing and/or customer profiling purposes (which do not include the sale of your personal data), 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
    
    Remember that through your personal account you are always free to correct and/or update your personal data once your account is created and on your own, withdraw (or provide) your consent to process your personal data for marketing and/or customer profiling purposes (which do not include the sale of your personal data) if you so wish.
    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:
    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.
    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 competent authorities if you believe that we have violated any rules concerning the protection of personal data.
  • 3.7 Privacy personal account
    We may periodically update the Privacy Policy herein.  Please reference the “LAST UPDATED IN” legend at the top of this page to see when the Privacy Policy herein was last revised.

• 4Privacy Policy Marketing Communication
  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”), of California Consumer Privacy Act of 2018 (CCPA) and any other specific local rules applicable 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 service.
  
  This Privacy Policy supplements the Privacy Policy of the Site , which we will refer to for anything not fully explained here.

  • 4 . 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. (hereinafter referred to as “Tod’s”, “we”, “us” or “our”), having its registered office in Via Filippo Della Valle, 1, Sant’Elpidio a Mare, (FM) - Italy (EU).
  • 4 . 2 Lawfulness and Purposes of Processing
    We will process your personal data but only with your explicit and specific consent to do so to:
    i.    conduct marketing activities (which do not include selling 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, 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 (which do not include the sale of your personal data), 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).
    
    To learn more about how we ask for consent
    
     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 which do not include the sale of your personal data), 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 our rights or of third parties, in compliance with the conditions and limits set forth by the current applicable laws.
  • 4 . 3 Personal data Processing and Security
    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 . 4 Personal data Disclosure and Transfer
    We will not disseminate your personal data.
    
    We will not sell your personal data to any third parties.
    
    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 transfers of your personal data outside the European Economic Area (EEA) or the US will take place only if the country of destination guarantees the same level of protection of personal data as that in the European Union (EU).
  • 4 . 5 Retention of personal data
    We will process your personal data for marketing purposes (which do not include the sale of your personal data) 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 of our rights 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.
  • 4 . 6 Your Rights
    You have the right to access your personal data, to request disclosure of such data and additional details, including its use purposes and any third parties 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.
    Especially with regards to processing for marketing and/or customer profiling purposes (which do not include the sale of your personal data), 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 managing your consent independently
    
    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:
    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 competent authorities if you believe that we have violated any rules concerning the protection of personal data.
  • 4.7 Updates to the Privacy Policy herein
    We may periodically update the Privacy Policy herein.  Please reference the “LAST UPDATED IN” legend at the top of this page to see when the Privacy Policy herein was last revised.
    
     

• 5Privacy Policy Contact Request
  January 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”), of California Consumer Privacy Act of 2018 (CCPA) and any other specific local rules applicable to the protection of personal data.
  
  Below you will find all the information regarding our processing of your personal data when you complete this contact request form.
  
  This Privacy Policy supplements the Privacy Policy of the Site , which we will refer to for anything not fully explained here

  • 5 . 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, S. Elpidio a Mare FM – Italy (EU).
  • 5 . 2 Lawfulness and Purposes of Processing
    We will process your personal data to enable us to respond to your contact request, 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 of our rights or of third parties, in compliance with the conditions and constraints set by the current legislation.
  • 5 . 3 Personal data Processing and Security
    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.
  • 5 . 4 Personal data Disclosure and Transfer
    We will not disseminate your personal data.
    We will not sell your personal data to third parties.
    
    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 purposes previously described, as well as to public authorities that make it lawful and legally required. Any transfers of your personal data outside the European Economic Area (EEA) or the US will take place only if the country of destination guarantees the same level of protection of personal data as that in the European Union (EU).
  • 5 . 5 Retention of personal data
    We will process your personal data for the period strictly necessary to respond to your contact request and to perform any task and operation related to your request. If the processing of your personal data is based on legal provisions or on any of our rights 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.
  • 5 . 6 Your Rights
    You have the right to access your personal data, request disclosure of such data and additional details, including its use purposes and any third parties 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 dataprivacyofficer@todsgroup.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.
  • 5.7 Updates to the Privacy Policy herein
    We may periodically update the Privacy Policy herein.  Please reference the “LAST UPDATED IN” legend at the top of this page to see when the Privacy Policy herein was last revised.
    
     

• 6Privacy Policy Website Services
  January 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”), of California Consumer Privacy Act of 2018 (CCPA) and any other specific local rules applicable to the protection of personal data.
  
  Below you will find all the information regarding our processing of your personal data when you contact our operators.
  This Privacy Policy supplements the Privacy Policy of the Site , which we will refer to for anything not fully explained here.

  • 6 . 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, S. Elpidio a Mare FM – Italy (EU).
  • 6 . 2 Lawfulness and Purposes of Processing
    We will process your personal data to enable us to respond to your contact request, 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 of our rights or of third parties, in compliance with the conditions and constraints set by the current legislation.
  • 6 . 3 Personal data Processing and Security
    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.
  • 6 . 4 Personal data Disclosure and Transfer
    We will not disseminate your personal data.
    We will not sell your personal data to third parties.
    
    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 purposes previously described, as well as to public authorities that make it lawful and legally required. Any transfers of your personal data outside the European Economic Area (EEA) or the US will take place only if the country of destination guarantees the same level of protection of personal data as that in the European Union (EU).
  • 6 . 5 Retention of personal data
    We will process your personal data for the period strictly necessary to respond to your contact request and to perform any task and operation related to your request.
    
    If the processing of your personal data is based on legal provisions or on any of our rights 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 . 6 Your Rights
    You have the right to access your personal data, request disclosure of such data and additional details, including its use purposes and any third parties 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 dataprivacyofficer@todsgroup.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.
  • 6. 7 Updates to the Privacy Policy herein
    We may periodically update the Privacy Policy herein.  Please reference the “LAST UPDATED IN” legend at the top of this page to see when the Privacy Policy herein was last revised.
    
     

• 7Privacy Policy Abandoned Cart
  INFORMATION ON THE PROCESSING OF YOUR PERSONAL DATA
  
  The Tod’s Group recognizes the importance of security surrounding your personal data, and it’s for this reason that we pay special attention to the collection and management of the data that you supply us with, by adopting special measures that guarantee security, discretion and integrity, in accordance with EU Standard 679/2016 (Standard) and of other, eventual and applicable local legislation, created for the protection of your personal data.
  
  The following policy is part of the General Website Privacy Policy , to which you should refer, if you require further information.
  
   

  • 7 . 1 Data Controller
    The data controller is Tod’s S.p.A., with legal headquarters in via Filippo Della Valle, 1 – 63811 Sant’Elpidio a Mare (FM), Italy.
  • 7 .2 Scope and legal requirements for the processing of your personal data
    The personal data that you supply us with, will be solely processed with the intention to offer you a “reminder” service, should you choose to save item(s) in your “virtual shopping bag” on our online store but are yet to complete the “checkout” process; the transmission in 30 days following this, of 2 communications to your email address as a reminder will allow you, should you choose too, complete the “checkout” process that was initially started. The processing of your personal data will exclusively occur with your explicit consent, in accordance with legislation as set in art. 6.1a) of the Standard and will include all activities necessary to successfully supply the described service. Furthermore, where necessary, we reserve the right to process your personal data, based on our or third parties’ legitimate interests, as set under art. 6.1f) of the Standard.
  • 7 . 3 Processing Duration
    Your personal data will be stored for a period not exceeding 32 days from the date that this permission is granted. Where processing occurs under the provisions of the Law or under our, or third parties’ legitimate interests, the handling of your personal information will be exclusively limited to the time necessary to process such information.
  • 7. 4 Communication and Distribution of Personal Data
    Your personal data will not be subject to dissemination. Your personal data may be passed on, exclusively for the methods as described above, to other brands within the Tod’s Group, to other companies, entities or associations that fall under the group, for a technical nature, coherent to the pursuit of previously described procedures
  • 7. 5 Processing Procedures
    Data processing and handling will be made using telematic, paper and IT services; which will be handled correctly, legally, transparently and with respect for your rights and privacy. Data will be processed in a manner that is safe from access by unauthorized parties, any eventual loss or damages and from incorrect handling methods.
  • 7. 6 Rights of Account Holder
    You have the right to obtain access to your personal information, including rectifications or integrations and the cancellation of that information; you may obtain the limitations of handling or oppose any handling of such information. A full list of your rights can be requested at any time, by writing to our Data Protection Officer (DPO), at the following email address: dataprivacyofficer@todsgroup.com. Lastly, we’d like to remind you, should you be subject to a violation, by us, of your rights and standards regarding the protection of your personal information that you may file any complaints to the Supervisory Authority.