我们想指出的是保护儿童的安全和隐私对Tod's集团非常重要。因此，对于未满16岁者，或未达到您居住国其他有效的法定最低年龄者，我们不打算收集并自愿使用其个人数据。因此，如果您未满16岁或未达到您在居住国的法定年龄，请不要向我们提供任何个人数据。

d.       根据欧盟条例第6.1（f）条，按照现行法律规定的条件和限制，追求我们的合法权益（即改善我们的业务流程、预防欺诈、行使并捍卫我们的权利等）。

尤其是可以通过自动化方式，例如通过比较分析您的购买行为（类型、数量、频率、时间等），以及通过分析您在特定时间段内要求的产品信息的类型和数量，对您的数据进行处理并进行客户分析。我们处理您的个人数据时，将最大限度地减少销毁、丢失和擅自访问您的数据或对您的数据进行未经授权或不合规处理的风险。

如果法律有要求，我们也可能需要与您联系，以便获得您的同意，并允许您继续使用本网站提供的服务。本隐私政策与我们提供给您的、要求您向我们提供个人数据的其他隐私政策有不一致之处的，以后者为准。

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).
 

Unless specified otherwise within the Privacy Policy herein, we collect and process the personal data you provide; we shall not obtain your personal data from any third party. “Personal data” pertains to any information concerning an identified or identifiable natural person (the ‘data subject’).
Your personal data (e.g. your name, surname, delivery address, e-mail address, and the like.), shall be processed pursuant to art. 6.1 (b) of Regulation, in order to allow you to purchase products on our E-Store, as well as to fulfil our contractual obligations.
We would like to point out that we shall NOT process your payment information (i.e. your credit card number) in any way.
Failing to disclose your personal data and information will not allow to complete your purchasing process, since such information is necessary to allow us to fulfil our contractual obligations, as well as to comply with the legislation, including the fiscal, bookkeeping and administrative obligations.
Finally, we may also process your personal data in order to comply with any legal obligations that we may have, pursuant to art. 6.1 (c) of Regulation, or to pursue any legitimate interest, be it ours or belonging to third parties (i.e. optimising the purchasing procedures, preventing frauds, exercising and defending a right of ours, improving the shopping experience), pursuant to art. 6.1 (f) of the Regulation, in compliance with the conditions and limits set by the legislation currently in force.

We shall process your personal data both by means of paper- and IT-based tools, and such processing shall be based on the principles of fairness, lawfulness, and transparency, in order to protect your rights and privacy.
We make use of industry-standard physical, organizational, contractual and technological security measures to protect your personal data from unauthorized access, public disclosure, use, modification, damage or loss.

We shall not disseminate your personal data.
To the extent permitted by law and where required with your consent, your Personal information may be disclosed, for the purposes described in the Privacy Policy herein:
i.    to our service providers, including other companies of Tod’s Group, performing technical and organizational tasks on our behalf (i.e. delivery and logistics services, IT technical support, fraud prevention in the electronic payment system [for further information, please see: https://www.forter.com/service-privacy-policy] , customers support, and the like), again pursuant with achieving the purposes described in the Privacy Policy herein;
ii.    to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other shift in all or in any given part of our business, assets or stock (also in connection with bankruptcy or similar outcomes);
iii.    in connection with the essential purposes described above (that is to say in order to comply with legal obligations or to execute a lawful request of public authorities).
We also undertake to carry out, in accordance with laws in force, any possible prior risk assessment concerning the data transfer; adopting, if necessary, any additional security measures, complementary to the safeguards guaranteed by the aforementioned transfer mechanisms.
At any rate, we shall transfer your personal information, only if the protection level, guarantee by the Regulation, is not compromised.
Should an adequacy decision pursuant to art. 45(3), or of appropriate safeguards pursuant to art. 46 of Regulation, including binding corporate rules, be absent, we may transfer your personal data only if:
i.    you have explicitly provided your consent to the proposed transfer   after having been informed of the possible risks of such transfers due to the absence of an adequacy decision and of appropriate safeguards;
ii.    the transfer is necessary for the performance of    a contract  you are involved in, or  for  the implementation of pre-contractual measures taken at your request;
iii.    the transfer is necessary for the conclusion    or the performance of a contract, concluded in your interest, between us and another natural or legal person.
Your personal data shall only be processed by parties being duly instructed and able to provide adequate technical and organizational safeguards, as well as bound to the strictest confidentiality by us.

We shall process your personal data at different times depending on the purpose.
Your personal data that we will process to enable you to complete your purchases on the E-Store shall be stored and processed until we completely fulfil all the obligations arising from the contract.
We would also like to inform you that we are further required to store your personal data in order to comply with specific law provisions dealing with fiscal, accounting and administrative matters, in the manner and   within the  timeframe established by said regulations.
Should the processing of your personal data be based on any legitimate interest, be it ours or belonging to third parties, the processing of your personal data shall be strictly limited to the time required to achieve the legitimate interest, on a case-by-case basis.

You have the right, as detailed within the law in force, to access your personal data, to correct or update it, to delete or to obtain a copy or the transmission in a structured format to any third party thereof. You may also request to limit or object to such processing.
You may exercise these rights at any time, by writing to our Data Protection Officer (DPO) to the following addresses:
•    by e-mail: dataprivacyofficer@todsgroup.com.
•    by post: Data Protection Officer - Tod's S.p.A., Via Filippo Della Valle n. 1, 63811 Sant’Elpidio a Mare (FM) – Italy (EU).
We would like to inform you that we shall not discriminate against you, should you exercise one or more of your privacy rights acknowledged by the relevant legislation; such an exercise shall have no impact on the purchasing of our products or on any existing relationships with the Company.
We will make sure to comply with your request to exercise your rights, always within the terms of the law.
We shall retain the right to ask you, in the ways we deem appropriate, for specific information to help us confirm your identity and be reasonably certain that only you can access your personal data and no unauthorized third party can seize, change or delete them. The processing of your request is free of charge. However, should your requests be manifestly unfounded, excessive, or repetitive in nature, we shall retain the right to refuse to comply with them or to request suitable economic contributions for them.
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.

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.

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).

We shall process your personal data both by means of paper- and IT-based tools, and such processing shall be based on the principles of fairness, lawfulness, and transparency, in order to protect your rights and privacy.
In particular, the processing of your data, involving profiling purposes as well, may be automated, for example through a comparative analysis of your purchases (by type, quantity, frequency, timing, and the like), and by analysing the type and number of your requests for product information within a given timeframe.
We make use of industry-standard physical, organizational, contractual and technological security measures to protect your personal data from unauthorized access, public disclosure, use, modification, damage or loss.

We shall not disseminate your personal data.
To the extent permitted by law and where required with your consent, your Personal information may be disclosed, for the purposes described in the Privacy Policy herein:
i.    with our service providers, included other companies belonging to Tod’s Group who perform technical and organizational tasks on our behalf, always in compliance with achieving the purposes described above;
ii.    with other belonging to Tod’s Group acting on our behalf:
a.    in order to involve you in local marketing initiatives (marketing purpose);
b.    to provide you with a tailored service and a better purchasing experience when you visit the Tod’s Group shops;
iii.    to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other shift in all or in any given part of our business, assets or stock (also in connection with bankruptcy or similar outcomes);
iv.    in connection with the essential purposes described above (that is to say in order to comply with legal obligations or to execute a lawful request of public authorities).
We guarantee that we shall transfer your personal data towards a country outside the European Economic Area (EEA) not having an Adequacy Decision by the European Commission (EC), only after the adoption of at least one of the  cross-border transfer mechanisms the Regulation recognizes as being able to ensure an adequate protection of the personal data being transferred:
i.    specific  “Standard Contractual Clauses” are to be drafted, issued by the European Commission, in order to ensure that the protection level of the personal data processed by our partners outside the EU shall comply with the EU's data protection level;
ii.    adoption of Company Binding Rules, approved by the competent Public Authorities, in compliance with the data transfer within a group of undertakings or enterprises is done through binding corporate rules, approved by the competent data protection authority in the UE, pursuant to the consistency mechanism referred to in art. 63 and to the conditions detailed under art. 47 of the Regulation.
We also undertake to carry out, in accordance with laws in force, any possible prior risk assessment concerning the data transfer; adopting, if necessary, any additional security measures, complementary to the safeguards guaranteed by the aforementioned transfer mechanisms.
At any rate, we shall transfer your personal information, only if the protection level, guarantee by the Regulation, is not compromised.
Your personal data shall only be processed by parties being duly instructed and able to provide adequate technical and organizational safeguards, as well as bound to the strictest confidentiality by us.

We shall process your personal data at different times depending on the purpose.
Your personal data, processed for the creation of your Personal Account and for the usage of services reserved to the owners of company accounts, shall be retained and processed until you delete your Personal Account. We would like to inform you that your personal data shall be automatically erased (or anonymised) once 7 years have passed since your last interaction with your Personal Account (i.e. when you log in to or update your personal data, place new purchases, and the like).

To learn more about the automatic expiration of your Personal 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.

Should you consent to the processing your personal data for marketing purposes, said processing will be performed until your consent withdrawal.
Should you provide your consent to the processing of your personal data for profiling purposes, said processing shall be performed for no longer than 7 years since the date when you provided your consent, and be automatically renewed each time you make a purchase at any boutique/point of sale belonging to Tod’s Group, or at our E-Store.
We would also like to inform you that we are further required to store your personal data in order to comply with specific law provisions, in the manner and within the timeframe established by said regulations.
Should the processing of your personal data be based on any legitimate interest, be it ours or belonging to third parties, the processing of your personal data shall be strictly limited to the time required to achieve the legitimate interest, on a case-by-case basis.

You have the right, as detailed within the law in force, to access your personal data, to correct or update it, to delete or to obtain a copy or the transmission in a structured format to any third party thereof. You may also request to limit or object to such processing.
Concerning the processing of personal data for marketing and/or customer profiling purposes, we would like to stress the fact that you may exercise your right to withdraw the consent you have provided us with at any time.
You may oppose the reception of direct marketing communications (also known as an opt-out) both via automatic means (text messages, MMS, messaging platforms, e-mail messages and push notifications) and traditional means (such as post, 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 at any time.
You may exercise these rights at any time, by writing to our Data Protection Officer (DPO) to the following addresses:
•    by e-mail: dataprivacyofficer@todsgroup.com.
•    by post: Data Protection Officer - Tod's S.p.A., Via Filippo Della Valle n. 1, 63811 Sant’Elpidio a Mare (FM) – Italy (EU).

To learn more about how you can manage your consents (also known as opt-out)
Without prejudice to your right to withdraw (also known as an opt-out) the consent to the processing of your personal data for marketing and/or profiling activities by writing to the aforementioned addresses, please note that each marketing communication contains tools that you can use to:
i.    inhibit the contact-channel (e.g., e-mail and SMS messages) by means of the which our marketing communications are sent;
ii.    withdraw your consent (also known as an opt-out) to the processing of your personal data for marketing purposes. In such cases, we shall not send advertising and/or promotional communication to you anymore and any and all newsletters related to any brand of the Tod's Group shall be automatically disabled;
iii.    withdraw your consent to the profiling activities.
Moreover, every newsletter of ours features a tool by means of which you can unsubscribe from it. In so doing, you shall no longer receive the periodical newsletter, but you will keep receiving our other marketing updates.

We would like to point out that we  shall not discriminate against you, should you exercise one or more privacy rights acknowledged within the legislation; any existing relationships with the Tod’s Group, or your Personal Account creation, or the usage of the services thereof, shall not be affected.
We will make sure to comply with your request to exercise your rights, always within the terms of the law.
We shall retain the right to ask you, in the ways we deem appropriate, for specific information to help us confirm your identity and be reasonably certain that only you can access your personal data and no unauthorized third party can seize, change or delete them. The processing of your request is free of charge. However, should your requests be manifestly unfounded, excessive, or repetitive in nature, we shall retain the right to refuse to comply with them or to request suitable economic contributions for them.
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.
 

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.

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).

Unless specified otherwise within the Privacy Policy herein, we collect and process the personal data you provide; we shall not obtain your personal data from any third party. “Personal data” pertains to any information concerning an identified or identifiable natural person (the ‘data subject’).
Tod’s S.p.A., pursuant to art. 6.1 (a) of Regulation, shall process your personal data (such as your name, surname, e-mail account, gender, and the like), with your explicit and specific consent to do so, in order to:
i.    perform marketing activities through newsletters, promotions, discounts, incentives, commercial information, and other related marketing schemes, by means of post, phone calls, direct sales, email, automatic voice calls, messaging platforms or SMS/MMS, messages and to send invitations for shows or events, perform market research and send notifications on special initiatives focused on the customers of TOD’S Group. In addition to the email address, in accordance with the marketing procedure that we will adopt, we may use complementary communication channels and tools (such as telephone, post, and the like), corresponding to the contact information you have provided or will provide to us in the future;
ii.    perform customer profiling activities, such as analysing 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. Should you provide your consent for us to process your personal data for profiling purpose, you consent that we can obtain from our local subsidiaries the information concerning the purchases you made at their points of sale. Likewise, if you have also given your consent to the processing of your personal data for marketing purposes, we will be able to send you promotional information and/or invitations to initiatives that best fit your profile, preferences and expectations as a shopper.

Learn more about how we ask for your consent

We will ask you to provide your explicit consent to the processing of your personal data by ticking the specific boxes concerning marketing purposes and profiling purposes. If you
a.    tick the corresponding box, we will process your personal data for the chosen purpose (marketing or profiling);
b.    don’t’ tick the corresponding box, we will comply with the situation previously in force:
•    if you had previously consented to the processing of your personal data (ex through other on-line forms or by means of the coupons available in our boutiques) for such purposes (i.e., marketing or profiling), we will continue to do so;
•    if you never consented to the processing your personal data for such specific purposes (i.e., marketing or profiling), we shall not process your personal data for said purposes (i.e., marketing or profiling).
You have the right to withdraw your consent(s) at any time, (also known as the “right to opt-out”), by following the instructions indicated in the Privacy Policy herein.

The provision of any and all personal data is voluntary. However, failure to disclose certain personal data could prevent you from being fully involved in our marketing and profiling initiatives in some cases.
Please note that, should you decide not to give your consent to the processing of your personal  information for marketing purposes, we will not be able to send you our promotional communications, including our periodical newsletter update service.  
Should you decide not to give your consent to the processing of your personal data for profiling purposes, this shall have no impact on your involvement in our promotional communications plan, but this would simply not allow us to fulfil the purposes detailed within point ii) above.
Finally, we may also process your personal data in order to comply with any legal obligations that we may have, pursuant to art. 6.1 (c) of Regulation, or to pursue any our legitimate interests (i.e. improving business processes, preventing frauds, exercising and defending a right of ours or optimising our customer contact strategies), pursuant to art. 6.1 (f) of  the Regulation, in compliance with the conditions and limits set by the legislation currently in force.

 

We shall process your personal data both by means of paper- and IT-based tools, and such processing shall be based on the principles of fairness, lawfulness, and transparency, in order to protect your rights and privacy.
In particular, the processing of your data, involving profiling purposes as well, may be automated, for example through a comparative analysis of your purchases (by type, quantity, frequency, timing, and the like), and by analysing the type and number of your requests for product information within a given timeframe.
We make use of industry-standard physical, organizational, contractual and technological security measures to protect your personal data from unauthorized access, public disclosure, use, modification, damage or loss.

We shall not disseminate your personal data.
To the extent permitted by law and where required with your consent, your Personal information may be disclosed, for the purposes described in the Privacy Policy herein:
i.    with our service providers, included other companies belonging to Tod’s Group who perform technical and organizational tasks on our behalf, always in compliance with achieving the purposes described above;
ii.    with other belonging to Tod’s Group acting on our behalf:
a.    in order to involve you in local marketing initiatives (marketing purpose);
b.    to provide you with a tailored service and a better purchasing experience when you visit the Tod’s Group shops;
iii.    to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other shift in all or in any given part of our business, assets or stock (also in connection with bankruptcy or similar outcomes);
iv.    in connection with the essential purposes described above (that is to say in order to comply with legal obligations or to execute a lawful request of public authorities).
We guarantee that we shall transfer your personal data towards a country outside the European Economic Area (EEA) not having an Adequacy Decision by the European Commission (EC), only after the adoption of at least one of the  cross-border transfer mechanisms the Regulation recognizes as being able to ensure an adequate protection of the personal data being transferred:
i.    specific  “Standard Contractual Clauses” are to be drafted, issued by the European Commission, in order to ensure that the protection level of the personal data processed by our partners outside the EU shall comply with the EU's data protection level;
ii.    adoption of Company Binding Rules, approved by the competent Public Authorities, in compliance with the data transfer within a group of undertakings or enterprises is done through binding corporate rules, approved by the competent data protection authority in the UE, pursuant to the consistency mechanism referred to in art. 63 and to the conditions detailed under art. 47 of the Regulation.
We also undertake to carry out, in accordance with laws in force, any possible prior risk assessment concerning the data transfer; adopting, if necessary, any additional security measures, complementary to the safeguards guaranteed by the aforementioned transfer mechanisms.
At any rate, we shall transfer your personal information, only if the protection level, guarantee by the Regulation, is not compromised.
Your personal data shall only be processed by parties being duly instructed and able to provide adequate technical and organizational safeguards, as well as bound to the strictest confidentiality by us.

We shall process your personal data at different times depending on the purpose.
Should you consent to the processing your personal data for marketing purposes, said processing will be performed until your consent withdrawal.
Should you provide your consent to the processing of your personal data for profiling purposes, said processing shall be performed for no longer than 7 years since the date when you provided your consent, and be automatically renewed each time you make a purchase at any boutique/point of sale belonging to Tod’s Group, or at our E-Store.
We would also like to inform you that we are further required to store your personal data in order to comply with specific law provisions, in the manner and within the timeframe established by said regulations.
Should the processing of your personal data be based on any legitimate interest, be it ours or belonging to third parties, the processing of your personal data shall be strictly limited to the time required to achieve the legitimate interest, on a case-by-case basis.

You have the right, as detailed within the law in force, to access your personal data, to correct or update it, to delete or to obtain a copy or the transmission in a structured format to any third party thereof. You may also request to limit or object to such processing.
Concerning the processing of personal data for marketing and/or customer profiling purposes, we would like to stress the fact that you may exercise your right to withdraw the consent you have provided us with at any time.
You may oppose the reception of direct marketing communications (also known as an opt-out) both via automatic means (text messages, MMS, messaging platforms, e-mail messages and push notifications) and traditional means (such as post, 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 at any time.
You may exercise these rights at any time, by writing to our Data Protection Officer (DPO) to the following addresses:
•    by e-mail: dataprivacyofficer@todsgroup.com.
•    by post: Data Protection Officer - Tod's S.p.A., Via Filippo Della Valle n. 1, 63811 Sant’Elpidio a Mare (FM) – Italy (EU). 

To learn more about how you can manage your consents (also known as opt-out)

Without prejudice to your right to withdraw (also known as an opt-out) the consent to the processing of your personal data for marketing and/or profiling activities by writing to the aforementioned addresses, please note that each marketing communication contains tools that you can use to:
i.    inhibit the contact-channel (e.g., e-mail and SMS messages) by means of the which our marketing communications are sent;
ii.    withdraw your consent (also known as an opt-out) to the processing of your personal data for marketing purposes. In such cases, we shall not send advertising and/or promotional communication to you anymore and any and all newsletters related to any brand of the Tod's Group shall be automatically disabled;
iii.    withdraw your consent to the profiling activities.
Moreover, every newsletter of ours features a tool by means of which you can unsubscribe from it. In so doing, you shall no longer receive the periodical newsletter, but you will keep receiving our other marketing updates.

We would like to inform you that we shall not discriminate against you, should you exercise one or more of your privacy rights acknowledged by the relevant legislation.
We will make sure to comply with your request to exercise your rights, always within the terms of the law.
We shall retain the right to ask you, in the ways we deem appropriate, for specific information to help us confirm your identity and be reasonably certain that only you can access your personal data and no unauthorized third party can seize, change or delete them. The processing of your request is free of charge. However, should your requests be manifestly unfounded, excessive, or repetitive in nature, we shall retain the right to refuse to comply with them or to request suitable economic contributions for them.
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.
 

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.

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).

Unless specified otherwise within the Privacy Policy herein, we collect and process the personal data you provide; we shall not obtain your personal data from any third party. “Personal data” pertains to any information concerning an identified or identifiable natural person (the ‘data subject’).
Your personal data and information (e.g. your name, surname, e-mail address, telephone number, and the like),  shall be processed pursuant to art. 6.1 (b) of the Regulation, shall be used in order to provide you with feedback to your contact request and provide you with the support you need.
Any and all personal data and information we require when you fill in the online form and/or which will be requested by our operators are essential to the processing of your request; therefore, your failure to communicate such information may prevent us from going through with your request for support.
Finally, we reserve the right process your personal data in order to comply with any legal obligations we may be subject, pursuant to art. 6.1 (c) of the Regulation, or to pursue any legitimate interest, be it ours or belonging to third parties (i.e. optimising the customer care service, preventing frauds, exercising and  defending a right  of ours or improving the business processes), pursuant to art. 6.1 (f) of  the Regulation, in compliance with the conditions and limits set by the legislation currently in force.

We shall process your personal data both by means of paper- and IT-based tools, and such processing shall be based on the principles of fairness, lawfulness, and transparency, in order to protect your rights and privacy.

We shall not disseminate your personal data.
To the extent permitted by law and where required with your consent, your Personal information may be disclosed, for the purposes described in the Privacy Policy herein:
i.    to  our service providers, including other companies of Tod’s Group, performing technical and organizational tasks on our behalf (i.e.   IT support services , delivery and logistics services, customer support, processing, or hosting services, etcetera);
ii.    to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other shift in all or in any given part of our business, assets or stock (also in connection with bankruptcy or similar outcomes);
iii.    in connection with the essential purposes described above (that is to say in order to comply with legal obligations or to execute a lawful request of public authorities).
We guarantee that we shall transfer your personal data towards a country outside the European Economic Area (EEA) not having an Adequacy Decision by the European Commission (EC), only after the adoption of at least one of the  cross-border transfer mechanisms the Regulation recognizes as being able to ensure an adequate protection of the personal data being transferred:
i.    specific  “Standard Contractual Clauses” are to be drafted, issued by the European Commission, in order to ensure that the protection level of the personal data processed by our partners outside the EU shall comply with the EU's data protection level;
ii.    adoption of Company Binding Rules, approved by the competent Public Authorities, in compliance with the data transfer within a group of undertakings or enterprises is done through binding corporate rules, approved by the competent data protection authorit
We also undertake to carry out, in accordance with laws in force, any possible prior risk assessment concerning the data transfer; adopting, if necessary, any additional security measures, complementary to the safeguards guaranteed by the aforementioned transfer mechanisms.
At any rate, we shall transfer your personal information, only if the protection level, guarantee by the Regulation, is not compromised.
Your personal data shall only be processed by parties being duly instructed and able to provide adequate technical and organizational safeguards, as well as bound to the strictest confidentiality by us.

We shall process your personal data at different times depending on the purpose.
We will process your personal data for the period strictly necessary to follow through with your support request and to perform any task and operation arising from your request.
We would also like to inform you that we are further required to store your personal data in order to comply with specific law provisions, in the manner and within the timeframe established by said regulations.
Should the processing of your personal data be based on any legitimate interest, be it ours or belonging to third parties, the processing of your personal data shall be strictly limited to the time required to achieve the legitimate interest, on a case-by-case basis.

You have the right, as detailed within the law in force, to access your personal data, to correct or update it, to delete or to obtain a copy or the transmission in a structured format to any third party thereof. You may also request to limit or object to such processing.
You may exercise these rights at any time, by writing to our Data Protection Officer (DPO) to the following addresses:
•    by e-mail: dataprivacyofficer@todsgroup.com.
•    by post: Data Protection Officer - Tod's S.p.A., Via Filippo Della Valle n. 1, 63811 Sant’Elpidio a Mare (FM) – Italy (EU).  
We would like to point out that, should you exercise one or more of the privacy rights acknowledged by the relevant legislation we shall not discriminate against you, and such activities shall have no impact on the support services given, nor on any relationship of yours with Tod’s Group.
We will make sure to comply with your request to exercise your rights, always within the terms of the law.
We shall retain the right to ask you, in the ways we deem appropriate, for specific information to help us confirm your identity and be reasonably certain that only you can access your personal data and no unauthorized third party can seize, change or delete them. The processing of your request is free of charge. However, should your requests be manifestly unfounded, excessive, or repetitive in nature, we shall retain the right to refuse to comply with them or to request suitable economic contributions for them.
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.

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.

We shall process your personal data both by means of paper- and IT-based tools, and such processing shall be based on the principles of fairness, lawfulness, and transparency, in order to protect your rights and privacy.
We make use of industry-standard physical, organizational, contractual and technological security measures to protect your personal data from unauthorized access, public disclosure, use, modification, damage or loss.
 

We shall not disseminate your personal data.
To the extent permitted by law and where required with your consent, your Personal information may be disclosed, for the purposes described in the Privacy Policy herein:
i.    to  our service providers, including other companies of Tod’s Group, performing technical and organizational tasks on our behalf (i.e.   IT support services , delivery and logistics services, customer support, processing, or hosting services, etcetera);
ii.    local retailer companies belonging to Tod's group, who carry out, on our behalf, one or more steps of the  Service you have subscribed to;
iii.    to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other shift in all or in any given part of our business, assets or stock (also in connection with bankruptcy or similar outcomes);
iv.    in connection with the essential purposes described above (that is to say in order to comply with legal obligations or to execute a lawful request of public authorities).
We guarantee that we shall transfer your personal data towards a country outside the European Economic Area (EEA) not having an Adequacy Decision by the European Commission (EC), only after the adoption of at least one of the  cross-border transfer mechanisms the Regulation recognizes as being able to ensure an adequate protection of the personal data being transferred:
i.    specific  “Standard Contractual Clauses” are to be drafted, issued by the European Commission, in order to ensure that the protection level of the personal data processed by our partners outside the EU shall comply with the EU's data protection level;
ii.    adoption of Company Binding Rules, approved by the competent Public Authorities, in compliance with the data transfer within a group of undertakings or enterprises is done through binding corporate rules, approved by the competent data protection authority in the UE, pursuant to the consistency mechanism referred to in art. 63 and to the conditions detailed under art. 47 of the Regulation.
We also undertake to carry out, in accordance with laws in force, any possible prior risk assessment concerning the data transfer; adopting, if necessary, any additional security measures, complementary to the safeguards guaranteed by the aforementioned transfer mechanisms.
At any rate, we shall transfer your personal information, only if the protection level, guarantee by the Regulation, is not compromised.
Your personal data shall only be processed by parties being duly instructed and able to provide adequate technical and organizational safeguards, as well as bound to the strictest confidentiality by us.
 

The Company shall process your personal data for different lengths of time depending on different  purposes of the processing and on the kind of Service you have subscribed to.
We shall process your personal  information and data only for the period being strictly necessary to  fulfil the commitments we have taken as you have subscribed to the Service.
We would also like to inform you that we are further required to store your personal data in order to comply with specific law provisions, in the manner and within the timeframe established by said regulations.
Should the processing of your personal data be based on any legitimate interest, be it ours or belonging to third parties, the processing of your personal data shall be strictly limited to the time required to achieve the legitimate interest, on a case-by-case basis.

You have the right, as detailed within the law in force, to access your personal data, to correct or update it, to delete or to obtain a copy or the transmission in a structured format to any third party thereof. You may also request to limit or object to such processing.
You may exercise these rights at any time, by writing to our Data Protection Officer (DPO) to the following addresses:
•    by e-mail: dataprivacyofficer@todsgroup.com.
•    by post: Data Protection Officer - Tod's S.p.A., Via Filippo Della Valle n. 1, 63811 Sant’Elpidio a Mare (FM) – Italy (EU).  
We would like to point out that, should you exercise one or more of the privacy rights acknowledged by the relevant legislation we shall not discriminate against you, and such activities shall have no impact on the services provided, nor on any relationship of yours with Tod’s Group.
We will make sure to comply with your request to exercise your rights, always within the terms of the law.
We shall retain the right to ask you, in the ways we deem appropriate, for specific information to help us confirm your identity and be reasonably certain that only you can access your personal data and no unauthorized third party can seize, change or delete them. The processing of your request is free of charge. However, should your requests be manifestly unfounded, excessive, or repetitive in nature, we shall retain the right to refuse to comply with them or to request suitable economic contributions for them.
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.

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.
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