Privacy Policy

PRIVACY POLICY

 

INTRODUCTION

Following consultation of this website (the “Site”) and use of the services offered through it, data relating to identified or identifiable persons may be processed. This privacy notice on the processing of personal data is provided to users accessing the website www.trussardi.com, in accordance with Article 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”), concerning the protection of natural persons with regard to the processing of personal data and the free movement of such data, as well as Italian Legislative Decree 196/2003, as subsequently amended and supplemented, and the applicable national and European legislation on personal data protection (hereinafter, collectively, the “Privacy Legislation”).

DATA CONTROLLER

The Data Controller of the data provided by the user is Trussardi Milano S.p.A., a company incorporated under Italian law and subject to the management and coordination of Miroglio S.p.A., with operating office in Milan

- 20135 - Italy, Via Burlamacchi Francesco no. 4, tax code and VAT no. 04101240044 (hereinafter “Trussardi” or the “Controller”).

DATA PROTECTION OFFICER

The Miroglio Group, of which the Controller is part, has appointed a Data Protection Officer, who may be contacted at the following addresses: Miroglio Group - Data Protection Officer, Via S. Barbara 11, 12051 - Alba (CN), Italy, e-mail: dpo@miroglio.com.

TYPES OF DATA PROCESSED

Trussardi may process different types of personal data (the “Data”), depending on the products, services and features of the Site.

The Data subject to processing may include the following:

·     Personal and identification data

First name and surname, date of birth, gender, etc.

·     Contact details

E-mail, telephone number, shipping address

·     Data voluntarily provided by the user

No personal data needs to be provided by the user merely to browse the Site. The optional, explicit and voluntary sending of e-mails to the addresses indicated on this Site, or in any case the sending of a message through the other contact methods indicated on this Site, entails the subsequent acquisition of the sender’s address, which is necessary to respond to requests, as well as any other personal data included in the message. Such data will be used solely to respond to the user’s request and may be disclosed to third parties only where this is necessary for that purpose.

·     Data relating to purchases made by the customer

Data relating to the products purchased and the amount spent

·     Data relating to products added to the cart

Data relating to the products added to the “virtual cart” and their price

·     Browsing data

The IT systems and software procedures used to operate this Site acquire, during their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected in order to be associated with identified data subjects, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users connecting 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 numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and IT environment.

This data is used solely to obtain anonymous statistical information on the use of the Site and to check that it is functioning correctly, and is deleted immediately after processing. The data may be used to ascertain liability in the event of hypothetical computer crimes against the Site: without prejudice to this possibility, web contact data currently does not persist for more than seven days.

·     Cookies

For information on the cookies present on the Site, please refer to the Cookie Policy

LEGAL BASIS AND PURPOSES OF PROCESSING

Trussardi may process your Data for different purposes, depending on the products, services and features of the Site.

Data processing will be carried out for the purposes and on the legal bases indicated below:

·     Contacts: the optional, explicit and voluntary sending of e-mails to the addresses indicated on this Site, or in any case the sending of a message through the other contact methods indicated on this Site (for example, through “Customer Service”), entails the subsequent acquisition of the sender’s address, which is necessary to respond to requests, as well as any other personal data included in the message. Such data will be used solely to respond to the user’s request and may be disclosed to third parties only where this is necessary for that purpose. The user’s consent is not required for the processing of data for these purposes, since the processing is necessary for the performance of a contract to which the user is party or for the implementation of pre-contractual measures taken at the user’s request, as well as, where applicable, to comply with a legal obligation to which the Controller is subject (legal basis: performance of a contract to which the data subject is party or pre-contractual measures taken at the data subject’s request, as well as, where applicable, legal obligation to which the Controller is subject).

·     Registration on the Site: creation and management of the user’s personal account, authentication in the reserved area and access to the services offered (legal basis: performance of a contract to which the data subject is party or pre-contractual measures taken at the data subject’s request);

·     Online purchase of products: online sale and purchase of products on the Site and provision of any other services relating to such sale and purchase (legal basis: performance of a contract to which the data subject is party or pre-contractual measures taken at the data subject’s request).

·     Legal and contractual obligations: in accordance with applicable laws and regulations, including for the purpose of preventing and identifying possible abuses, unlawful acts, offences or fraud (legal basis: legal obligation to which the Data Controller is subject);

·     Marketing: periodic sending of commercial, informational, promotional and/or advertising material through automated tools (e-mail, web, SMS, instant messaging, operator-free calls) and/or non-automated tools (paper mail and/or calls with an operator), as well as for carrying out market and statistical analyses, sending updates regarding initiatives or events organized by Trussardi, or sending reminders relating to abandoned carts in order to facilitate the user’s purchase operations (legal basis: consent);

·     Newsletter: periodic sending of commercial, informational, promotional and/or advertising material by e-mail (legal basis: consent);

·     Customer profile definition: analysis of the user’s purchases and choices, in order to better understand the user’s selections and preferences and consequently offer, including through automated decision-making and profiling processes, a personalized service in line with the user’s specific needs and characteristics (legal basis: consent);

·     Participation in loyalty programs, competitions and prize operations: we may process the Data provided by the user to allow participation in any loyalty programs, competitions and prize operations organized by the Controller, subject to the user’s acceptance of the relevant rules, and to comply with the obligations arising from those rules (legal basis: performance of a contract to which the data subject is party or pre-contractual measures taken at the data subject’s request).

NATURE OF DATA PROVISION

The provision of Data by the user may be optional or mandatory, depending on the purpose for which it is collected. Provision is mandatory when it is necessary to deliver the requested service or provide the requested product (for example, to register on the Site it is mandatory to complete the form by providing the data marked as “mandatory” (*): if the form is not completed or is completed only partially, user registration cannot proceed; in order to place an order or make a purchase, it is essential to provide the delivery address: if such data is not provided, the order or purchase cannot be completed).

 

PROCESSING METHODS

Data will be processed using manual and automated tools for the time strictly necessary to achieve the purposes for which it was collected, based on the purposes specified in the section “Legal basis and purposes of processing” of this Privacy Policy. Specific security measures are adopted to prevent data loss, unlawful or incorrect use and unauthorized access.

Processing connected to the web services of this Site is carried out only by personnel authorized to process data. Personal data may be processed by external service providers (such as IT companies, cloud service providers, e-mail marketing platforms and parties responsible for the technical maintenance of the Site) duly appointed as Data Processors pursuant to Article 28 GDPR. The complete list of Data Processors may be requested at any time by writing to the Data Controller at the address indicated in the “Data subject rights” section.

Personal data will be processed within the European Economic Area (EEA), but may be transferred outside the EEA exclusively for needs strictly connected to the provision of services and/or for technical reasons. In such cases, transfers will take place to countries that have received an adequacy decision from the European Commission or, in any case, through the execution of standard contractual clauses.

This Site may allow access, through specific links, to third-party websites. If you access such websites, we invite you to consult their respective privacy notices to understand how those third parties process personal data. In some sections of the Site, the “social login” function may also be available, allowing access to the reserved area using the credentials of a social network. Please remember that, by choosing this method of access, you accept the terms of use and privacy notice of the selected social network.

DATA RETENTION

Data may be retained for different periods depending on the purpose for which it is collected and processed by the Controller and, in any case, in compliance with the Privacy Legislation.

In particular:

·     for the purpose of “Contacts”, the Data will be retained for the time strictly necessary to provide the requested service to the user, without prejudice to any further retention obligations provided for by law;

·     for the purpose of “Registration on the Site”, personal data will be retained for the entire period during which the user actively uses the services reserved for registered users. Subsequently, the data will remain archived in our systems for a further period of 5 years, unless the user requests deletion. Once this period has elapsed, the data will be permanently deleted.

·     for the purpose of “Online purchase of products”, the Data will be retained for a period not exceeding that permitted by tax and civil law (therefore, without prejudice to exceptions provided for by law, for a period not exceeding 10 years);

·     for the purpose of “Legal and contractual obligations”, the Data will be retained for a period not exceeding that permitted by tax and civil law (therefore, without prejudice to exceptions provided for by law, for a period not exceeding 10 years);

·     for the purposes of “Marketing” and “Customer profile definition”, the Data will be retained until consent to processing is withdrawn following the registered user’s decision no longer to receive communications and, in any case, for a maximum period of 5 years from the last expression of interest in Trussardi products. At the end of this period, the Data will be deleted or permanently and irreversibly anonymized. The registered user may withdraw consent at any time. If the Controller launches a “loyalty program” and the user joins that “loyalty program” and accepts the relevant rules, the user’s Data for the purposes of “Marketing” and “Customer profile definition” will be retained for the entire duration of the “loyalty program” or until the user informs us of the intention to cancel their membership of that “loyalty program”. In any case, if the Controller finds that, for a period of 5 years, the user has no longer shown any interest in receiving updates regarding Trussardi products and events despite membership of the “loyalty program”, the Data will be deleted. Data relating to products added to the “virtual cart” will be retained for a period not exceeding 3 months from the date of insertion;

·     for the purpose of “Newsletter”, the Data will be retained until the user withdraws consent to processing following the decision no longer to receive such newsletters. Withdrawal may be exercised at any time, including through the appropriate “unsubscribe” procedure at the bottom of each newsletter;

·     for the purpose of “Participation in loyalty programs, competitions and prize operations”, the Data will be retained for the entire duration of the loyalty program, competition or prize operation, or until the user informs us of the intention to cancel their participation in the initiative. In any case, if the Controller finds that the user no longer has an interest in receiving updates regarding Trussardi products and events despite participation in one of the aforementioned initiatives, the Data will be deleted.

DATA SUBJECT RIGHTS

The individuals to whom the Data refers have the right to exercise their rights at any time pursuant to Articles 15 et seq. of the GDPR, including: a) obtaining information on the purposes and methods of processing; b) obtaining access to the Data; c) requesting the rectification and updating of inaccurate or incomplete Data; d) obtaining the deletion of the Data; e) objecting to processing, including for marketing purposes and, where applicable, to automated decision-making processes, including profiling; f) obtaining restriction of processing; g) withdrawing consent at any time; h) receiving the Data provided in a structured format and, where technically possible, transmitting it to another controller (portability).

To exercise these rights, you may write to privacy@trussardi.com or send a written communication to Trussardi Milano S.p.A., Via Burlamacchi Francesco no. 4, 20135 Milan.

The user also has the right to lodge a complaint with the Italian Data Protection Authority.

CHANGES TO THE POLICY

The possible entry into force of new sector regulations, as well as the constant review and updating of the services provided to users, may make it necessary to change the methods used to process users’ personal data. It is therefore possible that our privacy policy may change over time and we therefore invite visitors to consult this page periodically.