• Who is the Data Controller? Has a Personal Data Protection Officer (DPO) been appointed?

  The Data Controller is Calzedonia S.p.A. (hereinafter referred to as “Calzedonia”), with registered office in Via Portici Umberto Primo n. 5/3 Malcesine (VR) and administrative headquarter in Via Monte Baldo n. 20 Dossobuono di Villafranca (VR), Italy, e – mail privacy@calzedonia.com. Calzedonia has appointed a Data Protection Officer that can be contacted by sending an e – mail to dpo@calzedonia.com.

• What are the methods we use to process your Data?

  We process your Data using IT and telematic tools and supports, in compliance with the provisions of the law to ensure security and confidentiality, as well as the accuracy, updating and relevance of the data with respect to the stated purposes. Help us ensure that your Data is always accurate by communicating the updates to privacy@calzedonia.com.

• What categories of Data do we process?

  To give you access to our services and contents, we may collect:
  

  • • Personal and contact data collected through our online forms ;
  • • if you have received a Gift Card as a gift, in order to be able to deliver it and allow you to use it, we will use your contact details, such as your name and your e-mail address. These data are communicated to us by the purchaser of the Gift Card at the time of purchase;
  • • to make a purchase, in addition to the Data indicated on the online forms, you may be asked for additional information, such as data relating to the means of payment used and data for the shipment of products and any billing.
    We do not process data relating to the payment method you have chosen (e.g. credit card number and security code), which are instead collected exclusively by the chosen payment service provider.
    Providing such data is optional, but some of our fields are marked with asterisks. Those fields are mandatory and, failing that, we won’t be able to provide you with the service you requested. We will never ask neither for special categories related Data (revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, health status, sexual orientation and so on) or judicial Data (related to criminal records, the status of accused or suspected and so on).

  
  We may also collect:
  

  • • information that we may acquire when examining your interactions with us via e mail and newsletters, through our websites and the App that may be developed by us or by third party (for more information we invite you to read the related privacy policy);
  • • information shared by you through your social networks.

  
  We will process the Data you will provide us with only for the purposes related to each service requested and used.
  We may use your Data for other purposes, only with your prior consent or, in certain limited cases, in the presence of our legitimate interest.
  
  Cookies We use cookies in some areas of the websites. We invite you to read the Cookie Policy together with this notice.
  
  Social Network
  On our websites you can also find social buttons/widgets, depicting the icons of social networks (e.g., Facebook, Google and Twitter) and interactive social walls (that show pictures coming from the social). These "buttons" allow users who are browsing the Calzedonia websites to interact directly with social network which acquires data relating to your visit. In some areas of the websites, you may also find the so-called social login, that allows you to login your reserved area through the social network account. When you use the social login, you accept the terms and conditions and the privacy policy of the social network itself.
  

• For what purposes do we process your personal Data and what are the legal bases?

  PROCESSING	FOR WHAT PURPOSE DO WE PROCESS YOUR DATA?	WHAT ARE THE LEGAL BASES?
  Browsing the website	While you visit our sites, the computer systems used to operate them acquire some data (e.g. IP addresses, domain names, URIs) whose transmission is implicit and necessary for the Internet to function. Calzedonia uses this data for the sole purpose of allowing users to browse and obtain anonymous statistical information on the use of the sites and to check their correct functioning or to ascertain responsibility in the event of IT crimes.	The need to allow users to browse the sites. Calzedonia's legitimate interest in ensuring the proper functioning of IT systems and in proceeding with the investigation of alleged IT crimes (also on the basis of the existence of a legal obligation).
  Newsletter subscription	The newsletter is a promotional and advertising communication sent to users who request to receive it through a specific online form. On some of our sites, subscribing to the newsletter implies the sending of promotional communications that are not generalized, but targeted based on the language, gender and country of origin of the person concerned. This means that we process the data we receive in order to divide the subscribers into distinct groups by language, gender and country of origin so that the newsletter sent is as close as possible to what you have requested and which may be of interest to you.	Your consent. We will use the data requested in the registration form only with your authorization. At any time, you can withdraw your consent by writing an email to privacy@calzedonia.com.
  Products purchasing	Data you will provide us with will be used to process your purchase orders and related activities (shipment of goods, billing, payment processing, delivery etc.).	The need to execute the contract of sale of products..
  Customer Care	We provide you with an assistance service (via chat, telephone, email) for all your needs related to the purchase of our products or the use of our services. In some cases, we may ask you for your personal data when this is necessary to respond to the requests you make to our Customer Care.	The need to execute the contract for the sale of products or pre-contractual measures adopted on the basis of your request. To use the chat support service, we will ask you to provide your name and email address: these data are required on the basis of our legitimate interest in preventing the so-called "Chat spam"
  Surveys on your degree of satisfaction	To ascertain the level of satisfaction of our services and products.	Your marketing consent. We will use the data you provide only with your prior authorization, to send you questionnaires on your degree of satisfaction in relation to our products purchased by you and / or the services provided through Customer Care. In some limited cases, we will appeal to Calzedonia's legitimate interest.
  Loyalty Program	Manage participation in the loyalty program in order to provide members with discounts and other benefits provided in their favor and, more generally, for all related contractual and administrative obligations.	The need to provide subscribers the services offered under the loyalty program. By joining the program, you consent to the processing of data necessary for the performance of the loyalty program.
  Direct marketing	Sending commercial communications through the traditional paper mail service, email, SMS, landline and mobile phone; carrying out market research and surveying your degree of satisfaction regarding products relating to all the brands of the Calzedonia Group (Calzedonia, Intimissimi, Tezenis, Signorvino).	Your consent to receive these communications will be valid for mailings through the use of automated systems without the intervention of an operator (e.g. email, text message), and for traditional methods of contact (e.g. paper mail). You can always withdraw your consent to the processing of your data for this purpose by writing an email to privacy@calzedonia.com. Legitimate interest. Pursuant to art. 130, paragraph 4, legislative decree 196/2003 and subsequent amendments (relating to the so-called "soft spam"), without having to acquire your express consent, we can use the e-mail address you provided in the context of a previous purchase, for the purpose of direct sales and / or promotion of our products similar to those you have already purchased, provided that you do not object to such use by sending an email to privacy@calzedonia.com or by clicking on the appropriate link for the opposition to the receipt of communications considered unwanted, made available in the promotional emails sent by Calzedonia.
  Profiling	We will use the data you will provide us with to use individual services (for example, data released to make purchases or data following subscription to a loyalty program) for the so-called "profiling", that is the analysis of the social composition of consumers based on age, gender, country of origin, profession, consumption habits, etc. Profiling provides for the processing of the data that you will provide us with to create groups of consumers divided by market segments on the basis of a minimum set of elements (e.g. gender, country of origin), up to more advanced profiles based on preferences, online behavior and previous purchases. This activity has a dual purpose: to allow us to develop products and services with characteristics in line with the preferences of our consumers and to allow us to send you advertising communications as close as possible to your tastes and interests. In order to better understand your tastes and interest in our products and our communications, we may also use automated systems that do not, in any case, entail legal effects or other significant effects for the customer.	Your consent. Only with your authorization will we proceed with profiling activities. At any time, you can withdraw your consent by writing an email to privacy@calzedonia.com.
  Personalized assisted sales (only for members of the loyalty program)	Provide a personalized assisted sales service: customers enrolled in the loyalty program will be able to take advantage of the help and personalized advice of our sales assistants based on information (e.g. size, color, model) relating to purchases made in the previous 12 months.	Calzedonia has a legitimate interest in providing the best customer assistance service to customers enrolled in the loyalty program in its stores, in line with their needs.
  Anti-fraud measures	With regards to online purchases, verification of correspondence between the purchasing subject and the holder of the selected means of payment.	Calzedonia's legitimate interest to prevent and combat fraud.
  Participation in events, competitions and thematic initiatives of an extraordinary and temporary nature	We will use the data to enable you to participate in special initiatives you wish to take part in from time to time. For each event we will provide you with specific information that will detail the type of data processed, the storage duration and the specific processing purposes.	We will only collect your data with your consent.
  Registration within restricted areas of the web community	We use your personal data to enable you to create your own reserved area on our sites and to participate in virtual community initiatives (e.g. creating wishlists, sharing your content with other users through Calzedonia Group sites, purchase history, preferences email, etc.). Registering with our web community enables you to access many of our other services available on our website more rapidly, but it is not a mandatory requirement to use it.	The need to execute contract registration on the websites.
  Transferring of data to third parties	Only on certain occasions we may request your authorization to transmit your personal data to third-party companies belonging to the fashion, luxury and retail categories for sending their commercial communications to you. This is a possible processing purpose, with respect to which you will always be adequately informed and for which we will always collect your prior explicit consent.	We will only transmit your data to third parties for marketing purposes with your consent.
  Gift Card	We will process the name and e-mail address of the recipient of the Gift Card (i.e. the person who will receive it as a gift) as they are the contact details necessary to deliver the Gift Card and to ensure its use.	Calzedonia’s legitimate interest in guaranteeing the delivery and use of the Gift Card to the recipient of it.
  Statistical analysis	We create statistical reports and behavioral models in order to examine - in aggregate form - the effectiveness from an economic point of view of Calzedonia's commercial initiatives (for example the interest in a new product) and to guide our future commercial and promotional initiatives.	Calzedonia's legitimate interest in analyzing - in pseudonymized form (therefore without information directly attributable to individual customers) - customer data to obtain strategic information relating to: customer purchasing behavior, the ways in which customers interact with the company through the various communication channels and the effectiveness of commercial and promotional initiatives, in order to be able to compete with the main operators in the sector.

  We wish to inform you that when we base the processing of your personal data on our legitimate interest, we perform a balancing test between our interest and your rights, as required by law. You can contact the Data Controller at any time to request more information.

• How long do we keep your personal Data?

  PROCESSING	RETENTION PERIOD
  Browsing the website	The data are retained on our IT systems for no more than thirty days, unless legal provisions or provisions of Public Authorities impose a different retention time in relation to investigations related to any IT crimes.
  Newsletter subscription	The data you communicate to us to subscribe to the newsletter will be kept until we receive your request for cancellation from the mailing list.
  Products purchasing	Your personal data will be kept for the time necessary to fulfill the contractual obligations and obligations imposed by law (e.g. tax law) in relation to the performance of the sales activity.
  Customer Care	Your personal data will be processed for the time strictly necessary to achieve the processing purposes.
  Surveys on your degree of satisfaction	Your personal data will be processed for the time strictly necessary to achieve the purposes of analyzing your degree of satisfaction and in any case no later than 6 months from collection.
  Loyalty Program	We will retain your data no longer than the time necessary to manage your participation in the loyalty program. In any case, the information relating to your purchases and interactions with us will be retain no later than 12 months from the date of collection. In the event that you decide to cancel your membership in the loyalty program, your data will be deleted within the following three months.
  Direct marketing	Until a request for withdrawal of consent is received from you or, for direct marketing treatments based on our legitimate interest, until you object to the treatment.
  Profiling	12 months from the date of collection. The information relating to your purchases will be kept for 3 years from the date of each purchase.
  Personalized assisted sales (only for members of the loyalty program)	12 months from the date of collection.
  Anti-fraud measures	24 months from the date of collection.
  Participation in events, competitions and thematic initiatives of an extraordinary and temporary nature	For each event we will provide you with a specific policy that will detail the storage duration for the participation in events and initiative.
  Registration within restricted areas of the web community	In case of failure to use the account for over 2 years, we will cancel the account and all data relating to it.
  Gift Card	The recipient's data will be processed for the period strictly necessary for the delivery and use of the Gift Card by the latter.
  Statistical analysis	The data relating to the purchases will be kept - in pseudonymized form - for a period of five years. The other personal data will be kept - in pseudonymized form - for a period of two years.

• To whom do we communicate your Data?

  Data collected for the purposes indicated in this policy can be communicated to:
  

  • • subjects to whom the right to access them is granted by provisions of law or regulations;
  • • suppliers, consultants, companies linked to Calzedonia by commercial affiliation relationships, appointed as data processors as required by art. 28 of EU Regulation 2016/679. You can request a list of categories of entities appointed as Data Processors by writing to privacy@calzedonia.com;
  • • our employees in charge of providing and managing the services offered through this website;
  • • companies that provide payment services and financial institutions, companies that offer shipping services. These subjects act as independent Data Controller.

  
  
  

• Do we transfer your Data to non – EU countries?

  Personal data collected through this website may be transferred outside the European Union to be stored on the servers of the suppliers we use for the provision of our services. The transfer is carried out only after stipulating the Standard Contractual Clauses adopted by the European Commission with decision 2010/87, or after verifying that the non-EU country to which the transfer is made offers an adequate level of protection of personal data.

• What are the rights that you can exercise as Data Subject?

  You can exercise the rights that the law guarantees you regarding your Personal Data by writing to privacy@calzedonia.com.
  We undertake to respond to your request as soon as possible and in any case no later than 30 days from receipt of your report. In some cases, we may ask you for a copy of an identification document if, in connection with your request, it becomes necessary to verify your identity. In particular, you can exercise the following rights:

  
  

  • Right of access/to know

    You have the right to know if the processing of personal data concerning you is in progress and - if confirmed - to obtain a copy of such data and to be informed about: the origin of the data; the categories of personal data processed; the recipients of the data; the purposes of the processing; the existence of an automated decision-making process, including profiling; the data retention period; the rights provided for by EU Regulation 2016/679 (hereinafter the "Regulation").
    In particular, if you are a Californian resident, under the CCPA, you have the right to request any or all the following information related to the personal information we have collected about you or disclosed:
    

    • The specific pieces of personal information we have collected about you;
    • The categories of personal information we have collected about you;
    • The categories of sources of the personal information we have collected about you;
    • The categories of personal information that we have disclosed about you to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
    • The categories of personal information we have sold about you (if any), and the categories of third parties to whom this information was sold; and
    • The business or commercial purposes for collecting or, if applicable, selling personal information about you.

  • Right of rectification

    You have the right to obtain a rectification of data in our possession that concerns you or to update data that is incomplete.

  • Right of erasure/ Right to delete

    You have the right to request the erasure of your personal data if it is no longer needed for the purpose for which they were collected, or if we are no longer authorized to process it.
    In particular, if you are a Californian resident, under the CCPA, you have the right to request the deletion of personal information that we have collected from you.
    Once we receive and confirm your verifiable consumer request to delete, we will delete (and communicate to our service providers to delete) your personal information from our records, unless an exception applies (e.g. retaining the information necessary for us or our service provider(s) in order to complete the transaction for which we collected the personal information, providing a good or service that you requested, complying with a legal obligation etc.).
    With reference to the right to access/to know and the right of erasure/to delete, you may submit your requests, free of charge, by writing to privacy@calzedonia.com. We will need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account. We will only use personal information provided in connection with a consumer rights request to review and comply with the request. Once submitted the request, you will receive an e-mail as soon as feasibly possible, but no later than 10 business days, confirming that we have received your request and providing information about how we will process your request. We will respond to your request to access/to know or erasure/delete within 30 days (as required by GDPR) from the day we receive the request even if, in case of Californian consumers, the CCPA sets a longer period of 45 days. Any disclosure in response to a request to access/to know will cover the entire period from the date of your registration to the website (as required by GDPR) even if, in case of Californian consumers, the CCPA sets that disclosure of personal information must cover the 12-months preceding the business’ receipt of the request to know. In certain circumstances, we may decline a request to access/to know and/or erasure/delete, particularly where we are unable to verify your identity.

  • Right of restriction of processing

    You have the right to obtain processing restrictions in the following cases:
    

    1. you objected to the accuracy of personal data. You can request processing restriction for the period in which we will verify the accuracy of your data;
    2. we are not authorized to process your data and instead of deleting them, you can request a limit in their usage;
    3. where the data in our possession, although no longer necessary for us for the processing purposes for which they were collected, are required for the investigation, exercise or defense of a right in court;
    4. you oppose processing based on our legitimate interest. You can ask us to limit processing, pending verification of the precedence of our legitimate reasons, regarding those that are your responsibility

  • Right of consent withdrawal

    You can withdraw your consent in relation to all processing of data that requires it.

  • Right of data portability

    In the event that we process data based on your consent or in the implementation of a contract, or if the processing is carried out by automated means, you can exercise the right of data portability. You will then be able to receive the personal data you have communicated to us in a structured format, commonly used and readable using an automatic device. You can also request to forward your data directly to another company, as long as this is technically possible.

  • Right of opposition

    You have the right to object to the processing of your personal data at any time based on our legitimate interest, including profiling.

  We also inform you that if you believe that the processing of your personal data goes against the provisions of the Regulation, you have the right to file a complaint with the competent data protection supervising authority.
  
  If you are a Californian resident, under the CCPA, you may institute a civil action for statutory damages on an individual or class-wide basis (providing Calzedonia with 30 days’ written notice identifying the specific provisions violated) in the following cases: nonencrypted and nonredacted information subject to unauthorized access and exfiltration, theft or disclosure as a result of a business's lack of implementation of reasonable security procedures and practices. If Calzedonia within 30 days cures the noticed violation and provides the consumer an express written statement that the violations have been cured and that no further violations occur, no action for individual statutory damages or class-wide statutory damages may be initiated against Calzedonia.

  If you are a Californian resident, under CCPA, also the following rights will be applied:

  • Right to Opt-Out of Personal Information Sale

    Currently, we do not sell personal information, except in the case of profiling cookies. To learn more about profiling cookies, how to manage the use of such cookies and how to disable them, please visit our Cookie Policy.

  • Right to Non-Discrimination

    You have the right not to receive discriminatory treatment, in terms of price or services that we offer, for exercising any of the rights described above.
    However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you with our products or services or engage with you in the same manner.

  • Financial Incentives

    You have the right to be notified of any financial incentives offers and their “material terms” (terms and conditions), the right to opt-out of such incentives at any time, and to not be included in such incentives without your prior informed opt-in consent.
    We do not offer any incentives at this time.

  Authorized Agent
  In certain circumstances, you are allowed to use an authorized agent to submit the above requests on your behalf by writing to privacy@calzedonia.com. If you choose to submit a request through an authorized agent, we will require proof that the authorized agent has your written permission to submit a request on your behalf and, if necessary, we may require you to verify your identity with us. If the agent cannot provide your signed permission, we may deny the request.

We reserve the right to periodically update the content of this page.
We therefore invite you to consult this policy regularly in order to stay up to date with any changes that have occurred since your last consultation.
If you have any questions or requests in connection with this Privacy Policy or other privacy-related matters, please send an email to privacy@calzedonia.com

Last update: June 2021

Privacy policy