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Marketing communication
LAST UPDATED IN: SEPTEMBER 2022
Your Privacy and the security of your personal data/information are very important for the whole of Tod's Group, and that is why we use the utmost care in collecting and processing the personal data you will provide us by joining our promotional communications plan, adopting specific provisions in order to ensure the security, confidentiality and integrity thereof, in compliance with Regulation (EU) 2016/679 (from here on, the Regulation) , and with the applicable privacy regulations in Singapore (e.g. Personal Data Protection Act 2012), in accordance with the relevant implementation and within the limits of their territorial scope.
Below you will find the information regarding the processing of your personal data that we will perform in order to involve you in our marketing and promotional initiatives; and, where we have been allowed to do so, in order to provide you with services more suitable to your preferences and expectations.
The Privacy Policy herein supplements the Privacy Policy of the Website, to which you should refer to for additional information.
- 1. Data Controller \\(Organisation\\)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 offices in Via Filippo Della Valle, 1, Sant’Elpidio a Mare, (FM) - Italy (EU).
- 2. Legal basis and Purposes of ProcessingUnless 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. shall process your personal data (such as your name, surname, e-mail account, gender, etc.), with your express and specific consent to do so, for the purpose of:
i. carrying out marketing activities using 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 sending invitations out for shows or events, conducting market research and sending notifications regarding special initiatives focused on TOD’S Group customers. In addition to email, in accordance with the marketing procedure that we adopt, we may use complementary communication channels and tools (such as telephone, post, and similar), in line with the contact information you have provided or will provide to us in the future;
ii. customer profiling activities, such as analysing your interests and preferences concerning our products and services, and your shopping habits. By also looking at the type and frequency of your online purchases (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 TOD'S Group boutiques. Should you provide your consent for us to process your personal data for profiling purposes, you agree that we may obtain from our local subsidiaries information concerning the purchases you made at their points of sale. Likewise, if you have also granted 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 customer.
Learn more about how we ask for your consent +
Please provide your express 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 selected purpose (marketing or profiling);
b. do not tick the corresponding box, we will continue with the situation that was previously in force: • if you had previously consented to the processing of your personal data (e.g. via other online forms or 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 at any time, (also known as the “right to opt-out”), by following the instructions indicated in this Privacy Policy.
The provision of any and all personal data is voluntary. However, if you opt not to disclose certain personal data it could prevent you from being fully involved in some of our marketing and profiling initiatives.
Please note that, should you decide not to 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 grant your consent to the processing of your personal data for profiling purposes, it shall not impact your involvement in our promotional communications plan, however it will prevent us from pursuing the purposes detailed in section ii) above.
Finally, we may also process your personal data in order to comply with our applicable statutory obligations or to pursue our legitimate interests (i.e. improving business processes, preventing fraud, exercising and defending our rights or optimising our customer contact strategies), in compliance with the provisions and restrictions applicable under current legislation.
- 3. Personal data Processing and SecurityWe shall process your personal data using both hard and soft copies of the data and the processing will comply with the principles of fairness, lawfulness, and transparency so as to best safeguard your rights and privacy.
In particular, the processing of your data, including for profiling purposes, may be automated, for example via the comparative analysis of the purchases you make (according to type, quantity, frequency, timing, etc.), and by analysing the type and number of requests you make for product information within a given timeframe.
We 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.
- 4. Personal data Disclosure and TransferWe 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 this Privacy Policy:
i. with our service providers, including companies that belong to Tod’s Group that carry out technical and organizational services on our behalf, with the ultimate aim of pursuing the purposes described above;
ii. with other Tod’s Group companies 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 Tod’s Group shops;
iii. to a third party in the event of a reorganization, merger, sale, joint venture, assignment or transfer of any part of our business, assets or stock (also in connection with bankruptcy or similar proceedings);
iv. in connection with the essential purposes described above (i.e. to comply with statutory obligations or to respond to a lawful request made by public authorities).
Your personal data, under your consent, will be transferred from your country to our headquarters in Italy. We are subject to Regulation (EU) 2016/679, which is the data protection law applicable throughout all EU Member States that offers a comparable level of personal data protection as under Singapore laws and regulations.
Data transfers to countries outside the European Economic Area (EEA): We guarantee that we will only transfer your personal data to a country outside the European Economic Area (EEA) that does not have an Adequacy Decision by the European Commission (EC) only once at least one of the cross-border transfer mechanisms under the Regulation has been adopted that is able to ensure an adequate protection of the personal data being transferred:
i. specific “Standard Contractual Clauses” are drafted, as issued by the European Commission, in order to ensure that the level of protection of the personal data processed by our partners outside the EU complies with the EU's data protection level requirements;
ii. Company Binding Rules approved by the competent Public Authorities are adopted, in compliance with the data transfer within a group of undertakings or enterprises, approved by the competent EU data protection authority, pursuant to the consistency mechanism provided for by Article 63 and to the provisions of Article 47 of the Regulation.
We also undertake to carry out all possible advance risk assessments in accordance with applicable laws concerning the data transfer; adopting, as and when required, any additional security measures, on top of the safeguards guaranteed by the aforementioned transfer mechanisms.
In any event, we will only transfer your personal information if the level of protection guaranteed by the relevant privacy laws in force in our countries is not compromised.
Your personal data shall only be processed by parties that have been specifically instructed to do so and are able to ensure adequate technical and organizational safeguards, as well as being bound to the strictest confidentiality undertakings by us.
- 5. Retention of personal dataThe timing of when we will process your personal data will depend on the purpose of said processing. Should you consent to the processing of your personal data for marketing purposes, said processing will be performed until you revoke your consent.
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 grant your consent and it will 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 like to inform you that we are required to retain your personal data in compliance with specific law provisions, on the terms and for the retention periods required by said regulations.
Insofar as the processing of your personal data is based on a legitimate interest, either ours or that of a third party, the processing of your personal data will be strictly limited to the time required to achieve the legitimate interest, on a case-by-case basis.
- 6. Your RightsYou have the right under applicable law to access your personal data, to rectify and/or update it, to erase it and/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 withdraw your consent at any time to the processing of your personal data for marketing and/or customer profiling purposes.
You may object to receiving direct marketing communications (also called an opt-out) either via automatic means (text messages, MMS, messaging platforms, e-mail messages and push notifications) and/or via traditional means (such as post, phone calls from operators) and you are entitled to exercise this right partially i.e. objecting only to receiving promotional communications via automatic tools at any time.
You may exercise these rights at any time, by writing to our Data Protection Officer (DPO) at 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).
Moreover, our DPO is available for further information on the policy herein or about how we manage personal information.
To learn more about how you can manage your consents (also known as opt-out) +
Without prejudice to your right to revoke your the consent (also known as an opt-out) to the processing of your personal data for marketing and/or profiling activities by contacting the aforementioned addresses, please note that each marketing communication allows you to:
i. block the contact-channel (e.g., e-mail and SMS messages) via 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 will no longer send you advertising or promotional communications or and all newsletters related to any brand of the Tod's Group shall be automatically disabled;
iii. withdraw your consent to profiling activities.
Moreover, there is an option in every newsletter for unsubscribing and as a result of doing so you will no longer receive our newsletters, however you will continue to receive 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 under applicable legislation.
We will make sure to comply with your request to exercise your rights, always in full compliance with applicable law.
We will be entitled to ask you for specific information to help us to confirm your identity and to be reasonably certain that only you may access your personal data and that no unauthorized third party may seize, change or delete that data. The processing of your request is free of charge. However, should your requests be manifestly unfounded, excessive, or repetitive in nature, we shall have the right to refuse to comply with them or to request suitable economic compensation for them.
Note that at any time you may file a complaint with the Data Protection Authority if you believe that we have breached any rules concerning the protection of your personal data.
- 7. Updates to the Privacy Policy hereinWe 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.