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Privacy Statement pursuant to art. 13 Italian Law Decree 196/2003 We hereby inform you that TOD’S S.p.A. (the “Company”) will process your personal data in compliance with the regulations set forth in the Italian Law Decree 196/2003 and subsequent modifications (the “Privacy Code”); therefore, in accordance with the aforementioned article 13, we inform you of the following: 1. The data provided by you will be processed for the following purposes: (a) to offer you, through our newsletter, promotions, discounts, special offers and other services, to send you commercial or promotional information or free products, as well as to invite you to take part in shows or events, to conduct market research, and to announce all special initiatives dedicated to customers of the TOD’S Group; (b) to analyse your consumer choices (i.e. “profiling”) through a survey of the type and frequency of your purchase made online and/or at the TOD’S Group’s stores, in order to provide you with a better service when you make future purchases at any of the Group’s stores, and to pursue the purposes set forth in the previous point; (c) for the purposes of compiling statistics or historical records. 2. The processing shall be conducted by means of telecommunications, paper and digital instruments. 3. Your data will not be circulated. The data you provide will be accessible – always and exclusively for the purposes set forth in points (a), (b) and (c) above, and to ensure their ongoing accuracy and update them in the course of any future interaction you have with the TOD’S Group – by the Company’s employees and contractors (including service suppliers such as couriers, shipping agents, data entry firms, and so on), tasked with data processing; to companies in the TOD’S Group, in their capacity as external data controllers, and to the managers of TOD’S stores who are responsible for data processing, on premises in Italy and abroad; they will also be accessible by any third parties who shall be made responsible for the maintenance/development of our IT systems, only for the time strictly necessary to carry out such services. 4. Your data will be stored for the maximum period of seven years; at the end of this period the data will be automatically deleted and rendered permanently anonymous. In any case, you will have the right to withdraw your consent to receive commercial correspondence: to this end, each instance of correspondence will include a section that will allow you to withdraw your consent. The data transmitted to any services suppliers will be processed by them only for the period of time strictly necessary for them to perform the tasks assigned to them. 5. Any refusal to provide data or failure to consent to the processing of said data will render it impossible for our company to process the data for the marketing purposes outlined in point (a) above. If you do not consent to your data being processed for the purposes set forth in point (b), this will simply mean our Company will be unable to process said data for “profiling” purposes. Failure to consent to data processing for the purposes of “profiling” does not mean you will be unable to receive commercial or promotional information. 6. The Data Controller is TOD’S S.p.A., with headquarters in Via Filippo della Valle n. 1, Sant’Elpidio a Mare (FM), Italy. 7. The Data Manager, with whom you may exercise your rights stated in point (8) below, is the interim manager of the Company’s Customer Care Office, which can be contacted at the following e-mail address: customers@todsgroup.com. 8. At all times you have the right to know which data the Company has in its possession and how they are used. Pursuant to Art. 7 of Italian Law Decree 196/03, you also have the right to update, add to, correct or delete the data, to request that they be made anonymous, or to block any data processed unlawfully, and for legitimate reasons, to object to their processing; the full text of the aforementioned article 7 is available on this website under the “Privacy” section in the paragraph “Rights of the Data Subject”
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