LEGAL NOTICE

TOD'S s.p.a.

REGISTERED OFFICE: VIA FILIPPO DELLA VALLE, 1 – 63811 SANT'ELPIDIO A MARE (FM)

FISCAL CODE, VAT AND REGISTRATION NUMBER UNDER THE COMPANIES REGISTER OF FERMO (Italy) 01113570442

SHARE CAPITAL: EURO 61.218.802,00 fully paid up

R.E.A.: no. 114030 Fermo (Italy) – DATA PROCESSING NR. FM 004894

Thank you for visiting our website (hereafter, the “Site”).

You are recommended to read the following general terms and conditions of use carefully before using the site.

Accessing the Site and any use of the information the Site contains are subject to the following general terms and conditions of use (hereafter, the “Terms and Conditions”). You are invited to refrain from any further use of the Site if you do not agree with the contents of the Terms and Conditions. By accessing the Site you express your consent to be legally bound by the Terms and Conditions. Tod's S.p.A. (Tod's) reserves the right to change the Terms and Conditions at its discretion and at any time. Therefore, a recommendation is made to verify the applicable text on a regular basis, since, in any event, accessing the Site will entail accepting any change that has been made.

GUARANTEE EXCLUSIONS

Tod's offers this Site without any guarantee regarding its continuity and its contents. In particular, Tod's does not provide any expressed or implicit guarantee concerning the Site and its contents with reference to the ownership of the information contained therein, the absence of potentially dangerous programmes (for example: viruses, worms and trojan horses) and the suitability of the contents for specific purposes or commercial uses. Under no circumstance does Tod's guarantee that the information contained in this Site is accurate, complete and up-to-date, that the Site is free from faults or that any faults are corrected. When accessing the Site you acknowledge the circumstance that all use of the Site is under your exclusive responsibility; in particular, you accept to assume the risk of every and any loss of data, impossibility of use and the cost to repair the IT contents and programs used by you in relation to accessing and using the Site. Under no circumstance shall Tod's be responsible for the direct, indirect, specific or general damage of any nature, regardless of the circumstance that Tod's was aware or not of the possibility that such damage could occur in relation to the use of this Site. The contents of the foregoing exclusions may not be applicable, in full or in part when the possibly of excluding implicit guarantees is not acknowledged by a specific legal system.

LIMITED LIABILITY

Under no circumstance shall Tod's be liable, in contractual or non-contractual terms, for any direct or indirect, specific or general damage which may occur due to the use, the non-use and/or due to the performance of any product, information or content included in the Site (and the foregoing disregards the fact that Tod's was aware or not of the possibility that such damage may occur). Some of the foregoing limitations may not be applicable, since some jurisdictions do not permit the exclusion or limitation of liability for direct or indirect damages.

SURETY

By accessing the Site you undertake to stand surety for, hold harmless and defend Tod's, its subsidiaries and associated companies, its employees, directors and shareholders against any claim made by third parties, damage, loss, cost, expense (including the related legal and judicial costs reasonably sustained) resulting from your use of the Site or in relation to the Site concerned.

COPYRIGHT, TRADEMARKS AND OTHER INTELLECTUAL PROPERTY RIGHTS.

This overall Site and all the material the Site contains is protected by copyright and by other intellectual property rights. Therefore, you may view, print and copy the contents of this Site (including, merely by way of example, texts, images, animations, videos, logos and drawings) solely for personal purposes of a non-commercial nature. Using, changing, printing, displaying, reproducing, distributing or publishing the information contained in this Site is not permitted without the written consent of Tod's, subject to the provisions established herein. This Site may contain material protected by third party intellectual property rights. The permitted uses in such cases are to be verified with the holders or licensees of the respective rights, as identified in the Site from time to time.

CONTRIBUTIONS

All contributions or material transmitted to Tod's via the Site, including questions, comments or suggestions and the alike related to the Site's contents (hereafter, the “Contributions”) shall be deemed to be non-confidential. In particular, under no circumstance shall Tod's be under any obligation in relation to such Contributions and may freely copy, utilise, use, disclose to third parties, display, change, create works of a derivative nature and/or publish the Contributions without any limitation or amount being due and payable. In addition to the foregoing, Tod's reserves the right to use ideas, concepts, know-how or techniques contained in the Contributions for whatever purpose without an obligation to pay any compensation and/or amount, including, by way of example, the production and/or marketing of products which incorporate such Contributions.

LINKS AND INFORMATION FROM THIRD-PARTY SOURCES.

This Site may contain links to other websites (hereafter, the “Links”). Tod's declines all liability in relation to the contents and the materials accessible at the foregoing sites or however obtainable via such sites. All Links to other sites, as well as every other reference to information originating from third-party sources shall not be deemed to represent an express or implicit endorsement by Tod's. Questions and/or comments concerning the sites associated with the Links are to be directed exclusively to the administrators of the sites concerned. Moreover, this Site may contain information originating from third-party sources, as duly indicated from time to time, to which you shall refer exclusively for every query concerning their accuracy, truthfulness and completeness.

PRODUCTS

The Tod's products illustrated in this Site represent the Tod's collection. Therefore, this Site does not necessarily contain all of Tod's products, nor are all the products displayed on this Site currently available or will necessarily be available in all of Tod's stores. Tod's reserves the right to change the style, design and colours of Tod's products without prior notice. The information that Tod's publishes on the World Wide Web could contain references to Tod's products, initiatives and services or to products, initiatives and services of its subsidiaries, which may not be available or announced in your country. Such references do not imply Tod's intention to announce such products, initiatives and services in your country. Therefore, you are invited to consult Tod's local representatives from time to time concerning the products, programmes and services which are available in your country.

LIABILITY EXCLUSION

The material contained in this Site may contain inaccurate information and typing errors. Tod's declines all liability concerning losses or damage caused by or associated with the reliance made by the Site's users on information contained in the Site. Therefore, the user is responsible for assessing independently the accuracy of the information published on this Site. Tod's reserves the right to change the Site and its contents at any time without an obligation to notify such change in advance or at a later date.

UNAUTHORISED ACCESS AND USE OF THE SITE

Users of the Site are only authorised to consult the documents indicated in the Site's menus. Every unauthorised attempt to overcome or bypass the Site's protections, to use the operating systems which operate or are connected with the Site for uses other than the uses for which they are intended or to prevent their use by authorised users is prohibited; the prohibition also applies to accessing, obtaining, destroying, changing, damaging the information contained in the Site or interfering with such systems. All similar behaviour/action will be brought to the attention of the competent authorities without delay and prosecuted in all the competent civil and criminal courts, in accordance with the applicable laws and international conventions.

PRIVACY

This notice is addressed to anyone visiting and interacting with this Tod’s S.p.A. Internet site (Tod’s S.p.A. or the 'Company'). It only applies to this website and not to any other websites visited by the user via links on this website; this does not affect the information provided, for the sake of completeness, in relation to the web Store where Tod’s, Hogan orFay products can be purchased online. The Company shall to no extent be held liable for the unlawful processing of your data by third parties. Therefore, in order to exercise the rights referred to in the paragraph headed 'Rights of the Data Subject', please refer to the specific notices that those third parties are required to provide you with as independent Data Controllers. 

The notice is also based on Recommendation No. 2/2001 adopted by the personal data protection authorities in the European Union, in the form of the Working Party established by Article 29 of Directive No. 95/46/EC, on 17 May 2001 in order to identify certain minimum requirements for collecting personal data online and, more specifically, the manner, timescale and nature of the information that data controllers must provide to users when they link up to web pages, regardless of the purpose of that link. 
As the various pages of the site designed for the particular services on request are visited, specific notices in summary form will appear. 
The Company will process your personal data in compliance with the provisions of Legislative Decree No. 196/2003 as subsequently amended (the 'Privacy Code').

Browsing data 
During the course of their normal operation, the IT systems and software procedures that are used to run this web site acquire certain personal data; the transmission of this data is an inherent feature of the use of Internet communication protocols. 
This information is not collected in order to be linked to identified individuals. However, its very nature dictates that, via processing and matching with data held by third parties, it might enable users to be identified. 
This category of data includes the IP addresses or domain names of the computers used by users who connect with the site, the Uniform Resource Identifier addresses of the resources requested, 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 that indicates the response status provided by the server (success, error, etc.) and other parameters that relate to the operating system and the user's IT environment. 
This data is only used in order to gather statistical information in an anonymous form about the use of the site and to check that it is operating correctly, and is deleted immediately once it has been processed. The data could potentially be used in order to establish liability where computer crimes are committed to the prejudice of the site; save in those circumstances, web contact data is currently held for no longer than fifteen days.

Cookies
For further information, please see the Cookie Policy page.

Purposes of the processing 
Signing up for our newsletter and consent to marketing and/or customer profiling where provided; purchase of products in the Tod’s Group stores and completion of coupons for marketing and/or customer profiling purposes where applicable. 
You can also sign up for our newsletter, if you wish to do so. 
Similarly, when you make a purchase at one of the Tod’s Group stores, you will be given the option of providing us with certain data by filling in a specific coupon; this is so that the Tod’s Group can improve the service that it intends to offer its customers. 
The data provided by you when filling in the coupons at one of the Group's stores and/or by signing up for our newsletter will (only where you have freely provided your express consent in advance) be processed by Tod’s S.p.A., registered office at Via Filippo della Valle 1, S. Elpidio a Mare (FM), for the following purposes: 
(i) to offer promotions, discounts, concessions and other services and to send commercial or promotional information, giveaways and invitations to events, to carry out market research and to announce any special schemes designed exclusively for Tod’s Group clients; 
(ii) to carry out customer profiling, in compliance with the guarantees and necessary measures established by the Italian Data Protection Authority, by identifying the type and frequency of purchases that you make online and/or at Tod’s Group stores in order to be able to provide you with a better service on the occasion of future purchases at one of the Group's stores and for the purposes set out above.

The data may also be processed for statistical or historical purposes. 

Methods of processing 
The processing will be carried out in paper form and using web and IT tools; this processing will be carried out in accordance with the principles of propriety, legality and transparency and with principle that your rights and your privacy must be protected. 
The way that the data will be processed will mean that the risk of the data being destroyed, lost, accessed without authority or subject to processing without consent or other than for the purposes that it was collected for is kept to a minimum.

Provision of data and the consequences of withholding consent to processing 

Consent to marketing and/or customer profiling (always optional) 
A refusal to provide the data or withholding consent to the data being processed for the purposes of marketing and/or customer profiling as referred to in points (i) and (ii) of the paragraphs headed 'Signing up for our newsletter and consent to marketing and/or customer profiling where provided; purchase of products in the Tod’s Group stores and completion of coupons for marketing and/or customer profiling purposes where applicable' and 'Browsing the web Store; consent to marketing and/or customer profiling where provided' will simply mean that it is impossible to process the data for the purposes set out in those paragraphs. 
It follows that where consent to your data being processed for the purposes of 'Marketing and/or customer profiling' is withheld, you will still be able to purchase Tod’s Group products.

Parties or categories of parties that the data can be provided to and the extent to which the data is disseminated 
Your data will not be disseminated. 
Data provided when signing up to our newsletter or at Tod’s Group stores
The data provided by you, with your consent, for the purposes set out at points (i) and (ii) of the paragraph headed 'Signing up for our newsletter and consent to marketing and/or customer profiling where provided; purchase of products in the Tod’s Group stores and completion of coupons for marketing and/or customer profiling purposes where applicable' will be accessible to Tod’s S.p.A.'s employees and contract staff (including service providers such as couriers, freight forwarders and data entry firms etc.) authorised to carry out the processing, to companies in the Tod’s Group as external data processors, and to the operators of Tod’s stores authorised to carry out the processing, based in Italy or abroad (including outside the EU); such access will be solely and exclusively for the purposes referred to hereunder and in order to ensure that the said data is accurate at all times and is updated whenever you deal with the Tod’sGroup in the future.

Duration of the processing 
Save where storage for a longer period is required in order to comply with the applicable regulations, including accounting regulations, the Company will store your data by for the amount of time strictly necessary in order to ensure that the services purchases are properly provided. 
The data processed by Tod’s S.p.A. for customer profiling and/or marketing purposes (on condition, of course, that your express consent has been obtained), will be stored for a maximum period of seven years. When that period expires, we can ask you to renew your consent to the processing of your data or make the data anonymous and store it solely for statistical or historical purposes. 
You may revoke your consent to your data being processed at any time; all commercial correspondence will include a section that you can use in order to revoke the consent that you have provided. 
Data sent to service providers will be processed by them for the amount of time strictly necessary in order to enable them to provide the services required.

Data Controller 
The independent Data Controller in relation to any data provided when signing up for this site's newsletter and/or completing coupons at one of the Tod’s Group stores is Tod’s S.p.A., registered office at Via Filippo della Valle 1, S. Elpidio a Mare (FM), Italy. You can also contact the Data Controller by e-mail at info.privacy@todsgroup.com 
Tod’s S.p.A. is also: 
- Data Processor in relation to your personal data. You can exercise the rights set out below under 'Rights of the Data Subject' against the Data Processor, who is the manager pro-tem of the Customer Care Office; you can write to him/her at customers@todsgroup.com.

General notice for suppliers 
We would like to inform you that your data will be processed by Tod’s S.p.A. in compliance with the provisions of Legislative Decree No. 196/2003 as subsequently amended; this processing will therefore be carried out in accordance with the principles of propriety, legality and transparency and the principle that your privacy and your rights must be protected. Pursuant to Article 13 of the above Legislative Decree, we therefore provide you with the following information:

1.     The data provided by you will be processed for the following purposes:

2.     compliance with obligations pursuant to contracts between you and the Company;

3.     compliance with administrative and accounting requirements (handling/processing of orders, correspondence and invoicing, etc.). connected with the contracts referred to above;

4.     compliance with requirements imposed by the law, regulations and in general by the applicable legislation, including EU legislation, from time to time in force.

5.     The processing will be carried out on paper and using web and IT tools.

6.     Provision of the data is compulsory for the purposes set out above.

A refusal to provide the data requested or the provision of inaccurate data may result in the Company being unable to carry out the work that it is required to do, or to do so in part only, and/or prevent the relationship with the Company from continuing.

1.     The data will not be disseminated. It will be accessible to employees of the Company authorised to carry out the processing for the purposes set out at points (a), (b) and (c) above; it may be communicated to third parties, including our commercial partners and authorised service providers, solely for administrative and accounting purposes related to the aforementioned contracts with the Company and in order to better perform the obligations arising out of the same; in particular, your data may be communicated to other companies in the Tod’s S.p.A. Group.

It may also be communicated/made accessible to third parties instructed to carry out maintenance/development work on our IT system for the amount of time strictly necessary in order to provide that service.

1.     Save where storage for a longer period is required in order to comply with the applicable regulations, including accounting regulations, your data will be stored by the Company for the amount of time strictly necessary in order to ensure that the aforementioned obligations are properly complied with.

2.     The Data Controller is Tod’s S.p.A., registered office at Via Filippo Della Valle 1, Sant'Elpidio a Mare (FM), Italy.

3.     You can exercise the rights set out below against the Data Processor, who is the manager pro-tem of the Company's Administration and Finance Office. You can write to him/her at info.privacy@todsgroup.com.

4.     In compliance with Article 7 of Legislative Decree No. 196/03, which is set out in full under 'Rights of the Data Subject' below, you are entitled to be informed at any time of the data in the Company's possession and how that data is being used.

Rights of the Data Subject 
You are entitled to be informed at any time of the data in the Company's possession and how that data is being used. You may exercise your rights against the Data Controller pursuant to Article 7 of Legislative Decree No. 196/2003 at any time. 
For ease of reference, the full wording of Article 7 is set out below:

“Article 7. Right of access to personal data and other rights
1. A data subject is entitled to receive confirmation of the existence or otherwise of personal data that concerns him, including where that data has not yet been recorded, and to have that data communicated in an intelligible form. 
2. A data subject is entitled to be informed of:
a) the source of the personal data;
b) the purposes and methods of processing;
c) the logic applied in the event that processing is carried out electronically; 
d) details identifying the Data Controller, the Data Processors and the representative appointed pursuant to Article 5, paragraph 2;
e) the parties or categories of parties that the personal data can be communicated to or who may acquire knowledge of the said data as the appointed representative in Italy, as data processors or as persons authorised to carry out the processing.
3. The data subject is entitled:
a) to have the data updated, rectified or, where he/she so wishes, supplemented; 
b) where data is processed in breach of the law, including data which, in light of the purposes for which it was collected or subsequently processed, does not necessarily need to be stored, to have that data deleted, made anonymous or blocked;
c) to a statement confirming that the steps referred to at (a) and (b), and the content of those steps, have been brought to the attention of parties to whom the data has been communicated or disseminated, save where this proves to be impossible or would require the use of resources that is manifestly disproportionate to the right being protected. 
4. A data subject is entitled to object, in whole or in part:
a) on lawful grounds, to the processing of personal data that concerns him, including where the processing is relevant to the purposes for which it was collected;

b) to the processing of personal data that concerns him/her in order to send advertising material or for the purposes of direct sales or to carry out market research or for the purposes of commercial communications."

For US residents only. 

If you claim that your personal information has been used in a manner that is improper and/or contrary to these Terms of Use or that we have otherwise violated your rights or privacy, you must first give us an opportunity to resolve your claim by sending a written description of your claim to Richard Spata, Chief Financial Officer, r.spata@todsgroup.com. We each agree to review and negotiate your claim in good faith. If we reject your claim or if we are unable to negotiate a resolution of your claim with you, then either you or we may start arbitration proceedings which shall be conducted in New York, New York or such other jurisdiction as may be agreed by the parties in the interest of fairness and convenience. You agree that if you choose to pursue any such claim, you will pursue such claim in an arbitration proceeding (rather than in any judicial forum or court). Any dispute arising out of or relating in any way to use of your personal information and/or violation of your rights of privacy will be resolved by binding arbitration. The arbitration shall be conducted by a single arbitrator in the city of New York, New York, U.S.A., in accordance with the rules of the American Arbitration Association ("AAA"). No claims of any other parties may be joined or otherwise combined in the arbitration proceeding. Unless otherwise expressly required by applicable law, each party shall bear its own attorneys fees without regard to which party is deemed the prevailing party in the arbitration proceeding. The arbitrator shall be authorized to award either party any remedy permitted by applicable law. 

If you wish to pursue your claim in arbitration, you must send a letter requesting arbitration and describing your claim to our registered to [name of agent] in order begin arbitration. The American Arbitration Association (AAA) will arbitrate all disputes pursuant to the rules of the American Arbitration Association (AAA). For claims of less than $75,000, the AAA's Supplementary Procedures for Consumer-Related Disputes will apply; for claims over $75,000, the AAA's Commercial Arbitration Rules will apply. The AAA rules are available at www.adr.org or by calling 1-800-778-7879. 

We each agree that any proceedings, whether in arbitration or court, will be conducted only on an individual basis and not in a class or representative action or as a member in a class, consolidated or representative action. If a court or arbitrator determines in an action between you and us that this class action waiver is unenforceable, the above arbitration agreement will be void as to you. 

An. Del. U.S.A., Inc. , - a wholly owned subsidiary of TOD'S - complies with the U.S.-EU Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. An. Del. U.S.A., Inc. has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view An. Del. U.S.A., Inc.'s certification, please visit http://www.export.gov/safeharbor/ 

*Notice pursuant to Article 13 of Legislative Decree No. 196/2003

We would like to inform you that your personal data will be processed by Tod’s S.p.A. (the 'Company') in compliance with the provisions of Legislative Decree No. 196/2003 as subsequently amended (the 'Privacy Code'). Pursuant to Article 13 of Legislative Decree, we therefore provide you with the following information:

1.     The data provided by you will be processed for the following purposes: 
(a) to offer promotions, discounts, concessions and other services by sending out our newsletter, to send out commercial or promotional information and giveaways as well as invitations to events, to carry out market research and to announce any special schemes designed exclusively for Tod’s Group clients; 
(b) to create your customer profile by identifying and analysing the type and frequency of purchases that you make on-line and/or at Group Tod’s stores in order to provide you with a better service on the occasion of future purchases at one of the Group's stores and for the purposes set out at point (a) above; 
(c ) data processing for statistical or historical purposes.

2.     The processing will be carried out in paper form and using web and IT tools.

3.     Your data will not be disseminated. The data provided by you will be accessible to the Company's employees and contract staff (including service providers such as couriers, freight forwarders and data entry firms etc.) authorised to carry out the processing, to companies in the Tod’s Group as external data processors, and to the operators of Tod’s stores authorised to carry out the processing, based in Italy or abroad, such access being solely and exclusively for the purposes set out at points (a), (b) and (c ) above and in order to ensure that the said data is accurate at all times and is updated whenever you deal with the Tod’s Group in the future; the data will also be accessible to third parties instructed to carry out maintenance/development work on our IT system for the amount of time strictly necessary in order to provide that service.

4.     Your data will be stored for a maximum period of seven years; when that period expires, it will be automatically deleted or made permanently anonymous. You may revoke your consent to receive commercial communications at any time; all communications will in fact include a section to use in order to revoke the consent that you have provided. Data sent to service providers will be processed by them for the amount of time strictly necessary in order to enable them to provide the services required.

5.     Where you refuse to provide the data or withhold consent to your data being processed, this will mean that it is impossible for us to process the data for the marketing purposes referred to at point (a) above. Where consent is withheld to the data being processed for the purposes set out at point (b) above, we will simply be unable to process that data for the purposes of customer profiling. Where consent to your data being processed for the purposes of customer profiling is withheld, this will not prevent you from receiving commercial or promotional information.

6.     The Data Controller is Tod’s S.p.A., registered office at Via Filippo della Valle no. 1, Sant’Elpidio a Mare (FM), Italy.

7.     The Data Processor is the manager pro-tem of the Company's Customer Care Office. You can exercise your rights pursuant to point (8) below against the Data Processor, and you can write to him/her at customers@todsgroup.com.

8.     You are entitled to be informed at any time of the data in the Company's possession and how that data is being used. In compliance with Article 7 of Legislative Decree No. 196/03, you are also entitled to have the data updated, supplemented, rectified or deleted, to ask for the data to be made anonymous or for data processed unlawfully to be blocked, and to object, on lawful grounds, to the processing; the wording in full of Article 7 of Legislative Decree No. 196/03 can be found on this site in the 'Privacy' section, in the paragraph headed 'Rights of the Data Subject'.

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Privacy Notice

pursuant to Article 13 of Italian Legislative Decree No. 196/2003 and Article 13 of EU Regulation No. 679/2016

We wish to inform you that your personal data will be processed by TOD’S S.p.A. (the “Company”) in compliance with the provisions of Legislative Decree No. 196/2003 as subsequently amended (the “Italian Privacy Code”) and EU Regulation No. 679/2016 (the “Regulation”); pursuant to Article 13 of the Italian Privacy Code and Article 13 of the Regulation, we hereby provide you with the following information:

1.     The Data Controller is TOD’S S.p.A., with registered office at 1, Via Filippo della Valle, Sant’Elpidio a Mare (FM), Italy. The Data Processor is the Company’s Data Protection Officer, pursuant to Article 37 of the Regulation, who you may contact by writing to dataprivacyofficer@todsgroup.com and to whom you may refer to exercise the rights set forth in clause 7 below and to submit any requests regarding the processing of your personal data by the Company.

2.     The data you provide will be processed, on the basis of your prior, free and express consent, for the following purposes:

(a)      to offer promotions, discounts, benefits and other services by newsletter, to send out commercial or promotional information and giveaways as well as invitation to events or shows, to carry out market researches and to announce any special initiative tailored to clients of the TOD’S Group;

(b)      to carry out customer profiling activities by identifying the type and frequency of purchases made by you both online and/or at the stores of TOD’S Group, to provide you with a better service on the occasion of future purchases at one of the Group’s stores and for the purposes set out in the above paragraph.

Your data may also be processed for statistical or historical purposes.

3.     The processing of your data will be carried out by using telematic, paper-based and IT tools. In particular, the processing of your data, including for profiling purposes, may also take place by automated processes, for instance, by means of assessment and comparative analysis of your purchase choices (types, quantities) during a specific period and/or season and by analysing the type and number of your requests for information about products made during a predetermined timeframe.

4.     Your data will not be disseminated. The data you provide will be accessible to the employees and the co-workers of TOD’S S.p.A. – solely and exclusively for the purposes listed in clauses (a) and (b) above and in order to ensure that such data are accurate at all times and updated whenever you liaise with TOD’S Group. Your data will also be made available to third parties employed by TOD’S Group for the organization and management of its commercial activities, (e.g. service providers such as couriers, freight forwarders and data entry companies, etc.), companies belonging to the TOD’S Group, managers and franchisees of TOD’S Group stores, based both in Italy and abroad, acting as data processors or as person in charge, as the case may be. They will also be made accessible to third parties engaged with the maintenance/development of our computer system for the period strictly necessary for carrying out such service.

5.     The Company will store the data collected for the purposes referred to in clause 2 above until withdrawal of your consent to the processing of personal data and in any case, as for the data processed for the purposes set out in clause 2(b), for a maximum period of seven years after your last purchase, in compliance with the measure issued by the Italian Data Protection Authority (Garante per la protezione dei dati personali) on 7 November 2013 upholding the preliminary ruling requested by the Company. Upon withdrawal of your consent or upon expiry of the storage period of the data collected for the purposes set out in clause 2(b), whichever occurs earlier, such data will be automatically erased or rendered permanently anonymous. You may withdraw your consent to your data being processed any time: all commercial correspondence will include a section which can be used to withdraw consent you already provided. Data sent to service providers will be processed by them for a period strictly necessary to perform the tasks entrusted to them. 

6.     In the event of refusal to provide data or lack of consent to the data processing, our company will not be able to process data for marketing purposes set forth in clause (a) above. In the event of lack of consent to the processing of data for the purposes set forth in clause (b) above, our company will not be able to process data for “profiling” purposes. In no event lack of consent to the processing of your data for “profiling” purposes will prevent you from receiving commercial or promotional information.

7.     Pursuant to Article 7 of the Italian Privacy Code and Article 15 of the Regulation, you are entitled to be informed, any time, about which data are in possession of the Company and which use is made of such data. For further information about the rights you may exercise pursuant to the Regulation and the Italian Privacy Code and in general about processing of your personal data through this website, please refer to the general section “Privacy” available at the following link:  [<a href="/https://www.devboutique.com/it-en/legal-area/privacy-policy">Privacy</a>]. 

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