PRIVACY NOTICE \(May 25, 2018 version\)
1. Data Controller
Loro Piana S.p.A. with registered offices in Corso Rolandi 10, Quarona \(VC\) – 13017, Italy, in its quality as data controller \("Loro Piana"\) which can be contacted at the following email address email@example.com, informs you, according to European Regulation No. 679/2016 on the processing of personal data \("European Privacy Regulation"\) that it processes the personal data provided by you \("Data"\) with the following modalities.
2. Ways of Data Processing
Data is processed in paper and electronic form in line with organizational and security requirements defined by applicable laws.
3. Purposes of Data Processing
Loro Piana processes Data \(such as, for instance, name, surname, address, the details of your purchases, etc.\) collected from you, even online through its websites for the following purposes \(i\) to manage the sale of our products and provide sale and after-sale services \(including, for instance, fraud prevention, returns, guarantee and customer support\) and, concerning online activities, manage the services offered by our websites, including the management of your information requests \("Contractual Purposes"\); \(ii\) to comply with legal and regulatory obligations \("Legal Purposes"\); and, with your prior consent, \(iii\) to send marketing communications through electronic means \(including, for instance, email, SMS, MMS, mobile, social network and instant messages\) or paper means \(including, for instance, traditional mail\) to promote our trademarks, services and/or products and to conduct market analysis and statistics \("Marketing Purposes"\) and \(iv\) to analyse your habits, interests and preferences in order to offer services and send marketing communications on these basis \("Profiling Purposes"\).
Moreover, your Data related to spending volume, product category, store of purchasing and date of birth may be processed from May 25th 2018 on the basis of Loro Piana's legitimate interest to provide a service in line with your needs, adequately balanced with the necessity of your rights protection \("Marketing Related Legitimate Interest Purposes"\).
4. Legal Basis
Processing of Data for Contractual Purposes is mandatory since it is necessary to register, purchase products and use specific services offered by Loro Piana. Processing of Data for Legal Purposes is mandatory since it is required by the applicable laws. If you do not provide Data, it would not be possible to provide the products or services provided by Loro Piana that you request. Processing of Data for Marketing and Profiling Purposes is not mandatory and subject to your prior consent which, in any case, may be revoked. Processing of Data for Marketing Related Legitimate Interest is functional to the pursuit of a legitimate interest of Loro Piana, properly balanced with your interests and, considering the limitation to this form of processing explained in paragraph 3 and it will be carried out starting from May 25th 2018, when the European Privacy Regulation becomes applicable.
5. Data Retention Period
Your Data is processed for no longer that is necessary to fulfil the above mentioned purposes and, particularly, for the Contractual Purposes Data are retained for the duration of the contract \(in case of an account created on the website or in relation to services provided by Loro Piana\) and for 10 years after the requested service. For the Legal Purposes, your Data is stored in accordance with the specific limitation periods defined by law. Data for Marketing and Profiling Purposes is stored for a period of 7 years from the last purchase done, as per the authorization of the Italian Data Protection Authority obtained by Loro Piana S.p.A. on March 9, 2017, and/or from the last contact with you \(e.g. participation to an event, opening of a newsletter\). Even Data processed for Marketing Related Legitimate Interest is retained for a period of 7 years from the last purchase done, notwithstanding the right to object to the processing at any time. Upon expiry of the above mentioned retention periods, your Data will be automatically deleted or made anonymous in a permanent and non-reversible way.
6. Data Communication and Transfer Abroad
For the Purposes explained in paragraph 3, Loro Piana might communicate Data, strictly necessary to each purpose of processing, to the following categories of subjects: \(i\) employees in charge of the processing \(such as the personnel of the CRM, IT, Retail offices\); \(ii\) consultants and professional and technical service providers \(such as IT service providers, postal offices and couriers, legal consultants, etc.\), companies controlled by Loro Piana, Loro Piana's companies in joint venture arrangements and Loro Piana's franchisees which may also be located in countries outside the Economic European Area \(EEA\) as indicated on www.loropiana.com. Data may be transferred outside the EEA according to articles 45 and 46 of the European Privacy Regulation. Your Data are not disseminated.
You have the right to obtain a copy of Data held abroad outside the EEA and to receive information on the place where Data is kept, by asking directly to Loro Piana, through the contact details provided in paragraph 8 of this Privacy Notice.
7. Data Subject's Rights
You may always enforce your privacy rights, for example you may access the Data, verify Data content, origin, accuracy, ask that Data be integrated, updated, amended, deleted, blocked for breach of law, object to the processing of your Data for legitimate purposes. In addition to the rights above, you may ask for a restriction of the processing, ask for Data portability and bring a claim before the Data Protection Authority, if the premises subsist.
8. Change, Update and Contacts
This document will be effective from the date indicated in the heading. Loro Piana might change and/or integrate the Privacy Notice, also as a consequence of further modifications and/or integration of the European Privacy Regulation. Updates and modifications will be notified in advance and you will be able to view the update Privacy Notice at the www.loropiana.com.
If you have doubts, questions or complaints with regard to the collection and processing of your Data, you may contact the Data Protection Officer \(DPO\) designated by Loro Piana who is reachable to the following address firstname.lastname@example.org.