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Privacy Policy

Online And Offline Personal Information Processing Policy

Privacy Policy

1.     General Provisions

 

Ermenegildo Zegna Korea Ltd (the “Company” or “Zegna Korea”) establishes and discloses the Privacy Policy (the “Privacy Policy”) as follows in an effort to proactively protect the personal information of customers collected and processed by the Company and to effectively address any related difficulties experienced by customers pursuant to Article 30 of the Personal Information Protection Act (the “PIPA”).

The Company does not collect personal information from customers under the age of 14 years. Therefore, anyone under the age of 14 years cannot become an online or offline customer of the Company. Anyone that inputs his/her personal information into the Zegna Korea website thereby confirms that they are at least 14 years of age.

2.     Purposes of Processing Personal Information, Items of Personal Information to be Processed and Methods of Collection

<Online>

 

The Company collects the following items of personal information from customers online, through the Zegna Korea website.

  • For creating and managing the customer’s Zegna account: the customer’s name, title and email address are collected and used for purposes of creating and managing the customer’s Zegna account.
  • For contacting Zegna: the customer’s name, title, email address, phone number (if provided), and any other information that the customer voluntarily provides in the content of the customer’s message to Zegna are collected and used for purposes of responding to the customer’s messages.
  • For newsletter registration: the customer’s email address is collected and used for the purposes of providing the customer with Zegna’s newsletter.
  • For reserve in store: the customer’s name, email address, phone number (if provided), country information, appointment date and location, product of interest are collected and used for purposes of providing Zegna Korea’s ‘Reserve in Store’ services.
  • For booking an appointment: the customer’s name, email address, phone number (if provided), country information, appointment date and location are collected and used for purposes of booking an appointment for services provided by Zegna Korea.
  • For made to measure appointment: the customer’s name, email address, phone number (if provided), country information, appointment date and location are collected and used for purposes of providing Zegna Korea’s ‘Made to Measure Appointment’ services.
  • For checkout, shipping and facilitating payment: the customer’s name, address (including city and country, region and zip code), company or c/o information (if entered), phone number, purchase history, card holder’s name, card number, expiration month/year of card, and security code of card are collected and used for purposes of connected to the sale (payments, orders, deliveries), including the pre and post-sale services provided by Zegna Korea, even indirectly, (tailoring, shipping, repairs) and any processing with reference to the sale (such as accounting, fiscal and law obligations as legal warranty), to provide free services within the warranty period, and to facilitate payments.
  • For marketing: items of personal information listed above may be collected and used for the purpose of marketing activities including for studying the customer’s habits and preferences, and sending information and updates on products, sales, promotional campaigns, events and other initiatives.

 

Offline

 

The Company collects the following items of personal information from customers by means of written form (e.g., customer card) through directly owned stores operated by Zegna Korea.

  • The customer’s name, gender, contact information (at least one of either email address or mobile phone number), mail address and country of residence are collected and used for purposes connected to sales (payments, orders, deliveries, order status), pre and post-sale services (tailoring/alteration, shipping, repairs), warranty services, and communicating updates on the service requested.
  • Items of personal information listed above and the customer’s titles, birthday, ID information, store visits, mail address, Wechat ID and purchase history may be collected and used for the purpose of marketing activities including for studying the customer’s habits and preferences, and sending information and updates on products, sales, promotional campaigns, events and other initiatives.

3.     Period of Processing and Retaining Personal Information and Destruction of Personal Information

The Company will only keep customers’ personal information for five years from the last date of the customer’s interaction or until the customer revokes the customer’s consent, unless the information is otherwise required to be retained in accordance with other laws and regulations.

Upon the lapse of the retention period or fulfilment of the purposes of use, the Company will delete personal information in the form of electronic files by a technical method that makes it irrecoverable. Any other personal information printed out in documents will be destroyed by incinerating them or shredding them. The Company selects the personal information for which causes of destruction take place, and destroys the personal information upon obtaining an approval of the Chief Privacy Officer of the Company.

However, the Company must retain certain personal information for designated periods pursuant to other laws and regulations. Retention periods for such information are as follows:

  • Commercial books (such as accounting books and balance sheets) and material business-related documents (including various contracts)
  • Reason: The Korean Commercial Code
  •  Retention period: 10 years
 
  • Transaction-related books and evidentiary documents, tax invoices or receipts
  •  Reason: The Framework Act on National Taxes, the Corporate Tax Act and the Value-Added Tax Act
  • Retention period: 5 years

 

  • Information related to e-commerce
  • Reason: E-Commerce Act
  • Retention period for records on labelling and advertisement: 6 months
  • Retention period for records relating to termination of contract, withdrawal of subscription/membership, payment, supply of goods, etc.: 5 years
  • Retention period for records relating to how consumer complaints and disputes were addressed: 3 years
 
  • Website traffic log
  • Reason: Protection of Communications Secrets Act
  • Retention period: 3 months

4.     Providing Personal Information to Third Parties

The Company processes personal information of customers within the scope set forth under Section 2 hereof, and provides third parties with the personal information collected when it falls under Article 17 and 18 of the PIPA: (i) where consent is obtained from the customer, and (ii) where there are special provisions prescribed by acts.

The Company provides collected customers’ personal information to a third party as below.

 

Recipient Name

Country where Recipient is Located

Recipient’s Purpose of Using the Personal Information

Items of Personal Information to be Transferred

Period of Retention and Use by Recipient

Ermenegildo Zegna Holditalia S.p.A.

Italy

To provide a global customized and personalized customer service; and
marketing activities including for studying the customer’s habits and preferences, and sending information and updates on products, sales, promotional campaigns, events and other initiatives

Same as the personal information items collected in Section 2

Five years from the last date of interaction or until the customer revokes the customer’s consent

5.     Delegation of the Processing of Personal Information

The Company delegates the processing of personal information for efficient processing of personal information as follows:

Delegatee

Contents of Delegated Services

Ermenegildo Zegna Holditalia S.p.A.

IT management and customer relationship management services provider

TFour S.r.l.

Contact Center / Remote Assistant (Outbound Contact)

Arvato Services S.r.l.

Contact Center / Remote Assistant (Outbound Contact)

Reply S.p.A.

e-Commerce platform service

NHN KCP Co. Ltd

Online payment service

Younghwa Roi

Post service

Ilyang Logistics Ltd

Local delivery

When the Company enters into a delegation agreement, the Company implicitly sets forth in the agreement the matters related with liabilities regarding the prevention of personal information processing for purposes other than the purpose of performing the delegated services, technical and managerial measures to ensure security of personal information, restriction of subcontracting, management and supervision of the delegatee, and for compensation for damages pursuant to Article 26 of the PIPA, and supervises the safe processing of personal information by the delegatee.

When the delegatee or content of delegated services is changed, the Company will disclose such changes through this Privacy Policy in a timely manner.

If the Company delegates advertising or soliciting the sales of goods or services, it will notify the customers of the descriptions of the delegated services and the delegatee in writing, by email, fax, telephone, SMS or any other methods.

6.     Additional Use or Provision of Personal Information

The Company may use or provide personal information without the customer’s consent if such use or provision is within the scope that is reasonably related to the original purpose of collection. The Company will consider the following factors when determining whether the additional collection or provision of personal information is within the scope reasonably related to the initial purpose of collection:

  • The purpose of additional use and provision is related to the original purpose for which the personal information was collected;
  • The additional use and provision is foreseeable in light of the circumstances or industry practice;
  • The additional use and provision does not unfairly infringe on the interests of the customer or a third party; and 
  • If the purpose of additional use and provision can be achieved with the personal information being pseudonymized, the Company will pseudonymize the personal information.

 

7.     Overseas Transfer of Personal Information

 

To facilitate the process of personal information, the Company transfers personal information collected online overseas as follows:

Recipient of Personal Information

(Contact information of person responsible for information management)

Country to Which Information is Transferred

Information to be Transferred

Date of Transfer

Method of Transfer

Purposes for which Recipient will Use Information

Retention and Use Period

Ermenegildo Zegna Holditalia S.p.A.

(privacy@zegna.com)

Italy

Same as the personal information items collected in Section 2

Immediately upon collection

Online transmission

Same as Section 4 (recipient’s purposes of using personal information) and Section 5 (contents of delegated services)

Same as Section 4 (period of retention and use by recipient)

TFour S.r.l.

(Info@tfour.com)

Italy

Same as the personal information items collected in Section 2

Immediately upon collection

Online transmission

Same as Section 5 (contents of delegated services)

Same as Section 3 (Company’s period of retention and use)

Arvato Services S.r.l.

(information@arvato.cn)

China

Same as the personal information items collected in Section 2

Immediately upon collection

Online transmission

Same as Section 5 (contents of delegated services)

Same as Section 3 (Company’s period of retention and use)

Reply S.p.A.

(storm.zegna.support@reply.it)

Italy

Same as the personal information items collected in Section 2]

Immediately upon collection

Online transmission

Same as Section 5 (contents of delegated services)

Same as Section 3 (Company’s period of retention and use)

 

8.     Rights and Obligations of Customers and the Method of Exercising Thereof

A customer may request to inspect his/her own personal information that is processed by the Company.

A customer who inspected his/her own personal information may request the Company to correct or delete his/her personal information that is unidentifiable or inconsistent with the facts. However, in cases where such personal information is stipulated to be collected in other laws and regulations, the customer may not request the deletion of such information.

In cases where a customer requests correction or deletion of his/her personal information, relevant personal information will not be used or provided until the correction or deletion is completed. In such cases, if incorrect personal information has been used or provided, such personal information will be immediately corrected.

A customer may request the Company to suspend the processing of his/her own personal information. However, in any of the following cases, the Company may refuse such request after notifying the customer of the reason of such refusal:

  • If there is a special provision in laws or it is inevitable to refuse such request to comply with its obligations under applicable laws or regulations;
  • If such an act will likely to inflict damages upon another person’s life or body or unfairly infringe upon another person’s properties and other interests; or
  • If it is difficult to carry out any contract due to failure in providing services agreed with the customer or otherwise, unless relevant personal information is processed, but the customer has not explicitly expressed his/her intention to terminate such contract.

The personal information that is terminated or deleted by the Company upon request of the customer will be disposed of pursuant to the period of process and retention of personal information under Section 3 hereof.

The request of inspection, correction/deletion or suspension of processing under this Section may be made by filing of the written application with the Company by way of personal delivery, email or facsimile, and the Company will take a step in response to the application without delay. The application may be filed through the agent of the customer.

 

9.     Measure to Ensure the Security of Personal Information

With respect to the processing of personal information of customers, the Company takes various technical and managerial actions to protect the system from hacking or viruses, and controlling access rights to information for ensuring safety in order to prevent the loss, theft, leakage, alteration or damage of personal information.

10.  Chief Privacy Officer

The Company designates the following Chief Privacy Officer responsible for general affairs relating to personal information processing in order to handle customer complaints and damage remedy procedures regarding personal information processing.

Chief Privacy Officer

Name:  Minsuk Lee

Contact: zegna.korea@zegna.com

Department Responsible for Personal Information

Department name:        Zegna Korea CRM team

Person in charge:          Peter Kim

Telephone:       02-2240-6500

E-mail:             CUSTOMERCARE.KOREA@ZEGNA.COM

Customers may direct all questions concerning the protection of personal information, handling of complaints, remedy for damages that occurred in the course of using the services of the Company to the Chief Privacy Officer and the responsible department. The Company will endeavor to immediately answer and deal with customer’s inquiry without delay.

11.  Cookies

 

Cookies (supported in Internet browsers) are small data files that a website sends to computer hard disks for the purpose of storing records. Cookies record information on certain websites that a user frequently visits to enable more useful utilization of websites. The Company uses cookies to store personal information and search it from time to time so that its website can provide customized services to each user. The Company uses these cookies for the convenience of users and not for any commercial purposes.

 

Users who want to reject cookies may choose among the options of their web browser to accept all cookies, confirm every cookie when stored, or block all cookies. However, if a user refuses to install cookies, he/she may face difficulties in receiving services.

 

Example for settings (in case of Internet Explorer): The tool tab on the upper part of the web browser > Internet Option > Personal Information

 

12.  Amendments to Privacy Policy

This Privacy Policy shall take effect from August 14th, 2020. If the Company makes any amendment to this Privacy Policy, the Company shall inform customers of such amendment pursuant to the relevant statutes including the PIPA.

The previous version of the Privacy Policy is as follows.

l Privacy Policy as of August 2019 to August 13th, 2020: [Link to previous Privacy Policy]