The Ermenegildo Zegna Group is aware of the importance of your personal data and for this reason, before any processing activity, it provides you with a complete privacy information notice, asking for the necessary consents.
1. The Data Controller and the Data Protection Officer
The Data Controller is Ermenegildo Zegna HOLDITALIA S.p.A., Via Roma 99/100, 13835 TRIVERO (BI), ITALY (hereinafter referred to as, "Zegna"). Zegna duly appointed the Data Protection Officer, that you may contact for any information about the processing relating to your personal data, writing to email@example.com.
2. Purposes and modalities of the processing
Your personal data (hereinafter, also the “Data”) will be processed:
(i) for purposes strictly connected to the sale (payments, orders, deliveries), including the pre and post- sale services provided by Zegna, even indirectly, (tailoring, shipping, repairs) and any processing with reference to the sale (such as accounting, fiscal and law obligations as legal warranty).
and, having your prior express consent only,
(ii) for commercial and marketing purposes, namely, for sending you, information and updates on products, sales, promotional campaigns, events and other initiatives promoted by Zegna and/or by the companies of the Zegna Group and/or its business partners; by automatic means (such as SMS, instant messaging, email, etc.) as well as traditional means (such as post, phone calls).
(iii) for analysing and studying your spending habits, preferences and selection, in order to propose you products, services and initiatives more responsive to its customers' tastes and needs.
Furthermore, according to your prior express consent, Zegna is also authorized to:
(iv) transmit your Data to the companies of the Zegna Group, and its commercial partners working in the luxury industry as well as car industry, travel industry and consiergerie industry in order to enable them (acting as autonomous data controller) to directly contact you and to offer products and services provided by them, both with automatic means (such as SMS, instant messaging, email, etc.) and traditional means (such as post, phone calls) and for any other distance communication.
The Data will be mainly processed by automatic means and traditional means as some processing activities could be carried out by paper.
Specific security measures will be applied to prevent the lost, the illicit or un-correct use of Data and the non- authorized access.
3. Analysis of costumer's buying habits and selections
As indicated in Section 2 (iii) above, with your express consent, Zegna may also process your Data for the purposes of analysing your habits, buyings and selections, in order to propose to you products, services and initiatives more responsive to your tastes and needs.
Zegna will process, by automatic means, the value purchased within a framework of time, the frequency of the purchases (even if the purchases are made during the sale period) and the kind of product purchased (accessories, clothes, etc.). Zegna may also collect directly from you further information about your preferences, hobby, habits, lifestyle and favorite sports. This information may be also collected from social media platform or cookies used on the Zegna website. This would only happen if you had previously accepted the transfer of some of your personal data from the chosen Social during the social log-in registration and if you had authorized the use of analytical and marketing cookies through the methods indicated on the website.
Furthermore, Zegna may complete, correct and update some of your Data with public information, within the limits of relevance and not exceeding the consent provided and the purposes for which the personal data were collected. The study is only intended to propose to client products, services and initiatives more responsive to their tastes and needs. Zegna will not proceed with an intrusive study of the costumers’ behaviour. At any time, you are entitled to ask to analyze your profile and update or modify it, as you prefer.
4. Legal basis of the processing activities and storage period
The data processing is based on:
- the fulfilment of contractual and pre/post contractual obligations as well as the fulfilment of specific law obligations arising from the contract (such as accounting, fiscal obligations, legal warranty) or for the legal defence of the Data Controller, with regard to the sale activities as per Section 2 (i);
- the specific explicit consent given by the costumer, with regard to the activities specified in Section 2 (ii), (iii) e (iv) (Marketing, Study of Preferences, Communication of Data).
Personal Data will be storage for different period of time, according to the specific purpose for which they were collected: (a) personal data linked to the purchase will be stored for maximum 10 years, in compliance with tax and civil law; (b), personal data provided for marketing and profiling activities are kept for a period no longer than 5 years from the provision.
5. Mandatory or voluntary nature of providing data
The provision of personal data is not mandatory. However:
- the failure of personal data, with regard to the sale activity as per Section 2 (i), may make it impossible for Zegna to finalize the sale or to provide you the relevant services;
- the failure of personal data, with regard to the activities as per Section 2 (ii), (iii), (iv), may make it impossible for Zegna to purpose customized products and services, to send you information about products, materials, updates, and invitations to the events organized by the Zegna or by the Zegna Group and/or its business partners. However, it does not limit the sale and the services stricly related to it.
6. Categories of recipient of personal data
The Data can be disclosed by:
- other companies belonging to the Zegna Group,
- commercial partner of the Zegna Group;
- third party suppliers (IT service supplier, technical service supplier, postal services supplier, supplier of service strictly related to the sale);
- employees and consultants;
- third parties as Banks, Public Authorities, companies providing payment services (with reference to the processing and purposes as per Section 2(i) above).
The above mentioned subjects will act as data processors or persons authorized to the processing and provided with the relevant instructions from the Data Controller, or as autonomous data controllers.
7. Transfers outside European Union
The Data will not be disseminated. The Data may be transmitted abroad, including outside the European Union, in view of the cross-border nature of the Zegna Group (especially, the cross-border nature of the services provided by Zegna itself through its boutique and through the companies belonging to the Group and situated all over the world).
In any case, the Data will be transfer outside European Union only and if adequate levels of protection and sufficient safeguards, as provided for by the law, are guaranteed, such as “Standard Model Clauses” approved by the European Commission. For more information about the location of data and to ask a copy of your personal data, please contact the Privacy Protection Officer.
8. Your rights
Under article 7 of the Legislative Decree n. 196/2003 and under articles 15, 16, 17, 18, 20 and 21 of the Regulation (UE) 2016/679, you are entitled to: (a) access to the personal data concerning yourself; (b) request and obtain an update or correction of the Data concerning yourself, obtain restriction of processing of Data concerning the data subject (including, the right to erasure and right be forgotten, if applicable); (c) object, in part or in full, for legitimate reasons, the processing of personal data concerning yourself as well as ask for the data portability; (d) lodge a complaint with a supervisory authority; (e) ask for the logic applied by analyzing your buying habits and selection and ask to modify the relevant results. You are also entitled to withdraw consent at any time with regard to the activities as per Section 2 (ii), (iii), and (iv) (Marketing, Study of Preferences, Communication of Data) The right to object may also be exercised specifically with regard to one or more methods of sending marketing communications.
At any time, you are entitled to ask for a complete list of the appointed data processors by contacting Zegna, at the attention of the Data Processor Officer, Via Roma 99/100, 13835 TRIVERO (BI), ITALIA, at the following e-mail firstname.lastname@example.org.
Please note that if you ask not to be contacted by electronic means, such no-contact instruction will be automatically recorded also for communication delivered by traditional means, except if you specify to be contacted only by post of telephone.
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Selling your information: we have not sold personal information in exchange for monetary compensation. We may allow certain third parties (such as certain advertising partners) to collect your personal information via automated technologies on our platforms in an effort to serve you content and advertisements that may be of interest to you on our behalf. You have the right to opt out of this disclosure of your information, as described in the cookie section.
Your rights: subject to exceptions under applicable law, you may have certain choices regarding our use and disclosure of your personal information, as described below:
Access: you have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected about you during the past 12 months and details regarding our collection, use, disclosure of such information.
Deletion: you have the right to request that we delete the personal information we have collected from you subject to certain exceptions.
Opt-Out: You have the right to manage the activation of the cookies as described in the cookie section.
To exercise your rights, described above, you can:
- call the 844-609-3462 from Monday to Friday from 9:00am to 9:00pm (EST, excluding public holidays); or
- write to Customer Care email@example.com of the Website; or
- contact us directly at firstname.lastname@example.org. If you exercise your rights, we may require you to provide certain information to verify your identity (such as your name, email address, phone number and/or address).
No discrimination: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us.
Personal, family and household clients: California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email message to email@example.com with "Request for California Privacy Information" in the subject. You may make such a request up to once per calendar year. If applicable, we will provide you with a list of the categories of personal information disclosed to third parties for their direct marketing purposes during the preceding calendar year, along with the third parties' names and addresses. Please note that all the rights granted by the EU privacy Regulation remains not affected.