Giorgio Armani S.p.A., with offices in Via Borgonuovo 11, 20121 Milan (MI), the Local Giorgio Armani Companies and the other Armani Group Companies, operating in the fashion, beauty, lifestyle, catering, food & beverage, furniture, hospitality, club sectors (all collectively “Armani Group Companies”), in their capacity as data controllers—a list of which is available by writing to email@example.com—inform you of the following regarding the processing of your personal data (“data”) under the applicable privacy laws (“Privacy Laws”).
- 1. Data processed, purpose of processing and legal basis of processing
- 2. Processing Methods
- 3. Data retention
- 4. Nature of data provision and consequences in case of non-provision
- 5. Categories of subjects to whom data may be communicated
- 6. Data Subject Rights
- 7. California privacy rights
- 8. Joint use - exclusively for Japan
- 9. Klarna Chat
- 10. Data Protection Officer
The Armani Group Companies process common data (identifiers, personal data, contact data, financial data, localisation data and navigation data) for:
a) fulfilment of contractual obligations or execution of pre-contractual measures towards the data subject, i.e.:
- to manage the sale of Giorgio Armani products and services and related after-sales services (e.g. exchanges, returns and warranty, customer care and customer service, product delivery, etc.);
- to manage e-commerce and related after-sales services, registration and interaction with our sites and apps, and the use of services reserved for registered users (e.g., Wish List, My Orders, Quick Purchase, etc.);
b) fulfilment of legal or regulatory obligations: i.e. to manage legal obligations relating to the sales activity (such as the issuance and storage of invoices), the management of requests for exercising rights regarding the processing of personal data, the communication of any data breaches;
c) legitimate interest of the Data Processors: i.e. for the prevention and prosecution of fraud and abusive behaviour (including by third parties) that conflict with current regulations (e.g., intellectual property), contractual provisions, rules of fairness and good faith, as well as for the management of any claims/complaints and defence in court.
Giorgio Armani S.p.A. also processes personal data:
d) after you have given your consent:
- for marketing purposes: i.e. to send you information communications about products, services, events and promotions of the Armani Group Companies. Marketing activities are carried out using the contact methods chosen by you from those below, which you may modify at any time;
- for analysis purposes: i.e. to analyse, also via automated means, your preferences, habits and lifestyle, as well as the details of the purchases made. The data is used for the creation of group and/or individual profiles (“analysis”), market and statistical analyses, including with anonymous data organised in aggregate form. Where you also provide consent for marketing purposes, we will send you personalised communications based on analysis of your preferences and interests;
- for localisation purposes: i.e. to allow you to share your geographical location and reserve a product online at Giorgio Armani stores (“click & reserve”), as well as discover the nearest Giorgio Armani store (“Store Locator”).
The data are processed with and without the aid of electronic tools, based on logic and procedures consistent with the purposes indicated above and in compliance with Privacy Laws, including confidentiality and security profiles. Processing takes place through the collection, recording, organisation, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, erasure and destruction of data. More precisely, with regard to the analysis process, we inform you that the data are organised in group profiles in aggregate and/or individual form based on the preferences and interests communicated by you.
The data is kept for as long as is strictly necessary for the pursuit of the purposes for which it is collected and for the fulfilment of applicable legal and regulatory obligations. The storage period is different depending on the purpose of the processing, in particular:
- for the activities necessary for the performance of the contract relating to the performance or sale of our goods and services referred to in point 1, letter a) of this Policy, the data are stored for administrative-accounting purposes for ten years from the conclusion of the same, except for registering with the Site (“My Account”) and using the services reserved for registered users (for example: Wish List, My Orders, Quick Purchase, etc.), in relation to which your personal data will be stored until you request the deletion of your account and in any case for no longer than seven years. Retention for longer periods takes place if authorised by law and in case of defence of rights in court;
- for the marketing and analysis purposes referred to in point 1, letter d) of this Policy, the data are stored for a period of seven years;
- for the location purposes referred to in point d), the data are stored for the time necessary to use the service;
- for the activities necessary for the fulfilment of legal obligations referred to in point 1, letter b) of this Policy, the data are stored for the time necessary to pursue the purposes and in any case for no longer than ten years;
- for the activities necessary for the prevention and prosecution of fraud and abusive behaviour referred to in point 1, letter c) of this Policy, the data are stored for the time necessary to pursue the legitimate interest of the Data Controller and in any case for no longer than ten years.
Please note that you can withdraw your consent at any time in the manner indicated below to exercise your rights. At the expiry of the aforementioned periods, the data will be deleted automatically, or anonymised permanently and irreversibly, unless the Giorgio Armani Companies are required to store the data for an extended period in order to comply with legal or regulatory requirements.
For the purposes referred to in point 1, letter a), b), c), d) above, the provision of the data is necessary and any refusal to provide it would prevent the activities indicated from being carried out. The provision of data for the purposes referred to in point 1, letter d) above is, instead, optional and any refusal will have no effect on the possibility of purchasing Giorgio Armani products and services.
The data are accessible to the Armani Group Companies, where necessary, and to our duly authorised staff. The data is also shared with our service providers, for example for technical and organisational services functional to the purposes indicated above, including in associated form, shipping, marketing and payment management companies, who act as our Data Processors on the basis of our instructions.
The data are communicated to third parties in the following cases: (i) when disclosure is required by applicable laws and regulations with respect to legitimate third parties receiving communications, such as public authorities and bodies, who act as independent data controllers for their respective institutional purposes; (ii) communication to third parties (such as current or proposed assignees, transferees, participants or sub-participants in rights or our business), independent data controllers, in case of extraordinary operations (e.g. mergers, acquisitions, company transfers, etc.). The data are not disseminated, except in the case of particular initiatives (e.g. online) in respect of which we will provide you with specific information at the time.
Some of the Armani Group companies and some of our service providers who have access to data may be established abroad in third countries. Giorgio Armani S.p.A. evaluates the level of protection offered by the importing country and takes the necessary precautions, contractual and otherwise, for a legitimate transfer of data and to ensure an equal level of protection of data transferred abroad. You may request information on the list of Armani Group Companies, the list of service providers and the transfer of data abroad by contacting Giorgio Armani S.p.A. or the Data Protection Officer of Giorgio Armani S.p.A. at the contact details indicated in paragraph 11.
You may contact Giorgio Armani S.p.A. at any time, also for the other Armani Group Companies, to exercise your rights under applicable Privacy Laws (such as: obtain confirmation of the existence or not of your data, access the data, verify the content, origin, correctness, ask for amendments, updates, rectification, cancellation, anonymisation, ask for data portability, restriction of processing) through any channel and preferably to firstname.lastname@example.org. You may at any time lodge a complaint with the competent authority pursuant to art. 77 GDPR.
The Data Protection Officer is Rödl & Partner, established at Via Largo Donegani 2, 20121 Milan, represented by the Data Protection Department Officer, who can be contacted at the following email address: email@example.com.