Legal area / Privacy Policy
- Data processed, purpose of processing and legal basis of processing
- Processing Methods
- Data retention
- Nature of data provision and consequences in case of non-provision
- Categories of subjects to whom data may be communicated
- Data Subject Rights
- California privacy rights
- Joint use - exclusively for Japan
- Data Protection Officer
- Sources of the data
- Minors
- Data security and personal data breaches
- Changes to this notice
Giorgio Armani S.p.A., with registered office at Via Borgonuovo 11, 20121 Milan (MI), the Local Giorgio Armani Companies and the other Companies of the Armani Group, operating in the fashion, beauty, lifestyle, catering, food & beverage, furnishing, hospitality and club sectors (collectively, the Companies of the Armani Group), in their capacity as data controllers and whose list is available by writing to privacy@giorgioarmani.it, hereby inform you as follows regarding the processing of your personal data ("data") pursuant to applicable privacy laws ("Privacy Law").
1. Data processed, purpose of processing and legal basis of processing
The Companies of the Armani Group process common data (identification, personal, contact, financial, location and browsing data) for:
a) performance of contractual obligations or pre-contractual measures taken at the request of the data subject, namely:
• to manage the sale of Giorgio Armani products and services and the related after-sales services (for example exchanges, returns and warranty, customer care and customer service, product delivery, etc.);
• to manage e-commerce and related services such as registration and interaction with our websites and Apps and the use of services reserved for registered users (for example, Wish List, My Orders, Quick Purchase, etc.);
b) compliance with legal or regulatory obligations: namely to manage the legal obligations relating to sales activity (such as the issuance and retention of invoices), the handling of requests to exercise rights regarding the processing of personal data, and the notification of any data breaches;
c) legitimate interest of the controllers:
• for the prevention and repression of fraud and abusive conduct (including by third parties) contrary to applicable law (for example, intellectual property), contractual provisions, and the rules of fairness and good faith, as well as for the handling of any complaints and legal defence;
• to carry out aggregate statistical analyses aimed at measuring the number of conversions of a given advertisement, for organisational purposes, using the e-mail address you provided only if you have given your consent to profiling cookies, as set out in the Cookie Policy.
Giorgio Armani S.p.A. also processes common data for:
d) subject to your consent:
• for marketing purposes: namely to send you informational communications about products, services, events and promotions of the Companies of the Armani Group. Marketing activities are carried out through the contact methods you have chosen and which you may change at any time, and every marketing communication includes a link to object, free of charge and at any time, to further mailings;
• for the purpose of tracking e-mail opens: namely to insert into e-mail communications a tracking pixel, i.e. an invisible image that makes it possible to detect the opening of messages, in order to measure interest in our communications and, where you have given consent for marketing purposes, to personalise their content and frequency. You may disable such tracking at any time through the preference management page accessible from the link contained in each communication or from your Personal Area, while continuing to receive e-mails without the pixel;
• for analysis purposes: namely to analyse, including by automated means, your preferences, habits and lifestyle, as well as the details of your purchases. The data are used to create group and/or individual profiles ("analysis"), market and statistical analyses, including with anonymous data, organised in aggregate form. Where you also give consent for marketing purposes, we will send you personalised communications based on the analysis of your preferences and interests;
• for geolocation purposes: namely to allow you to share your geographical position and book a product online at Giorgio Armani stores, as well as to find the nearest Giorgio Armani store.
2. Processing Methods
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, communication, erasure and destruction of data. More precisely, with regard to the purpose of analysis , 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.
3. Data retention
The data are retained for the time strictly necessary to pursue the purposes for which they are collected and to comply with applicable legal and regulatory obligations. The retention period varies according to the purpose of the processing, in particular:
· for the activities necessary to perform the contract relating to the provision or sale of our goods and services referred to in point 1, letter a) of this notice, the data are retained for administrative-accounting purposes for ten years from its conclusion, except for registration on the Site ("My Account") and the use of services reserved for registered users (for example: Wish List, My Orders, Quick Purchase, etc.), in relation to which your personal data will be retained until you request the deletion of your account and in any case for no more than seven years. Retention for longer periods occurs where authorised by law and in the event of the defence of rights in legal proceedings;
· for the marketing and analysis purposes referred to in point 1, letter d) of this notice, the data are retained for a period of seven years;
· for the geolocation purpose referred to in point 1, letter d), the data are retained for the time necessary to use the service;
· for the activities necessary to comply with legal obligations referred to in point 1, letter b) of this notice, the data are retained for the time necessary to pursue the purposes and in any case for no more than ten years;
· for the activities necessary for the prevention and repression of fraud and abusive conduct referred to in point 1, letter c) of this notice, the data are retained for the time necessary to pursue the legitimate interest of the controller and in any case for no more than ten years;
· for the activities necessary to carry out aggregate statistical analyses on an individual basis aimed at measuring the number of conversions of a given advertisement, referred to in point 1, letter c) of this notice, the data are retained for the time necessary to pursue the purposes described above, subject to the exercise of objection, and in any case by Google for a maximum period of 140 days.
We remind you that you may at any time withdraw your consent in the ways indicated below for the exercise of rights. Upon expiry of the periods indicated above, the data are automatically deleted or rendered anonymous in a permanent and irreversible manner, except where the Companies of the Armani Group are required to retain the data for a further period in order to comply with legal or regulatory obligations.
4. Nature of data provision and consequences in case of non-provision
For the purposes referred to in point 1, letters a), b), c) above, the provision of data is necessary and any refusal to provide it would prevent the indicated activities 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 consequence on the possibility of purchasing Giorgio Armani products and services
5. Categories of subjects to whom data may be communicated
The data are accessible to the Companies of the Armani Group, where necessary, and to our duly authorised personnel. The data are 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, which act as our data processors on the basis of our instructions.
The data are disclosed to third parties in the following cases: (i) when the disclosure is required by applicable laws and regulations with respect to legitimate third-party recipients of communications, such as public authorities and bodies, which act as independent data controllers for their respective institutional purposes; (ii) disclosure to third parties (such as current or proposed assignees, transferees, participants or sub-participants in rights or in our business), independent data controllers, in the event of extraordinary transactions (for example mergers, acquisitions, business transfers, etc.). The data are not disseminated, except in the case of particular initiatives (for example, online) in relation to which we will provide you with specific information on the occasion of such initiatives.
Some of the Companies of the Armani Group and some of our service providers who have access to the data may be established abroad in third countries. Giorgio Armani S.p.A. assesses the level of protection offered by the importing country and adopts the necessary safeguards, contractual and otherwise, such as an adequacy decision of the European Commission (Article 45 GDPR) or appropriate safeguards pursuant to Article 46 GDPR, including the Standard Contractual Clauses, of which you may request a copy, for a lawful transfer of the data and to ensure an equivalent level of protection of the data transferred abroad. You may request information on the list of the Companies of the Armani Group, 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 9.
6. Data Subject Rights
You may contact Giorgio Armani S.p.A. at any time, also on behalf of the other Companies of the Armani Group, to exercise the rights granted to you under applicable Privacy Laws (such as: obtaining confirmation of whether or not your data exist, accessing the data, verifying their content, origin and accuracy, requesting their integration, updating, rectification, erasure, anonymisation, requesting data portability, the restriction of processing, objecting to the processing for reasons connected with your particular situation and, in the case of direct marketing, at any time (Article 21 GDPR), withdrawing at any time the consent given without prejudice to the lawfulness of processing based on consent carried out before the withdrawal (Article 7(3) GDPR), not being subject to decisions based solely on automated processing, including profiling, which produce legal effects or similarly significantly affect you (Article 22 GDPR)) through any channel and preferably at the mailbox privacy@giorgioarmani.it. You may at any time lodge a complaint with the competent authority pursuant to Article 77 GDPR. You may also give instructions regarding the processing of your personal data for the period following your death (post-mortem directives) pursuant to Article 2-terdecies of the Italian Privacy Code.
7. California privacy rights
8. Joint use - exclusively for Japan
Please see this section here: https://www.armani.com/it-it/legal/joint-use-exclusively-for-japan/
9. Data Protection Officer
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: dpo@giorgioarmani.it.
10. Sources of the data
We collect your data partly directly from you (for example when you make a purchase, create an account, subscribe to our communications or contact us) and partly indirectly, through your devices and the cookies or similar tools present on our websites and Apps. In any case, we process only the data necessary for the purposes indicated in this notice.
11. Minors
Giorgio Armani does not collect registrations of minors under 18 years of age. Should we become aware of having collected the data of a minor under 18 years of age, we will delete them without undue delay.
12. Data security and personal data breaches
We adopt appropriate technical and organisational measures to protect your data against unauthorised destruction, loss, alteration, disclosure or access, including the encryption of communications between your device and our systems, the limitation of access to authorised personnel on a strictly necessary basis and the related confidentiality obligations. In the event of a personal data breach, we adopt the measures provided for by applicable law and, where the conditions are met, we notify the breach to the competent supervisory authority and communicate it to the data subjects pursuant to Articles 33 and 34 of the GDPR.
13. Changes to this notice
Giorgio Armani S.p.A. reserves the right to modify this privacy notice at any time. The amended notice will be published on our website, on our intranet or sent by email or other means of communication. In the event of substantial changes, we will give notice with adequate advance notice before they take effect. Last updated: [●].