ERMENEGILDO ZEGNA GROUP
Effective Date: July, 2014
At Ermenegildo Zegna Group, we understand the importance of informing and empowering our customers regarding the privacy of the personal information we collect in our stores and through our website(s), mobile applications, social media and other online services.
Under EU legislation, a "data controller" is one who "alone or jointly with others determines the purposes and means of the processing of personal data" (hereinafter the "Data Controller") and a "data processor" is one who "processes personal data on behalf of the controller" (hereinafter the "Data Processor").
- Ermenegildo Zegna HOLDITALIA S.p.A., Via Roma 99/100, 13835 TRIVERO (BI), ITALY, and EZI S.p.A, Via Trieste 13, Biella, Italy (hereinafter collectively, "Zegna" or "We").
- For online transactions, including delivery, and website maintenance, YOOX NET-A-PORTER GROUP S.p.A., via Morimondo, 17 – Milano 20143(Italy) is also a data controller.
2. WHAT PERSONAL DATA WE COLLECT
"Personal Data" is information that can be used to uniquely identify or contact a single person. Also iInformation of a non-personal nature, when strictly linked to Personal Data, shall also be considered as Personal Data.
a. Customer service
When you contact us, we collect Personal Data that helps us understand and respond to your comments or inquiries, including your contact information (e.g., name, mailing address, email address, telephone number).
b. Subscription to Zegna mailing list
When you subscribe to our mailing list to receive our newsletter and other product updates and information, we collect as Personal Data your contact information, including your name, mailing address, e-mail address, and country and telephone number.
c. Zegna accounts
When you create a Zegna account, we collect as Personal Data your contact information (e.g. name, mailing address, email address, telephone number), certain demographic information (e.g., gender, date of birth), and other customer information and preferences.
d. Purchases and related transactions and services
When you purchase, exchange, or return items, we collect as Personal Data (a) your contact information (e.g., name, mailing address, e-mail address, telephone number), (b) information about the items (e.g., product description, price), and (c) payment information (e.g., credit card number). If the items are altered and/or delivered, we collect as Personal Data the information required to provide those services, including your contact information and delivery address.
e. Customer postings
When you post in a public space such as on our website(s), we collect as Personal Data the posted information as Personal Data.
When you submit an application through the "career" section of our website(s), we collect as Personal Data the information you submit, including contact information (e.g., name, mailing address, e-mail address, telephone number), your resume, and other information your provide regarding your education, current employment, and knowledge of foreign languages.
g. Browsing our website
When you visit or leave our website, we receive and collect, as Personal Data, the URL (uniform resource locator) of the website that you came from and the website you visit when you leave us. We also receive and collect the IP (internet protocol) address of your computer, the type of operating system and web browser you are using, your mobile device identifier and operating system (if you access the website using a mobile device), and the name of your ISP (internet service provider) or your mobile carrier. We may also receive and collect location data, which we may use to improve the services we offer you and for marketing purposes. For example, we may use your location data to identify stores that are close to you and/or special promotions in those stores.
3. HOW WE USE PERSONAL DATA
a. Manage your account, process transactions and provide services you request
We use your Personal Data to create and manage your account; to process orders, exchanges, and returns; and to provide related services, including services offered by third parties such as alterations and delivery.
b. Improve our understanding of your needs and interests
We use your Personal Data to understand your needs and interests in order to improve our products and services and customize our marketing communications. For example, we may propose certain products and send you invitations to in-store events and special offers based on your purchasing history.
c. Zegna newsletter and marketing communications
We use your Personal Data to distribute the Zegna newsletter and for other marketing communications. Marketing communications may be made by phone (including SMS), mail or email. For example, in addition to product catalogs, we may send you product announcements, special offers and promotions, gifts, invitations to in-store events, and requests to participate in surveys and other market research.
d. Other Zegna communications
We use your Personal Data to communicate with you for reasons other than marketing. These communications may be made by phone (including SMS), mail or email. For example, we may use your information to respond to inquiries and to thank you for shopping with us.
We use your Personal Data submitted through the "career" section of our website for hiring and recruitment.
4. WHO HAS ACCESS TO YOUR PERSONAL DATA
a. Sharing information with Zegna affiliates and controlled companies
We may share your Personal Data with Zegna affiliates and controlled companies in connection with services (e.g., purchases, credit card payments, alterations, delivery), marketing (e.g., newsletters, catalogs, market and statistical research and analysis), and internal business and administrative functions (e.g., management/maintenance of our website, accounting, legal).
b. Sharing information with third parties
Zegna and Zegna affiliates and controlled companies may share your Personal Data with third -parties that provide or assist in carrying out the services, marketing, and internal business and administrative functions referenced above, such as franchisees, licenscees, banks, insurance companies, legal advisors, and marketing and public relations firms. These third-party service providers include but are not limited to the following: United Parcel Service, for the management of delivery to you of your purchases; BT Italia S.p.A., for the maintenance of the YOOX NET-A-PORTER GROUP S.p.A. Servers; Banca Sella S.p.A., for the management of electronic payments services with credit/debit cards; Contact Lab, for the sending of newsletters; InterConnexiaLDA, for the data processing for call centers and customer care services users of our website(s); Mas Factory S.r.lL. (also appointed as Data Processor), for the realization and the sending of paper and electronic advertising and promotional materials; Altamira sS.r.l., c.so Magenta, 53, Milano 20123, for recruitment purposes; and Ten Lifestyle Management Limited, for the management of certain services related to the Zegna World Pass Program.
Zegna and Zegna affiliates and controlled companies do not share your Personal Data with third parties for their direct marketing purposes.
c. Compliance with legal process and other disclosures
Zegna and Zegna affiliates and controlled companies may disclose your Personal Data when required by law, subpoena or other legal process, or if Zegna has a good- faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected illegal activities or to assist government enforcement or regulatory bodies; (2) enforce the Terms and Conditions of Sale and/or Terms and Conditions of Use, and to defend ourselves against any third-party claims or allegations, or protect the security or our website and business; or (3) exercise or protect the rights, property, or safety of Zegna, our affiliates, our customers, our employees, or others.
d. Disclosures as the result of a change in control or sale of Zegna
e. Statistical Iinformation
Statistical information about website(s) usage, sales patterns, traffic volumes and related matters may be communicated to third parties for analysis.
5. YOUR RIGHTS AND CHOICES REGARDING YOUR PERSONAL DATA
a. You may choose not to provide your Personal Data
You may choose not to provide your Personal Data.
Kindly consider, though, that if you choose not to provide your Personal Data or provide incomplete and/or incorrect Personal Data, we may not be able to create a Zegna account for you and may prevent Zegna and Zegna affiliates and controlled companies, as well as their third-party service providers, from providing services you may have requested.
b. You may contact us to review, update or delete your Personal Data
You may exercise the rights provided by article 7 of the Italian Privacy Code and article 12 of EU Directive 95/46/EC.
Upon your request, Zegna will freeze your Personal Data oin its database and, to the extent it is technically feasible, remove itthem from its database. You may also inspect your Personal Data and/or request that your Personal Data be corrected, amended or deleted upon written request. Please note that Zegna will not remove your Personal Data from its records to the extent it is necessary for any continued obligations or liabilities of Zegna or Zegna affiliates and controlled companies or to the extent that such information must be retained by operation of law.
c. You may opt out of receiving our newsletter and marketing communications
To opt -out offrom receiving the Zegna newsletter or other marketing communications, you may either use the opt-out link contained in each such communication or send an email requesting an opt-out to firstname.lastname@example.org. Opting out will trigger the automatic deregistration from any Zegna communication and/or service.
d. You can control cookies and other tracking tools
6. OTHER IMPORTANT INFORMATION