Privacy policy

Salvatore Ferragamo S.p.A. with registered offices at Via de’ Tornabuoni 2, 50123, Firenze (hereinafter, “Salvatore Ferragamo”) and each company of the Salvatore Ferragamo Group which may process personal data under the circumstances specified below (the “Relevant Company” and, jointly, with Salvatore Ferragamo, “Ferragamo”) are committed to protecting the online privacy of the users of its websites and social network pages. As such, this Privacy Policy has been written in order to allow you to understand Ferragamo’s policy regarding your privacy, and how your personal information will be handled when using our websites (www.ferragamo.com, group.ferragamo.com, csr.ferragamo.com hereinafter, collectively, "Website") and when browsing and interacting with social network pages (on Instagram, Spotify, Facebook, Twitter, LinkedIn, YouTube, Pinterest, Weibo, LINE, etc. “Social Pages”). This Privacy Policy will also provide you with information so that you are able to consent to the processing of your Personal Data in an explicit and informed manner, where appropriate.

The information and data which you may provide, or which may otherwise be collected in the context of your use of Ferragamo’s services – e.g., access to reserved areas in the Website, browsing the Social Pages, contacting the Salvatore Ferragamo Group’s customer care through the Website or Social Pages, etc. (hereinafter, the "Services") – will be used by Ferragamo in compliance with the internationally recognized data protection principles. This means, in particular, that any Personal Data processing carried out by Ferragamo will respect the principles of lawfulness, fairness, transparency, purpose limitation, storage limitation, data minimization, accuracy, integrity and confidentiality.

CONTENTS

1. Data Protection Officer
2. Personal Data processed
   1. Browsing data
   2. Special categories of Personal Data
   3. Data provided voluntarily by the data subject
   4. Data referred to Data Subjects and collected from third parties
   5. Purchase data
   6. Location data
   7. Cookies
3. Purpose of the processing
4. Legal bases, data controllership and mandatory / discretionary nature of the processing
5. Recipients of Personal Data
        a. Disclosure of Purchase Data for anti-Misuse/Fraud
6. Transfers of Personal Data
7. Retention of Personal Data
8. Data subjects’ rights
9. Amendments
10. Additional information concerning local processing, where applicable, and privacy laws

1.1. At the address privacy@ferragamo.com you may contact the DPO of the Ferragamo Group.

2.1. As you use the Website or Social Pages, we inform you that Ferragamo may collect and process information related to you as an individual and which allows you to be identified (either directly or together with additional information), or which is related to other individuals (“Personal Data”), such as your name, an identification number, an online ID or one or more characteristic elements of your physical, physiological, mental, economic, cultural or social identity.

2.2. Personal Data which may be processed by Ferragamo through the Website and/or Social Pages are as follows:

1. Browsing Data

   2.A.1. The Website’s operation, as is standard with any website on the Internet, involves the use of computer systems and software procedures, which collect information about the Website’s users as part of their routine operation. While Ferragamo does not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information, or by using other information collected – as such, this information is also considered Personal Data.

   2.A.2. This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the Website, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on.

   2.A.3. These data are used exclusively to compile anonymous, statistical information on the use of the Website, as well as to ensure its correct operation and identify any faults and/or abuse of the Website – the data is deleted immediately after processing, unless it must be used to identify responsible parties in the event of cybercrime committed which harms the Website or third parties, in which case information on web contacts may be kept for a period of 7 (seven) days.

2. Special categories of Personal Data

   2.B.1. Where registering an account to the Website, or in the "Human Resources", “Contact”, “Thesis Support” or “Internship” section of the Website of Salvatore Ferragamo, you are allowed to submit Personal Data which may fall under special categories of Personal Data – i.e. data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

   2.B.2. While this should not prevent you, for example, from submitting your CV for a job application through the Website, Ferragamo asks that you do not disclose any such types of Personal Data, unless you consider this to be strictly necessary. Indeed Ferragamo remind you that if you disclose such special categories of Personal Data in absence of an explicit consent to process them, Ferragamo may not in any case be held liable.

   2.B.3. In any case, Ferragamo stresses the importance of providing your explicit consent to process special categories of Personal Data if you decide, nonetheless, to share it.

   2.B.4. Please note that, for purposes of selection of an applicant to a certain position, Ferragamo may decide to analyse the professional social media profiles which you make freely available on the Internet (e.g. LinkedIn).

3. Data provided voluntarily by the data subject

   2.C.1. When using some of the Website’s Services (e.g., when using the “Contact” form, where registering an account on the Website, where applying for an Internship or for Thesis Support in the relevant section of the Website, where answering to a Survey), you are allowed to submit Personal Data related to other persons.

   2.C.2. In any situation where you decide to share Personal Data related to other persons through the Website, you will be considered as an independent data controller regarding that Personal Data, and must assume all inherent legal obligations and responsibilities. This means that you must also must make sure that you have these third parties’ consent to their Personal Data being used in this manner before providing them to Ferragamo, or another appropriate legal basis which may allow for lawful processing of this information.

   2.C.3. To this end, you must fully indemnify Ferragamo against any complaints, claims or demands for compensation for damages which may arise from the processing of this Personal Data, initiated by the third parties whose information is processed via the Website by your initiative.

4. Data referred to Data subjects and collected from third parties

   2.D.1. Your Personal Data may be collected from third parties. This happens, for example, when your Personal Data is collected from a third party autonomous data controller in order to provide you with services you have requested (e.g. Alibaba for services requested by by Ferragamo Fashion Trading (Shanghai) Co. Ltd’s customers, third parties who offer services in relation to the purchase of Ferragamo products). In this case, the third party will communicate your Personal Data to Ferragamo because they have contractually assured us that they have obtained your consent or have another legal basis that legitimizes the communication/sharing of your data with Ferragamo. On this point, Ferragamo is strongly committed to verifying the conformity of the data it receives before its use. In this case, the third party will communicate your Personal Data to Ferragamo and Ferragamo will inform you of how we process your Personal Data at the first relevant occasion. Ferragamo confirms that, in such cases, you may, at any time, exercise your rights, request information on the origin of your Personal Data and/or request its deletion by contacting us via the modalities specified in section in section 8 of this Policy.

5. Purchase Data

   2.E.1. You may use the Ferragamo e-commerce platform either as a registered user or as a guest user. When you purchase Ferragamo products on the e-commerce platform of the Website, the Personal Data you provide in the context of the process relating to the transaction and, where you have registered, the Personal Data you provide as a registered user of the Website (jointly referred to as the “Purchase Data”) will be collected and processed by Ferragamo to manage your Sale and to prevent Misuse / Fraud in payments, as better described in section 3 of this Privacy Policy.

   2.E.2. When you consent to the Profiling purpose, as described in Paragraph 3 below, Purchase Data are analysed by Ferragamo in order to provide you with promotional material which you may find more relevant to your preferences.

6. Location Data

   2.F.1. For providing you with more precise and useful Services, Ferragamo may ask you to enter your address, postcode or simply the Country where you are to find the Ferragamo boutique closest to you, for example for the purposes of Reserve, Pick-up and Ship to Store, as better defined in paragraph 3 below.

   2.F.2. Alternatively, and under your previous and explicit consent, your Internet navigation programme (“Browser”) may share with the Website an approximation of your geographic location through information on wireless access points close to you and on your IP address of your device.

   2.F.3. In both cases, it is an optional use of Personal Data but extremely useful Ferragamo for proving you even more useful Services. If you think that sharing your approximate location through your Browser is invasive, you may revoke at any time your consent changing the settings of your Browser (or settings of you operating system). To obtain more information we invite you to read the specific privacy notice of your Browser.

   2.F.4. When you activate a Smart Tag within a Ferragamo product by means of your device, through the Near Field Communication (NFC) technology, in order to access further information on the product, Ferragamo will have access to the generic IP location, but without being able to precisely locate you. The same generic localisation takes place for Anti-Counterfeiting purposes.

7. Cookies

   2.G.1. Information regarding the use of cookies is available in the Cookie Policy at the following link: https://group.ferragamo.com/en/cookie-policy

3.F.1. Ferragamo intends to use your Personal Data, collected through the Website and/or the Social Pages, for the following purposes:

• to verify your identity and assist you, in case you lose or forget your login / password details for any of your personal accounts; to enable you to consult your purchase history and to save your preferred products (“Client Management”);
• to send you the newsletters for which you have subscribed as a Service, containing only informative and not marketing content, e.g. preview of new collections (“Newsletter”);
• to browse and interact with Ferragamo’s Social Pages (e.g. Facebook, Instagram, LinkedIn etc.) (“Social Management”);
• to sell you our products and to provide assistance before, during and after a purchase, in particular by: (i) providing general pre- and after- sale assistance through Ferragamo’s customer care (“Customer Care”); (ii) upon your request, exploring Ferragamo brick-and-mortar stores via videocall (“Remote Selling”); (iii) upon your request, to finalise purchase orders and make them available for pick-up from the Ferragamo boutique chosen by you from those available at the time of order placement (“Reserve, Pick-up and Ship to Store”); (iv) addressing and managing requests for personalization, return and/or repair of products (“Personalization, Return and/or Repair”); (v) assuring compliance with Ferragamo’s obligations on producer’s liability for damages arising from defective products, where applicable (“Producer’s Liability”, jointly with the purposes mentioned in this paragraph referred as "Sale");
• to examine applicants’ resumes / CVs and motivational letters and to get in contact with applicants, for open job positions or internships, who have submitted their application via the Website (“Recruitment”);
• to allow Ferragamo to provide personalised sales services to you at stores worldwide, to send you commercial communications by using the automated (e-mail, texts, chat) and traditional (mail, phone) contact methods you selected and collect your opinion with regard to Salvatore Ferragamo products and initiative through the contact channel indicated by you (“Marketing”);
• to allow Ferragamo to send promotional communications by e-mail about Ferragamo products and events ("Soft Opt-In");
• to send you e-mail and mail marketing communication regarding products and services provided by Ferragamo and which are similar to those you have chosen in the context of a purchase via the Website, even when the purchase has not been finalized (“Recovery Cart”);
• to understand your purchase preferences in order to send you communications and provide services in line with your interests. Your Personal Data are processed in compliance with the guarantees and measures set forth by the Italian Data Protection Authority in the decision accepting the request for preliminary verification submitted by Salvatore Ferragamo S.p.A. of 30 May 2013. For this purpose, your consent is required (“Profiling”);
• to observe the preferences you reveal through your use of the Website, to send you advertising messages in line with those preferences, through the use of Profiling Cookies, as better detailed on Cookie Policy. These cookies, if used together with other information about you, such as for example how our products and/or services are used, allow to recognize when access is made to the reserved area, and to send personalized marketing messages in line with the visitor's preferences. Social and profiling cookies, as better detailed on Cookie Policy, which also enable users to interact with social networks (Facebook, Twitter). allow to share contents of the Website through social networks (“Retargeting”);
• to send you customer satisfaction surveys and process the answers and feedbacks voluntarily provided by you in order to assess your level of satisfaction when using Ferragamo services and/or making purchases, contact you to address any possible dissatisfaction and, more generally, also based on aggregate statistical analyses, improve Ferragamo services (“Survey”);
• to access and enjoy the contents by means of interaction with the tag placed inside Ferragamo products through your device, by using the Near Field Communication (NFC) technology; in the context of this activity, Ferragamo processes only general information related to the device you are using (device type, language, IP general localization), without processing any ID of your device (“Smart Tag”);
• to combat and prevent the counterfeiting of Ferragamo products, by analysing data relating to when and where a tag stored inside a Ferragamo product is read by a device, by using the Near Field Communication (NFC) technology, to check for irregularities and clones; your device reads the ID tag and thus interrogates Ferragamo internal database; Ferragamo then detects the device type, language, IP general localization in order to ascertain whether products have been counterfeited (e.g., where the same tag has been read by two different devices located far away from each other). This processing activity does not imply the continuous monitoring of your location, nor whether a specific product has been counterfeited, and allows Ferragamo to gather general information related to counterfeiting (“Anti-Counterfeiting”);
• to comply with laws which impose upon Ferragamo, according to the specific cases, the collection and/or further processing of certain types of Personal Data (“Compliance”);
• to prevent and detect any misuse of the Website, or any fraudulent activities carried out through the Website, especially as regards the payments made through the e-commerce platform and enable Ferragamo to defend its rights (“Misuse/Fraud”). For this purpose, Personal Data relating to your purchase are shared with Riskified and – only for the Japanese Website - Cybersource. Please find more information on paragraph 5.A of this Privacy Policy.

4.1. Ferragamo’s legal bases to process your Personal Data, according to the purposes identified in Section 3, are as follows:

• Client Management: the processing for this purpose is carried out by Salvatore Ferragamo as autonomous data controller for the Services. This processing is necessary to provide the Services to you and, therefore, is necessary for the performance of a contract with you. It is not mandatory for you to give Salvatore Ferragamo your Personal Data for these purposes; however, if you do not, Salvatore Ferragamo will not be able to provide the relevant Services to you.
• Newsletter: the processing for this purpose is carried out by Salvatore Ferragamo as autonomous data controller and is necessary to provide you the newsletter informational Services that you have requested. It is not mandatory for you to give Salvatore Ferragamo your Personal Data for this purpose. The newsletter Service is entirely optional and is provided on your specific request through the provision of your e-mail address in the relevant space; you can at any time revoke your request following the instructions in Paragraph 8 of this Privacy Policy and the sole consequence will be that you will not receive the newsletter anymore.
• Social Management: the processing for this purpose is carried out by Salvatore Ferragamo, in some instances as joint data controller with the Relevant Company and/or the social network provider for the processing carried out through cookies, as for Facebook (here you can find the joint controllership agreement entered into between Ferragamo and Facebook), and is necessary to let you use the consultation and, where applicable, interaction Services with Ferragamo’s Social Pages. It is not mandatory for you to provide Ferragamo your Personal Data for these purposes; however, if you do not, Ferragamo will not be able provide you the relevant Services.
  For the purpose of Social Management, the Relevant Company may be Ferragamo Hong Kong Ltd (for the Social Pages in Hong Kong, China, Taiwan, Macau), Ferragamo Korea Ltd. (for the Social Pages in Korea), or Ferragamo Japan K.K. (for the Social Pages in Japan).
• Sale: the processing for this purpose is carried out by Salvatore Ferragamo as autonomous data controller for the Services performed in European Union, and by Salvatore Ferragamo and the Relevant Company as joint data controllers for the Services performed outside the European Union. This processing is necessary to invoice your purchases and deliver you the products and, therefore, in order to perform the purchase agreement with you and to comply with legal obligations applicable to Ferragamo stemming from consumer law. It is not mandatory for you to provide to the joint controllers your Personal Data for these purposes; however, if you do not, the joint controllers will not be able to fulfil your request.
  For the purpose of Sale, the Relevant Company may be Ferragamo Australia Pty Ltd, Ferragamo Canada Inc., Ferragamo Korea Ltd, Ferragamo Japan K.K., Ferragamo Mexico S. de R.L. de C.V., Ferragamo USA Inc., or Ferragamo Fashion Trading (Shanghai) Co. Ltd. for the sale performed in, respectively, Australia, Canada, Korea, Japan, Mexico, United States and China.
• Recruitment: the processing for this purpose is carried out by Salvatore Ferragamo and/or the Relevant Company you have applied for (among the subsidiaries of the Ferragamo Group, listed here). This processing is needed in order for Ferragamo to be able to consider offering you a position. Therefore, the processing is necessary to take steps at your request before (potentially) entering into a contract. It is not mandatory for you to provide your Personal Data for this purpose; however, if you do not, Ferragamo will not be able to consider your applications.
• Marketing: the processing for this purpose is carried out by Salvatore Ferragamo as autonomous data controller when you provide your Personal Data in Italian stores or by using Italian Website, or by Salvatore Ferragamo and the Relevant Company as joint data controllers when you provide your Personal Data in non-Italian stores or by using a non-Italian Website. This processing is based on your consent. It is not mandatory for you to give consent to Ferragamo for use of your Personal Data for these purposes, and you will suffer no consequence if you choose not to give it (aside from not being able to receive further marketing communications from Ferragamo). Any consent given may also be withdrawn at a later stage (please see Section 8 for more information).
  For the purpose of Marketing, the Relevant Company is the company (among the subsidiaries of the Ferragamo Group, listed here) to which you have freely provided your Personal Data. Please note that your Personal Data may be also shared with other companies of the Ferragamo Group as data processor, in line with guidelines and instructions specified by Salvatore Ferragamo.
• Soft opt-in: the processing for this purpose is carried out by Salvatore Ferragamo as autonomous data controller when you provide your e-mail address by using making a Sale on the Website. This processing is based on Ferragamo’s legitimate interest to send promotional communications, and does not require your consent. You can always object (i.e., opt-out) of this processing, and you will suffer no consequence (except for the non-receipt of Soft Opt-In communications by Ferragamo). You may object by using the opt-out link at the bottom of each e-mail received.
• Recovery Cart: the processing for this purpose is carried out by Salvatore Ferragamo as autonomous data controller and is based on its legitimate interest in sending you direct e-mail marketing communication regarding products and services provided by Ferragamo and which are similar to those you have previously purchased through the Website. You can interrupt these communications, and you will suffer no consequence if you do so (aside from not being able to receive further communications from Ferragamo), by objecting through the link provided at the bottom of all such communications (please see Section 8 for more information).
• Profiling: the processing for this purpose is carried out by Salvatore Ferragamo as autonomous data controller when you provide your Personal Data in Italian stores or by using the Italian Website, or by Salvatore Ferragamo and the Relevant Company as joint data controllers when you provide your Personal Data in non-Italian stores or by using a non-Italian Website. This processing is based on your consent. It is not mandatory for you to give consent to the joint controllers to use of your Personal Data for this purpose, and you will suffer no consequence if you choose not to (aside from not being able to benefit from greater personalisation of your user experience regarding the Website). Any consent given may also be withdrawn at a later stage (please see Section 8 for more information).
  For the purpose of Profiling, the Relevant Company is the company (among the subsidiaries of the Ferragamo Group, listed here) to which you have freely given your Personal Data. Please note that your Personal Data may be also shared with other companies of the Ferragamo Group as data processor, in line with guidelines and instructions specified by Salvatore Ferragamo.
• Retargeting: the processing for this purpose is carried out by Salvatore Ferragamo as autonomous data controller. This processing is based on your consent, which is provided by you when browsing the Website, as stated in the Website cookie banner. It is not mandatory for you to give consent to Salvatore Ferragamo to use your Personal Data for this purpose, and you will suffer no consequence if you choose not to (aside from not being able to benefit from greater personalisation of your user experience regarding the Website). Any consent given may be withdrawn at a later stage by using the options provided in section 6 of the Cookie Policy.
• Survey: surveys are sent only on the basis of your explicit consent to Marketing, while the processing for statistical purposes is carried out by Salvatore Ferragamo as autonomous data controller and is based on its legitimate interest to improve Ferragamo services and/or purchase experiences based on clients’ level of satisfaction. It is not mandatory for you to provide to Salvatore Ferragamo your Personal Data for this purpose, and you will suffer no consequence if you choose not to.
• Smart Tag: the processing for this purpose is carried out by Salvatore Ferragamo as autonomous data controller and is necessary to fulfil your request to access contents stored in the Tag located inside Ferragamo products through your device. It is not mandatory for you to allow Ferragamo to use your Personal Data for this purpose, and you will suffer no consequence if you choose not to (aside from not being able to benefit from the access to further product information).
• Anti-Counterfeiting: the processing for this purpose is carried out by Salvatore Ferragamo as autonomous data controller and is based on its legitimate interest to prevent and combat counterfeiting of its products. It is not mandatory for you to allow Ferragamo to use your Personal Data for this purpose, and you will suffer no consequence if you choose not to.
• Compliance: the processing for this purpose is carried out by Salvatore Ferragamo and/or the Relevant Company (among the subsidiaries of the Ferragamo Group, listed here), as autonomous data controller(s) according to their respective area of competence and it is necessary to comply with its legal obligations. When you provide any Personal Data to Ferragamo, Personal Data must be processed in accordance with the laws applicable to it, which may include retaining and reporting your Personal Data to official authorities for compliance with tax, customs or other legal obligations.
• Misuse/Fraud: information collected for this purpose are used exclusively to prevent and detect fraudulent activities or misuse of the Website (for potentially criminal purposes) and allow Salvatore Ferragamo and/or the Relevant Company, as autonomous data controller, to defend themselves in subsequent legal proceedings that may arise. For this purpose, Purchase Data are shared by Salvatore Ferragamo with Riskified for Sales transactions taking place in the European Union, Australia and the United States; Purchase Data for Sales transactions taking place in Mexico and Japan are also shared, respectively, by Salvatore Ferragamo, as joint controller with F. Mexico S. de R.L. de C.V. and Ferragamo Japan K.K. with CyberSource Limited. Please find more information on paragraph 5.a of this Privacy Policy.

5.1. Your Personal Data may be shared, for the purposes listed in Section 3, with different persons / entities (hereinafter and collectively, “Recipients”):

1. entities acting as data processors on Ferragamo’s behalf, in particular:
   1. persons, companies or professional firms providing Ferragamo with advice and consultancy regarding accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services;
   2. entities engaged in order to provide the Services (e.g., hosting providers or e-mail platform providers); and
   3. companies and persons authorised to perform technical maintenance (including maintenance of network equipment and electronic communications networks);
2. public entities, bodies or authorities acting as autonomous data controllers to which your Personal Data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities;
3. payment service providers, acting as data processors, to which your Purchase Data may be disclosed in order to process your payment for Sale purposes; in particular, in order to offer to you Klarna Bank AB’s payment methods, during the checkout we pass your personal data in the form of contact and order details to Klarna, in order for Klarna to assess whether you qualify for their payment methods and to tailor those payment methods for you. For more details, please consult Klarna’s own privacy notice.
4. legal entities which provide Ferragamo anti Misuse/Fraud services, as better described in the following Section 5.A;
5. persons authorised by Ferragamo to process Personal Data needed to carry out activities strictly related to the provision of the Services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees of Salvatore Ferragamo and/or the Relevant Company).

Your Personal Data may be shared within the Salvatore Ferragamo Group for the purposes specified in Paragraph 3 above, in accordance with a data protection agreement concluded among all companies of the Salvatore Ferragamo Group. For further information, please contact privacy@ferragamo.com.

A. Disclosure of Purchase Data for Misuse/Fraud

5.A.1. For purposes of Misuse/Fraud, as better described above, Riskified Ltd., a company with registered offices at 30 Kalisher St., Tel Aviv 6525724 Israel (hereinafter referred to as “Riskified”), Klarna Bank AB, a company with registered office at Sveavägen 46, 111 34 Stockholm, (hereinafter referred to as “Klarna”) or – only for the Japanese Website – Cybersource Limited (hereinafter referred to as “Cybersource”) will carry out security and Misuse/Fraud checks through the Purchase Data on the transactions carried out. Riskified, Cybersource and Klarna are companies specialized in anti-fraud services, software and platforms in the field of e-commerce. Those companies will process your Purchase Data as autonomous data controllers to ascertain the security of your payments.

5.A.2. Salvatore Ferragamo and the Relevant Company, which you may find in paragraph 4 above, disclose your Purchase Data to Riskified, Cybersource and Klarna, which process such data pursuant to the legitimate interest of Ferragamo to prevent frauds, in order to guarantee the legality of payments made using the e-commerce platform of the Website. The data processing by Riskified, Cybersource and Klarna will be carried out through automated means and will consist of aggregating your Purchase Data with other data relevant to transactions concluded on e-commerce platforms, in order to assess the regularity of the payment, according to pre-determined criteria.

5.A.3. For a description of the commitments and measures provided by Riskified and Cybersource to guarantee the protection of your Personal Data, please read, respectively, Riskified (https://www.riskified.com/privacy/), Cybersource (https://www.cybersource.com/privacy/) and Klarna (https://www.klarna.com/international/privacy-policy/) privacy policies. You may also contact the Ferragamo DPO on privacy@ferragamo.com for further information.

5.A.4. Please be aware that the disclosure of your Purchase Data to Riskified entails the transfer of your Purchase Data outside the European Economic Area. Your Purchase Data will be transferred to the USA, where they will be retained in the Riskified servers in that country. This transfer is subject to Riskified’s undertaking to provide adequate guarantees relevant to your Purchase Data, by accepting the standard “Controller to Controller” contract clauses adopted by the European Commission. To obtain a copy of the standard contractual clauses please write to privacy@ferragamo.com. A backup copy of your Purchase Data will also be retained by Riskified on servers in the State of Israel. Your Personal Data are transferred according to the adequacy decision of the European Commission adopted on 31 January 2011, which recognised that the legal system of the State of Israel ensures that your right to the protection of your personal data, is substantially guaranteed, and equivalent to that in force in the European Union.

5.A.5. Please note that you may always object to the communication of your Purchase Data for Abuse/Fraud, as better described in Paragraph 8.6 of this Privacy Policy.

6.1. Given the international presence of the Ferragamo Group, apart from the transfer referred to in the previous paragraphs, some of your Personal Data are shared with Recipients who may be located outside the European Economic Area. Ferragamo ensures that your Personal Data are processed by these Recipients in accordance with applicable data protection legislation. These transfers can be based on an adequacy decision or on the Standard Contractual Clauses approved by the European Commission. Further information is available at the following address: privacy@ferragamo.com.

7.1. Personal Data processed for Client Management will be kept for the period in which you have an account on the Website and are part of the Ferragamo’s fidelity program, or until the period provided by the Italian Supervisory Authority with regard to fidelity cards data. As Personal Data for this purpose are processed in order to provide the Services, Ferragamo may retain the data for a longer period as may be necessary to protect Ferragamo’s interests to defend against potential liability related to the provision of the Services.

7.2. Personal Data processed for Newsletter will be kept until you unsubscribe from the newsletter through the link at the bottom of every e-mail sent to you. As Personal Data for this purpose are processed in order to provide the Services, data may be retained for a longer period as may be necessary to protect Ferragamo’s interests to defend against potential liability related to the provision of the Services.

7.3. Personal Data processed for Social Management will be kept for the period necessary to interact with you. When the platform is jointly managed with the platform provider, please refer to Personal Data retention policy available in the relevant social network privacy notice.

7.4. Personal Data processed for Sale will be kept for the period deemed strictly necessary to fulfil such purposes (e.g. for the delivery of the product purchased). In any case, as these Personal Data are processed for the provision of the Services, Ferragamo may retain the data for a longer period as may be necessary to protect Ferragamo’s interests to defend against potential liability related to the provision of the Services, in accordance with the statutes of limitation.

7.5. Personal Data processed for Recruitment will be retained as follows. If a working relationship with Salvatore Ferragamo or the Relevant Company is not established, your Personal data will be stored for a maximum of thirty-six (36) months from receipt of your CV or the end of the selection process. Before the expiration of the thirty-six (36) months period, the Data Controller may contact you to update your Personal Data and receive communications about open positions. If your answer is negative or not received within fifteen (15) days, Ferragamo will delete your personal data within the deadline; if your answer is positive, the data will be kept for a further period of thirty-six (36) months.

7.6. Purchase Data collected by Salvatore Ferragamo and/or the Relevant Company for Marketing and Profiling purposes will be retained for seven (7) years, in compliance with the decision accepting the request for preliminary verification filed by Salvatore Ferragamo, adopted by the Italian Supervisory Authority on 30 May 2013.

7.7. Personal Data processed for Soft Opt-In will be kept until you object to such purpose.

7.8. Personal Data processed for Retargeting will be retained until you withdraw your consent.

7.9. Personal Data processed for Recovery Cart will be kept until you object to this processing through the link you may find at the bottom of every Recovery Cart e-mail.

7.10. Personal Data processed for Compliance will be kept for the period required by the specific legal obligation set forth by the applicable law.

7.11. Personal Data processed for Anti-Counterfeiting and Smart Tag will be kept for two years from the collection. Personal Data processed for preventing Misuse/Fraud will be kept for as long as deemed strictly necessary to fulfil this purpose for which it was collected and until Ferragamo has to keep the data in order to defend themselves in subsequent legal proceedings that may arise, or communicate this data to Public Authorities, as may be requested.

7.12. Personal Data processed for Survey will be kept, in the form of statistical analysis, for seven (7) years, in compliance with the decision accepting the request for preliminary verification filed by Salvatore Ferragamo, adopted by the Italian Supervisory Authority on 30 May 2013.

7.13. More information on the data retention periods are available by writing to Ferragamo at: privacy@ferragamo.com. You may always object to the further retention of your Personal Data by writing to the same e-mail address.

8.1. As a data subject, are entitled to request from Ferragamo at any time, access to your Personal Data, the correction and erasure of your Personal Data, as well as to object to its processing, based on grounds relating to your particular situation. You are also entitled to request the restriction of the processing of your Personal Data, as well as to obtain the Personal Data you have provided to Ferragamo in a structured, commonly used and machine-readable format.

8.2. Please note that most of the Personal Data you provide Ferragamo can be changed at any time, including your e-mail preferences, by accessing, where applicable, your user profile created on the Website.

8.3. For Marketing and Profiling, you may always withdraw your consent at a later stage, without prejudice for the processing lawfully carried out before such withdrawal.

8.4. For the purpose of Soft opt-in and Recovery Cart, you have the right to object at any time by clicking at the opt-out link at the bottom of each e-mail received.

8.5. For Retargeting, you may always withdraw your consent at a later stage by using the options provided in section 6 of the Cookie Policy, without prejudice for the processing lawfully carried out before such withdrawal.

8.6. Requests should be made in writing to Ferragamo at: privacy@ferragamo.com. At the same address, you may contact the Salvatore Ferragamo Group DPO.

8.7. Please note that you may always object to the communication of your Purchase Data for Survey, Anti-Counterfeiting and Abuse/Fraud, for reasons related to your particular situation. Ferragamo may continue to process your Personal Data for this purpose for compelling legitimate grounds which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

8.8. In any case, please note that, as a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of Personal Data, if you believe that the processing of your Personal Data carried out through this Website violates applicable law.

9.1. Ferragamo reserves the right to partly or fully amend this Privacy Policy, or simply to update its content, e.g., as a result of changes in applicable law. Where they are of a substantive nature, Ferragamo will inform you of such changes as soon as they are introduced, and they will be binding as soon as they are published on the Website. In any case, Ferragamo invites you to regularly visit this Privacy Policy in order to acquaint yourself with the latest, updated version of the Privacy Policy, so that you may remain constantly informed on how Ferragamo processes and protects your Personal Data.

10.1. This privacy policy has been prepared in light of European Union and Italian data protection legislation, as the Ferragamo Group has its headquarter in Italy. Should you need further information with specific regard to Ferragamo processing of Personal Data according to the privacy laws of your Country, please contact privacy@ferragamo.com.