Data Protection Policy

This information, and the data protection policy described herein, is aimed at all subjects visiting and interacting with this website of Trussardi S.p.A. (the “Website”), and describes the ways in which the personal data provided on this Website by registered and non-registered users are processed.

This information is provided for this Website only, and not for other websites that may be consulted by the users via links contained herein, except as further specified with reference to the E-shop from which it is possible to purchase Trussardi brand products.

Therefore, Trussardi S.p.A. may not be held liable in any way for any processing of your data carried out by third parties not contemplated in this information.

Trussardi therefore accepts no responsibility for the ways in which other subjects collect, use, transmit or protect the data you provide them with by accessing third-party websites. We invite you to carefully read the information on data protection and on specific cookies of any third-party websites, because this information may be different from ours, and to contact the manager of the website concerned if you have any doubts on the use of your personal data on other websites

The Website offers access to the e-commerce section of Trussardi S.p.A. (“E-shop”), where you can purchase Trussardi products online. This section of the Website is managed by TRS Evolution S.p.A., a Trussardi Group company that sells Trussardi brand products of various kinds through the E-shop.

This information is also inspired by Recommendation no. 2/2001 adopted on 17 May 2001 by the European personal data protection authorities that form part of the Group set up by art. 29 of Directive no. 95/46/CE in order to identify a number of minimum requisites for the collection of personal data online, and specifically, for the kind of information data controllers should provide users with when they access web pages, regardless of the reasons.

Trussardi S.p.A. will process your personal data in observance of the measures set out in Legislative Decree no. 196/2003 as amended (hereinafter the “Italian Data Protection Act”).

Update: July 2017

index

 

GENERAL INFORMATION REGARDING DATA PROTECTION

a) Definitions
The expression “personal data” has the meaning reported in Directive 95/46/CE regarding the protection of personal data, and refers to any information relating to the user that may be directly or indirectly used to identify him/her.
In this policy, the following terms: "we" and "our" refer to Trussardi S.p.A., a Trussardi Group company incorporated in Italy, with registered office in Piazza della Scala no. 5, 20121 Milan, Italy, Business Register enrolment no. 1239427 and Tax ID no. 01709450165, VAT no. 08766830155 (“Trussardi”), subject to the management and coordination of Finanziaria Operazioni Societarie S.p.A., an Italian company with registered office in Milan, in Piazza della Scala no. 5, and, if pertinent, of its affiliates and subsidiaries in Italy and abroad, including in countries outside of the European Union. A list of the affiliates may be requested by contacting Trussardi S.p.A.
The terms "you" and "your" refer to (registered and/or non-registered) users of the Website.

b) Data Controller
Unless otherwise specified in this Policy, the subject who controls the processing of the personal data described herein and is described as the data controller for the purposes established by European regulations governing data protection, is Trussardi.

c) Consent
With the exception of those processing purposes for which Trussardi must request your explicit consent pursuant to the regulations currently in force, by using the Website, uploading or providing personal data on it or notifying said data to Trussardi, for purposes other than professional purposes, you agree to and give your consent to be bound by the terms and conditions of this policy and the cookie policy (to which specific reference is made for further information on cookies), and therefore give your consent for Trussardi to disclose your personal details, with no exceptions, in compliance with the terms and conditions set forth in this information and in the cookie policy.
Pursuant to the regulations in force, you will be asked to give your consent for a number of specific types of data processing (for example, the possibility to analyse your habits regarding the purchase of Trussardi products, both online and in the brick-and-mortar stores), so we can offer you personalised services, and for marketing purposes. Please remember that your consent is, in any case, freely given and unconditional and that by selecting the dedicated box, you may agree to or refuse the specific types of data processing, which will in all cases be carried out as expressly contemplated in this information, in the Policy and in the cookie policy.

d) Sharing of personal data
Trussardi S.p.A. would like to inform you that the company may:

  1. use the services of affiliates or subsidiaries of Trussardi Group, as well as third parties, to provide the services available on the Website/s, depending on the services you use. These subjects will process your personal data in their capacity as joint data controllers, i.e. subjects entrusted by us with data processing, based on specific contractual guarantees with which our institutions undertake to conform with regard to data protection;
  2. share your personal data with other Trussardi Group companies, so that they may store and retain said personal data centrally in their capacity as data controllers;
  3. share your data within the framework of extraordinary corporate operations, such as mergers, business combination transactions, sale of assets or in the unlikely event of bankruptcy. Where necessary for compliance with the law in force, and provided you have previously provided your contact details, you will be sent notification when such processing takes place;
  4. disclose data regarding users, including contact information, in the event that Trussardi is obliged to do so based on the regulations in force, including cases in which Trussardi must comply with court orders or in other circumstances contemplated by the law that require compliance on the part of Trussardi;
  5. disclose your data for the purpose of enforcing its own legal rights or interests, and/or the rights of companies in which it holds a stake, and/or belonging to Trussardi Group protected by the law, in order to safeguard the security of the Website and its users.

  6. Minimum age
    Trussardi does not accept registration or orders placed by subjects under the age of 18, or subjects who are not legally adults according to the regulations in force in their country, and it will not knowingly collect or use their personal data. Minors are invited not to register on the website or make online purchases, and to ask an adult to carry out the necessary procedures.

  7. Applicability of other information on data protection
    If you are registered with other Trussardi services that do not expressly refer to this information and the pertinent Policy, other information and statements may be applicable to the protection of personal data; this information does not replace or modify other information or statements regarding the protection of personal data that may apply to personal data collected or used by Trussardi within the framework of said specific relationship.

  8. Security Measures
    Trussardi is constantly committed to applying the most advanced security procedures and standards to protect your personal data from improper use, loss and/or unauthorised alterations. However, despite our efforts to guarantee our users the maximum protection of their personal data, we believe you should be aware there is no absolute guarantee against unauthorised access to your personal data on the part of third parties. Therefore, we would like you to be aware that when you send us your data, you accept the above, and will not hold us responsible for any breaches of security, except for cases in which this is due to negligence on our part.

  9. International transfer of personal data
    If you have chosen to register on the Trussardi customer database for marketing and profiling activities, we may collect your personal data in your country, for example data regarding your visits to our stores, and subsequently transfer and file them, in compliance with the regulations in force, in another country in which the servers of our Group companies or our suppliers are located, and which offer hosting services. The data will be transferred for the purposes described in this Policy (for example to provide the services you have requested, or to offer personalised services in all our stores worldwide, to share your data with other Trussardi Group companies, or simply because the servers your data are stored on are located in other countries). The privacy and data protection regulations in force in said countries may not be the same as those in force in your country of residence. Trussardi will adopt measures to ensure your data are processed in a secure manner and in compliance with this Policy, regardless of the country they may be transferred to. These measures include the use of standard contract clauses for the transfer of data approved by the European Commission (i.e. specific, mandatory contractual obligations that must be undersigned by the supplier) and/or, if applicable, certification that the subject receiving the data has joined the US Safe Harbor programme, or complies with other legitimation criteria contemplated by the law, such as, for example the Binding Corporate Rules, if deemed appropriate in future.

    Where permitted in your country, by using the Website/s or providing us with your data for the purposes set forth in this Policy, you declare that you fully understand and clearly agree to the processing of your personal data abroad in the context of the normal commercial operations of Trussardi, including the collection, storing and processing of said data in the USA.

  10. Duration of storage and processing of personal data
    Your data will be stored by Trussardi for the period of time strictly necessary to guarantee the proper provision of the services requested from us - without prejudice to the need to store said data for a longer period of time in observance of the applicable regulations.
    The data processed by Trussardi for profiling and/or marketing purposes (always, of course, provided you have specifically given the pertinent consent), will be held for a maximum of seven years. At the end of this period, Trussardi may delete the data, or anonymise them and retain them for statistical purposes or for our records only.
    In any case, you may withdraw your consent for the processing of your data at any time. Data transmitted to any third parties who provide the services requested by you will be processed by said providers for the amount of time strictly necessary for them to carry out the tasks entrusted to them

  11. Changes to this Policy
    In time, Trussardi may make changes to this Policy, also in order to comply with new obligations imposed by the laws in force, or for technical reasons.
    The updated information will be published on the Website, and if there are any changes for which the applicable regulations require your express consent, we will ask you for said consent
    We therefore invite you to consult this page regularly.
 

Further information

 

BROWSING ON THE WEBSITE

Personal data acquired automatically.
Please note that while you are browsing the Website, there may be some personal data that Trussardi acquires automatically, the transmission of which is implicit in the use of internet communication protocols.

This information is not specifically collected by Trussardi in order to be associated with a specific identified subject, but given the nature of such data, they could be used to identify you if processed and combined with data held by third parties.

This data category includes the IP addresses or domain names of computers of users who visit the website, the URI (“Uniform Resource Identifier”) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file received in reply, the numerical code indicating the status of the response from the server (successful, error, etc.) and other parameters relating to the operating system and the computer environment of the user.

These data are used only to obtain anonymous statistical information on the usage of the Website and to check its correct functioning, and are immediately deleted after processing. The data could be used to determine responsibility in the case of hypothetical computer crimes against the Website. Except for this eventuality, data on web contacts are not currently held for any longer than 15 days.

If you have given your specific consent, these data may also be cross-referenced with your personal data (for example, in the case of authentication on the E-shop) and processed in order to improve the services we provide you with.

Group employees entrusted with carrying out specific operations on the Website (including statistical analysis and Website development) may process the data collected while you are browsing the Website and/or data you have provided us with while using the Website.

Cookies
To guarantee the functioning of the Website and improve the service offered, the Website uses cookies.
Cookies are small text files positioned by the Website on your computer or mobile device, where they are memorised so they can be retransmitted to the Website upon your subsequent visit.
They are files that automatically collect some information you do not provide directly.

Trussardi uses cookies to (i) make the Website function, or to make it function more efficiently and make it simpler to use,and (ii) obtain data on the use of the Website for statistical purposes (for example to find out which pages are visited and how frequently).

When you use our Website, as a registered or non-registered user, Trussardi may also use Cookies to tailor the Website more closely to your requests and to simplify your browsing experience. For example, Cookies allow us to ensure that the information present on the Website is in line with your preferences during your subsequent visits.

For further information on the use of Cookies, pixel tags, flash cookies and similar technologies, please read our Information on Cookies.

 

PURPOSES OF PROCESSING

i) Signing up for our newsletter and consent for marketing and/or profiling where pertinent; filling out, where pertinent, of forms for marketing and/or profiling purposes at Trussardi Group stores

If you like, you may sign up for our newsletter.

Likewise, when you make a purchase at one of the Trussardi Group stores, our sales staff may offer you the possibility, which you are free to accept or decline, to sign up for our newsletter services by filling out an appropriate form on paper or providing your data on a computer form.

As well as by filling out the form you will find on the registration page, and the paper form present in our stores, you may also choose the option - for registering on our Website - of using your Facebook or Google+ account.

This option allows you to register with the Website in just a few clicks, without having to indicate a new username and password.

This makes access to the Website quicker, without having to create a new account to remember.

Access via Facebook or Google+ will allow us to gain access to the personal data you have authorised via the privacy settings of your profile.

Any data you provide using the mean specified above will be processed - only if you have freely given you express, advance consent - by Trussardi for the following purposes:

  1. to respond effectively to any requests sent to us, also regarding any problems with the functioning of the Website;
  2. for promotional offers, discounts, special conditions and other services;
  3. for sending commercial or promotional information and invitations to take part in events;
  4. to carry out market research and notify users of special activities and events dedicated to Trussardi Group customers;
  5. to analyse your consumer choices (known as “profiling”), in compliance with the necessary guarantees and measures established by the Italian Data Protection Authority, by recording the type and frequency of the purchases you make online and/or at Group stores, so we can provide you with a better service when you make any future purchases in one of the Group stores and pursue the purposes listed at the point above.

Your data may also be processed for statistical purposes and for our records.

Your personal data will be filed and used, mainly through automated processing systems, to keep you informed - via e-mail, SMS or any other means you indicate - on Trussardi and on our products, services and promotions and on the activities and events organised or sponsored by Trussardi.

Your personal data will be processed by our staff specifically authorised for the purpose, employed directly by Trussardi and/or its subsidiaries and/or affiliates, mainly operating in the Marketing, Advertising and IT Systems departments.

Trussardi will not disclose your personal data to third parties for direct marketing purposes, and will not sell your data to third parties. However, we may need to transmit your contact data and identification data within the Group, and to our service providers (for example providers of technical services) to whom we have entrusted data processing, or to other third-party subjects (for example, external suppliers we use for sending advertising material), where this is necessary to allow you to receive communications from us, as indicated in this section.

You may, at any time, notify us that you no longer wish your personal data to be used for marketing purposes.

All you have to do is write to:  customerservice@trussardi.com.

You may also express your opposition to the sending of further promotional material from Trussardi, by using the link entitled “unsubscribe” or similar that you will find at the bottom of all our e-mail communications.

In any case, if you unsubscribe from our newsletter and commercial information service, your Website account will not automatically be deleted.

ii) Browsing and registering with the “E-shop”; possible consent, for marketing and/or profiling.

As explained above, from the Website it is possible to directly access the e-commerce website of Trussardi S.p.A., where you can purchase any Trussardi products you like online.

The E-shop is managed by TRS Evolution S.p.A., a subsidiary of Trussardi Group.

The data you provide for registering with the E-shop, and for any online purchases of Trussardi products, will be processed by Trussardi in its capacity as joint data controller together with TRS Evolution S.p.A., a single-shareholder subsidiary of Trussardi Group, headquartered in Milan, in Piazza Della Scala no. 5, for the purpose of managing access to the services offered by the E-shop and to simplify the purchase of products online.

Please note that some of the information you will be asked for is essential to complete the registration procedure, and that without this information, or if you refuse to provide it, we will be unable to respond to your request.

On the Website, you will find clear indications of the essential data you are asked for and without which we will not be able to provide you with the services requested. If you intend to purchase Trussardi products online, essential information includes all the information that regards you and is necessary to respond to your order, i.e. to carry out all the activities necessary to manage your order (including the administrative management of the contract, the shipping of the products, handling of payments, credit and any controversies and the prevention of fraud) and to comply with all the obligations established by the law and the regulations in force regarding the retail sale of products.

At the E-shop, you may freely provide your express consent for your data to be processed by Trussardi for the following purposes:

  1. to provide and manage the online operations necessary for sending the order;
  2. to check that the information you provide for the transactions is complete, valid, correct and is not fraudulent;
  3. to process the order and deliver the products to you;
  4. provide you with customer care, including returns or repairs;
  5. contact you, by the means you select, for any problems regarding the management of the order;
  6. comply with the legal obligations deriving from the fiscal and accounting regulations and any other regulation in force binding upon our company, or to comply with provisions legitimately issued by the competent authorities;
  7. to respond effectively to any requests sent to us, also regarding any problems with the functioning of the Website;
  8. for promotional offers, discounts, special conditions and other services;
  9. for sending commercial or promotional information and invitations to take part in events;
  10. to carry out market research and notify users of special activities and events dedicated to Trussardi Group customers;
  11. to analyse your consumer choices (known as “profiling”), in compliance with the necessary guarantees and measures established by the Italian Data Protection Authority, by recording the type and frequency of the purchases you make online and/or at Group stores, so we can provide you with a better service when you make any future purchases in one of the Group stores and pursue the purposes listed at the point above.

Your data may also be processed for statistical purposes and for our records.

Please also note that by using some of the services provided on the Website, Trussardi may collect further information linked to the activities you carry out online on the Website (for example, the products entered on your wish list, the products on your shopping bag that you have not removed before leaving the Website), or your preferences regarding the use of the Website selected through the functions available on the Website.

When providing your data, please make sure they are correct, and if there are any changes to the personal data you have provided us with, please let us know as soon as possible by writing to: customercare@trussardi.com, or directly edit your data online in the “Profile”, area, if you have registered.
This will allow us to keep your personal data up to date.

 

MEANS OF DATA PROCESSING

Your personal data will be processed using the appropriate electronic or automated instruments, IT or telematic systems, or by hardcopy means, in full observance of the principles of correctness, lawfulness and transparency, and in such a way as to protect your rights and your confidentiality, and will be processed only for the purposes for which your data were collected.

Your personal data will be processed by staff of Trussardi Group (employees and persons working with the Group), authorised for the purposes in their role as persons entrusted with data processing as part of the working duties assigned to them, and where necessary by external subjects if this is necessary for and/or instrumental to the carrying out of the purposes indicated above (merely by way of example: shipping companies, IT technicians entrusted with carrying out maintenance on the Website and IT systems of the Group, companies entrusted by Trussardi with activities relating to the management of promotional campaigns, events, marketing activities, etc.).

Expressly excluded from this is any use of data regarding your credit card for purposes other than verifying the existence of means of payment, charging for orders or managing payments relating to orders you have made, as well as for dealing with any complaints and controversies. Therefore, please note that your data will also be processed by the credit institute that provides the services connected with the management of online payments, as well as the institute that issued the credit card you indicate as the means of payment for your order.

Please note that if you agree to the processing of your personal data for the purposes set forth at letters (viii) to (xi) of the preceding paragraph, your data will be visible to and/or shared with all the retail outlets of Trussardi Group located within and outside of the European Union. In this regard, please note that we have taken all the appropriate safety and confidentiality measures required by the applicable regulations.

 

EXERCISING YOUR RIGHTS

For any questions, comments, complaints or requests regarding this Policy, you can send an e-mail to privacy@trussardi.com, or write to

Trussardi S.p.A., Ufficio Privacy, Piazza Della Scala no. 5, 20121 Milan, Italy

Trussardi will process your data in compliance with Legislative Decree no. 196/2003 as amended. Therefore, your data will be processed in full observance of the principles of correctness, lawfulness and transparency, in order to protect the security and confidentiality of your data.

Please remember that you are entitled at any time to ask Trussardi if, and if so, which of your data are held by our Group, where they were collected, how and for what reason they are held or processed, which subjects they have been disclosed to or may be disclosed to, as well as information regarding the data controller and/or data supervisors. You also have the right to ask Trussardi to rectify your data, if you believe they are not correct, complete and up to date.

You also have the right to ask Trussardi to delete or anonymise your data, or to suspend the processing of your data if they are being processed unlawfully. In addition, please remember that you may, at any time, withdraw your consent for the processing of your data for marketing and profiling purposes; this will not prevent you from accessing the Website and making any purchases from the E-shop.

Furthermore, if you have requested that Trussardi send you commercial information, you may, at any time, oppose this by requesting the deletion of your data from the mailing list, by following the “unsubscribe” link you will find in all the commercial communications sent to you by Trussardi; alternatively, you may write to the Dipartimento Marketing - Trussardi S.p.A., Piazza della Scala no. 5, 20121 Milan, Italy.

Should you wish to exercise one of these rights, or to receive the list of the companies belonging to Trussardi Group, you may contact:

  • the Ufficio Legale - Trussardi S.p.A., Piazza Della Scala no. 5, 20121 Milan, Italy, or send an e-mail to: privacy@trussardi.com.
 

Information in accordance with Legislative Decree no. 196/03

We would like to inform you that Trussardi S.p.A. will process your data in accordance with Legislative Decree no. 196/2003 as amended; your data will therefore be processed in full observance of the principles of correctness, lawfulness and transparency, in order to protect your confidentiality and your rights. Therefore, pursuant to article 13 of the aforementioned Legislative Decree we are pleased to provide you with the following information:

1. The data you provide will be processed for the following purposes:
(a) to carry out the obligations deriving from the contractual relationship between you and the Company;
(b) to carry out administrative and accounting procedures (management/dispatch of orders, correspondence, invoicing etc.) connected with the aforementioned contractual relationship;
(c) to carry out the obligations deriving from the law, regulations and in general any rules and regulations applicable at any given time, including EU regulations.

2. Your data will be processed with the assistance of telematic, hardcopy and IT instruments.

3. The provision of data is mandatory for the above purposes.
Refusal to provide the data requested, or the provision of inaccurate data may make it fully or partially impossible to carry out the tasks entrusted to the Company and/or to continue the relationship with the Company.

4. Your data will not be made public. They will be accessible to employees of the Company entrusted with processing data for the purposes indicated at points (a), (b) and (c) above; they may be disclosed to third parties, including our commercial partners and authorised suppliers of services, exclusively for administrative and accounting purposes connected with the aforementioned commercial relationship with the Company and for more effective compliance with the obligations deriving from said relationship; specifically, your data may be disclosed, in Italy and abroad, to the other Trussardi Group S.p.A companies.
They may also be disclosed/made accessible to subjects entrusted with the maintenance/development of out IT system, for the time required for carrying out said service.

5. Your data will be stored by our Company for the period of time necessary to guarantee proper compliance with the aforementioned contractual obligations, and may be stored for a longer period in observance of the regulations applicable, including accounting regulations.

6. The Data Controller is Trussardi S.p.A., with registered office in Piazza della Scala no. 5, Milan, Italy.

7. The Data Supervisor, vis-à-vis whom you may exercise your rights as set forth below, is the Manager pro tempore of the Administration and Finance Office of the Company, whom you may write to at privacy@trussardi.com.

8. You have the right, at any time, to be informed of which data are held by the Company and how they are used, in compliance with art. 7 of Legislative Decree no. 196/03, the full text of which is reported in the paragraph below, entitled “Rights of the Interested Party”.

You have the right, at any time, to be informed of which data are held by the Company and how they are used. You may, at any time, exercise your rights vis-à-vis the Data Controller pursuant to art. 7 of Legislative Decree no. 196/2003.
Please find below, for your convenience, the full text of art. 7:

“Art. 7. Right to access personal data and other rights

1. The interested party has the right to obtain confirmation of the existence of his or her personal data, even if they have not yet been recorded, and the communication thereof in an intelligible form.

2. The interested party has the right to obtain indications regarding:
a) the origin of his/her personal data;
b) the purposes of processing and the methods used;
c) the logic applied to the processing of his/her personal data using electronic equipment;
d) the details of the data controller, the data supervisors and the representative designated pursuant to article 5, paragraph 2;
e) the subjects or categories of subjects to which the personal data may be disclosed, or that may have access to the data in their capacity as designated representative in Italy, data supervisors or persons responsible for data processing.

3. The interested party has the right to obtain:
a) the updating, correction and/or integration of his or her personal data, if the latter is in his/her interest;
b) the deletion, transformation into an anonymous form or blocking of any data processed in breach of the law, including those for which storage is not required in relation to the purposes for which the data was collected or subsequently processed;
c) the confirmation that the operations referred to at points a) and b) have been notified, also as far as the content is concerned, to those to whom the data was disclosed or transmitted, except in those cases in which such notification is impossible or requires the use of means manifestly disproportionate to the right protected.

4. The interested party has the right to oppose, in full or in part:
a) the processing of his/her personal data, for legitimate reasons, even where this is pertinent to the purposes for which the data was collected;
b) the processing of his/her personal data for the purposes of sending advertising or direct sales material or for the carrying out of market research or commercial communications.”