Privacy Policy
LAST UPDATE: November 7, 2025
Your privacy and the security of your personal information is very important to the Tod's Group. For this reason, we take the utmost care in collecting and managing the personal information that you provide us with or that we automatically acquire, adopting specific measures to guarantee their security, confidentiality and integrity, in compliance with the provisions of Regulation (EU) 2016/679 (hereinafter the "Regulation"), with the Provisions of the Personal Information Protection Law of the People's Republic of China (hereinafter the “PIPL”), in accordance with their respective territorial scope of application.
This privacy policy applies to the products/services we offer in mainland China through our website and the Wechat client mini-program "Hogan boutiques".
This privacy policy does not apply to any other third-party products/services that you access or are redirected through our website.
The privacy policy will not be extended to other companies that provide services in their own names, such as franchisees or licensees, or you share your personal information on social media (such as WeChat, WhatsApp, Baidu, Kakao Talk , Facebook , Twitter, Instagram, etc.), or online platforms owned and operated by other companies. Because other companies have their own privacy policies, please remember that their rules, not ours, will apply to how they use any personal information you provide them.
To make our privacy policy easier to understand, we use bold font for important contents.
Prior to disclosing any sensitive personal information to us, you acknowledge that you have carefully considered the appropriateness of such disclosure and hereby affirm that it is suitable under the circumstances. You agree that such sensitive personal information will be processed by us, in accordance with the purposes and in accordance with the methods set out in the privacy policy.
DEFINITIONS
• Personal Information Handler - refers to Individual or Organization that autonomously determines the purposes and methods of the processing of personal information, pursuant to art. 73 (1) of the PIPL and art. 4 (7) of the Regulation.
• Personal information - refers to any kind of information related to an identified or identifiable natural person as electronically or otherwise recorded, excluding information that has been anonymized.
• Sensitive information - refers to personal information that, when leaked or used unlawfully, may result in a violation of individuals' personal dignity or harm to personal safety and property, including biometric data, religious beliefs, specific identities, medical health, financial account, location, etc. information and personal information of minors under the age of fourteen.
• Entrusted party or entrusted partner - refers to companies, associations or individuals who process personal information in the name and on behalf of the Personal Information Processor, under its instructional and supervisory.
• Anonymization - refers to process of removing personal identifiers, both direct and indirect, that may lead to an individual being identified.
• Cross-border transfers - refers to the transfer of your personal information outside of mainland China
• Mainland China – refers to geopolitical area under the jurisdiction of the People's Republic of China, excluding Special Administrative Regions (Hong Kong, Macao and Taiwan).
• Product and/or services – refers to products and/or services provided with our official website and WeChat application.
Your privacy and the security of your personal information is very important to the Tod's Group. For this reason, we take the utmost care in collecting and managing the personal information that you provide us with or that we automatically acquire, adopting specific measures to guarantee their security, confidentiality and integrity, in compliance with the provisions of Regulation (EU) 2016/679 (hereinafter the "Regulation"), with the Provisions of the Personal Information Protection Law of the People's Republic of China (hereinafter the “PIPL”), in accordance with their respective territorial scope of application.
This privacy policy applies to the products/services we offer in mainland China through our website and the Wechat client mini-program "Hogan boutiques".
This privacy policy does not apply to any other third-party products/services that you access or are redirected through our website.
The privacy policy will not be extended to other companies that provide services in their own names, such as franchisees or licensees, or you share your personal information on social media (such as WeChat, WhatsApp, Baidu, Kakao Talk , Facebook , Twitter, Instagram, etc.), or online platforms owned and operated by other companies. Because other companies have their own privacy policies, please remember that their rules, not ours, will apply to how they use any personal information you provide them.
To make our privacy policy easier to understand, we use bold font for important contents.
Prior to disclosing any sensitive personal information to us, you acknowledge that you have carefully considered the appropriateness of such disclosure and hereby affirm that it is suitable under the circumstances. You agree that such sensitive personal information will be processed by us, in accordance with the purposes and in accordance with the methods set out in the privacy policy.
DEFINITIONS
• Personal Information Handler - refers to Individual or Organization that autonomously determines the purposes and methods of the processing of personal information, pursuant to art. 73 (1) of the PIPL and art. 4 (7) of the Regulation.
• Personal information - refers to any kind of information related to an identified or identifiable natural person as electronically or otherwise recorded, excluding information that has been anonymized.
• Sensitive information - refers to personal information that, when leaked or used unlawfully, may result in a violation of individuals' personal dignity or harm to personal safety and property, including biometric data, religious beliefs, specific identities, medical health, financial account, location, etc. information and personal information of minors under the age of fourteen.
• Entrusted party or entrusted partner - refers to companies, associations or individuals who process personal information in the name and on behalf of the Personal Information Processor, under its instructional and supervisory.
• Anonymization - refers to process of removing personal identifiers, both direct and indirect, that may lead to an individual being identified.
• Cross-border transfers - refers to the transfer of your personal information outside of mainland China
• Mainland China – refers to geopolitical area under the jurisdiction of the People's Republic of China, excluding Special Administrative Regions (Hong Kong, Macao and Taiwan).
• Product and/or services – refers to products and/or services provided with our official website and WeChat application.
- 1. WHO WE AREThe Personal Information Handler is Tod's S.p.A., with registered office in Via Filippo Della Valle n.1, Sant'Elpidio a Mare (FM) - Italy (EU), contactable at the following e-mail address dataprivacyofficer@todsgroup.com.
With reference to the purpose of the processing referred to art. 3.2 (i) of the privacy policy, including the related legal obligations referred to art. 3.3 of the privacy policy, the Personal Information Handler is Tod's (Shanghai) Trading Co. Ltd, with registered office at Unit 1,2,3 & 6, Floor 45, Wheelock Square, No. 1717 West Nanjing Road, Jing'an District, Shanghai, which can be contacted at the following email address TodsChina.privacy@todsgroup.com.
- 2. WHAT PERSONAL INFORMATION WE PROCESSWhen consulting the pages of our website, some of your personal information will be collected or, in connection with some services, you will be requested to provide additional personal information.
We will follow the principles of lawfulness, legality and necessity to collect and use your personal information for the following purposes described in this privacy policy. We will not collect personal information unrelated to the services provided, nor will we refuse you to use the basic functions of the products and/or services because you do not agree to the collection of unnecessary personal information. If we use your personal information for other purposes not specified in this privacy policy or collect and use your personal information for other specific purposes, we will reasonably notify you and obtain your consent again before collection and use.
2.1. WHAT PERSONAL INFORMATION WE COLLECT AND PROCESS
(i) Browsing Data - The computer systems and software procedures used to operate the Website acquire, in the course of their normal operation, some data whose transmission is implicit in the use of Internet communication protocols.
(ii) Cookies - to find out more, we invite you to read the section "Cookie Policy - Cookie Setting" available at the bottom of every page on our website. This is information that is not collected in order to be associated with you, but which by its very nature could, through processing and association with data in possession of third parties, allow you to be identified. This category of data includes the IP addresses or domain names of the computers used for navigation and which connect to the Sites, the URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the IT environment. These data are not circulated, but are used only to obtain anonymous statistical information on the use of the Site and to check its correct operation, and are kept for the time periods defined by the relevant legal regulations. The data could, however, be used to ascertain responsibility in the event of hypothetical computer crimes to the detriment of the Site. Except in the latter case, such data are not retained for more than fifteen days. For further information and to manage your preferences, we invite you to view the section "Cookie Policy - Cookie Settings", which can be reached via the link available at the bottom of each page of our website. You can choose whether to authorize us to use the relevant permissions of your device. If you do not authorize us to use relevant permissions, some products/services we provide may be unavailable, but this will not affect your use of basic functional services. You may view the detailed SDK list of our corresponding services; the which is complementary to the information available in the section "Cookie Policy - Cookie Setting".
(iii) Geo-localisation data - The Site's internal search system collects data, exclusively when used and subject to your confirmation, relating to your geographical location, in order to obtain the appropriate search results (e.g., when searching for the boutique nearest to you via the dedicated functionality).
Learn more about the geo-localization process
In order to recommend nearby shops to you, based on your separate consent, we will request your location permission and collect your location information. If you do not provide this information, it will not affect your normal browsing and use of our products/services. If you do not enable location permission, the information of the store closest to you will not be displayed automatically, but you can still manually enter and view the information of the corresponding store.
2.2. Data voluntarily provided by you
In order to enable you to take advantage of the various features offered by our website, you may be requested to provide other personal information, such as:
(i) personal information: first name, surname, date of birth, gender, nationality;
(ii) contact details: e-mail address, telephone number, address of residence or domicile; shipping address;
(iii) information relating to purchases made: date, quantity and type, product code, sale amount, VAT number where applicable, shipping/billing address, data relating to the payment method you wish to use, information on complaints, returns, guarantee, refunds and other information relating to the sale of products;
(iv) user-name and password when purchasing our products online, subscribing to one of the services provided through the website or activating a Personal Account on our website;
(v) information about your level of satisfaction if you decide to rate our products or services.
Please note that your payment information, such as your credit card number, will NOT be processed by us.
2.3. Personal information collected through social media pages
We may also collect some of your personal information when you interact with our social pages. Some information is submitted directly by you, when you decide to share - through your profile - images published on our social pages, comment on our posts and/or express your approval of one of our products, one of our initiatives or one of our events by selecting the appropriate features, as well as when you decide to write us a message using the private chat or other channels made available on the various social media.
We may also become aware of some information that is indirectly collected as a result of your interaction with our social pages; for example, we may know the time and day when you express your liking to one of our posts or send a request through a mail message.
The knowledge of much of your personal information depends on your chosen social media settings and the content you choose to make public. This information could include your first name, last name, some contact details, and the image associated with your social profile and related information collected through social log-in. We therefore remind you that some of your information may be visible to us should you decide to follow our social pages. For this reason, we invite you to read the privacy policy of the different social media and to check the privacy settings.
2.4. Personal information relating to minors
We would like to point out that the protection of the safety and privacy of minors is very important to the Tod's Group. Therefore, we do not intend to collect and do not intend to voluntarily use any personal information of persons under eighteen (18) years of age, or under any other age limit imposed by the laws in force in your country of residence. We therefore request you to refrain from providing us with any of your personal information if you are under the age of eighteen (18) years or under the age of majority in your country of residence.
In the case of collecting personal information from minors, we will only use the information when the law permits, if the guardian expressly consents. If you believe that we have unintentionally collected personal information from a child without the consent of the guardian, please inform us immediately through the contact information provided in Article 9 of this Privacy Policy and we will try to delete the relevant data as soon as possible.
- 3. FOR WHAT PURPOSES AND WITH WHAT LEGAL BASES WE USE YOUR PERSONAL INFORMATIONWhenever we acquire and process your personal information, this will be done exclusively in accordance with the principles of legitimacy envisaged in the legislation. Your personal information will be processed on the basis of the following principles of lawfulness:
3.1. CONSENT, pursuant to art. 6.1 (a) of the Regulation and to art. 13 (1) of the PIPL, in order to:
(i) conduct marketing activities, both through automated tools (SMS, MMS, messaging platforms, e-mail, push notifications) and through traditional channels (paper mail, telephone call with operator). The marketing activities may take the form of sending newsletters, promotions, discounts, facilitations, commercial information and other dedicated services, by paper mail, call with operator, direct sale, through e-mail, pre-recorded calls, 'social' or messaging platforms and SMS/MMS.
In this context, Tod’s S.p.A and local affiliated companies entrusted by TOD’s S.p.A may also process your personal information to invite you to show and events, ask you to participate in market research or to report on special initiatives dedicated to TOD'S Group customers, in the manner and period we believe to be most effective for any of the various initiatives mentioned. Learn more about our marketing actions By accepting to receive our marketing communication, you authorize us to contact you through each contact channel that you have made available to us (e-mail address, telephone number, mail address).
Following the instructions described in art. 7.7 of the privacy policy, you can decide, at any time, to block all our marketing communications or to inhibit one or more contact channels.
The provision of your personal information is entirely voluntary, but failure to provide some of them may result in your partial or total inability to be involved in our marketing initiatives. Please note that, should you decide not to consent to the processing of your personal information for marketing purposes, this would prevent us from being able to involve you in our promotional initiatives, including our periodic newsletter updates.
(ii) analysing some of your personal tastes to identify your preferences, interests and consumption choices, in order to provide you with services that better meet your expectations and needs.
The profiling activities may take the form of the analysis of information regarding your interests and preferences with regard to our products and services and your consumption choices: by surveying the type and frequency of the purchases you make on our e-commerce sites, through your Personal Account and in "guest" mode, and at our boutiques, in order to be able to guarantee you a personalised service during your future visits to TOD'S Group boutiques.
If you have also given your consent to the processing of your personal information for marketing purposes, it will allow us to send you promotions and/or invitations to initiatives that are more in line with your profile, preferences and expectations.
Learn more about our personalized services
To provide you with services in line with your interests and expectations and a personalized shopping experience, we will collect and use your personal information such as age, nationality, gender, preferred shopping channel (e-commerce boutique), event preferences fashionable; information relating to the use of our website or social media, subscription to our services, ratings on them and responses to our surveys; information relating to your purchases, such as purchase date, quantity and type, product code, sale amount, shipping/billing address, data relating to the payment method used.
We may draw conclusions from any of the above information to create a profile about you, reflecting your preferences, characteristics, tendencies, predispositions, buying inclinations and behaviours.
Should you decide not to consent to the processing of your personal information for profiling purposes, this would have no impact on your participation in our promotional communications plan but would simply result in our inability to send you personalised promotional communications.
The official website for the PRC region (https://www.hogan.cn/) currently does not offer personalized services and therefore this section of the agreement is not applicable.
Learn more about how our consent request works
When giving your consent, you will be requested to tick the checkbox for each purpose for which you wish to authorise us to process your personal information:
a) if you tick the consent check box, we will process your personal information for the chosen purpose;
b) in the event that you do not tick the consent check box, we will maintain the previous situation, i.e.,
if you have previously given us your consent, it shall remain valid until revoked or until the defined 'expiry date';
if you have not previously given us your consent, we will continue NOT to use your personal information for the purpose in question.
We would like to remind you that you may revoke previously issued consents at any time by following the instructions given in the remainder of this Privacy Policy.
3.2. FULFILMENT OF CONTRACT OBLIGATIONS OR CONTRACT MEASURES, pursuant to art. 6.1 (b) of the Regulation or to art. 13 (2) of the PIPL, in order to:
(i) enable you to purchase products, as well as to fulfil our contract obligations to you. Failure to provide your personal information will result in the impossibility of completing the purchase process, as such information is necessary for us to fulfil our contract obligations;
Learn more about our purchasing process
When placing an order for our products, you can choose to pay quickly as a guest or choose to register a member account and establish yourself as a member to enjoy more membership benefits (see section 3.2 (ii) “Create a Personal Account” for more details). When you choose to pay as a guest, you must provide us with your email address to complete the purchase process and receive transactional communications relating to the purchase order made.
When you order our products by choosing to collect in store, you must provide us with the recipient's name, mobile number and choose the store where you wish to collect the goods. When ordering our express delivery products, you must provide us with your title ("Mr." or "Ms."), recipient's name, mobile phone number, location, detailed delivery address, code postal address, e-mail address for receiving electronic invoices (optional) and invoice header information (optional) to complete the transaction smoothly and ensure the security of the transaction. If you do not provide the above information, the transaction may not be completed.
At checkout, we will generate an order for the products you have purchased, which will include your order number, information about the product you purchased, the time of your order, payment status, the amount you should pay, logistics information, and the product specifications (including size or dimensions) to help you complete the purchase process.
If you purchase through our WeChat mini-program, you can choose how your delivery address is communicated between: (i) using "synchronized WeChat address"; in this way WeChat informs us of your location (if you have authorized WeChat to locate you through its application); (ii) by providing us with your delivery address via our dedicated collection form.
(ii) allow you to create a Personal Account on our Website and use the related dedicated services. The list of services dedicated to holders of a Personal Account may be amended and/or supplemented over time at the discretion of the Personal Information Handler.
Some of the personal information that we request you to submit to us when creating your Personal Account are compulsory, as they are indispensable for us to be able to process your request to open a Personal Account; the communication of other personal information is optional, but failure to submit them may make it impossible for us to provide you with some of the services, or part of some of them, dedicated to those who have a Personal Account on our website;
Learn more about registering and logging into your personal account When you activate an account on our website, you must provide us with your email address, name, gender, date of birth (mandatory, we need this information to make sure you are not under the age of 18) and secret password to create a Hogan account. If you do not provide the above information, you may not be able to complete the personal account activation process on our website.
To access your Personal Account on our website you will be asked to enter your email address and the password you chose when activating your Personal Account.
After logging in, you can complete or edit your personal information, including your name, gender, date of birth, country/region, state, detailed address, email address, and account password. By completing your personal information and clicking save, you agree to provide us with the above information.
When you activate a WeChat mini-program account linked to us, you must provide us with your mobile phone number, WeChat avatar and nickname, city, gender and date of birth.
If you do not complete your personal information, this will not affect your normal browsing or use of our products and/or services.
(iii) enable us to respond to your contact request and allow us to provide you with the necessary assistance. The personal information we request you for when filling in the on-line form and/or which will be requested from you by our operators are indispensable to enable us to handle your request;
Learn more about our customer assistance
When communicating with customer service or handling disputes, you may need to provide us with your name, order information (including payment time, payment amount, payment channel), contact information(including contact number and delivery address), and other personal information necessary to respond to your request (including the content of communications required for customer service interactions or dispute resolution), etc., so to verify your identity information, check your order information and reply in time. If you do not provide this information, we may not be able to provide you with adequate assistance.
(iv) enable us to provide you with the services on the Website to which you have subscribed. The personal information that we request you to provide when you subscribe to a given service are indispensable for the provision of that service; therefore, failure to provide them may make it impossible, in whole or in part, for you to benefit from them.
In the event that communication channels such as messaging apps (WhatsApp, WeChat, Telegram, etc.) are used for the provision of services, please also read the privacy policy of the messaging platform used.
Learn more about the web site services
When you subscribe to one of our website services you may need to give us your name, contact details and other information we need to be able to provide you with the service you are subscribing to. We will ask you to communicate only the information strictly necessary for the optimal provision of the service, therefore if you do not provide this information, we may not be able to provide you with the requested service.
3.3. LEGAL OBLIGATIONS, pursuant to art. 6.1 (c) of the Regulation and to art. 13 (3) of the PIPL, in order to comply with compulsory regulatory provisions to which the Company is subject, including in the tax and administrative area.
We may process your personal information based on other circumstances established by specific laws and administrative regulations applicable from time to time.
- 4. HOW WE PROCESS AND PROTECT YOUR PERSONAL INFORMATIONThe processing will be carried out with the aid of telematic, paper and computer tools; such processing will be based on the principles of correctness, lawfulness, transparency and protection of your rights and confidentiality.
In particular, the processing of your data, including for profiling purposes, may be carried out by means of automated processes, for instance through the comparison and comparative analysis of your purchasing choices (types, quantities, frequency, etc.), during a given period and/or season, and through the analysis of the type and number of your possible requests for information on products made in a predetermined timeframe. The official website for the PRC region (https://www.hogan.cn/) currently does not offer personalized services and therefore this section of the agreement is not applicable.
The data will be processed in such a way as to minimise the risks of destruction, loss, unauthorised access or processing that is not permitted or not in accordance with the purposes of collection.
We use of industry-standard physical, organizational, contractual and technological security measures to protect your personal information from unauthorized access, public disclosure, use, modification, damage or loss.
(i) Personal information storage area: For the purposes of global business operations and service improvement, we will store personal information in Italy: we will do this in accordance with the relevant laws and regulations, after obtaining your separate consent. In such cases, we will ensure that your personal information is protected equally and effectively as it is in Mainland China.
(ii) Technical and organizational measures: in order to protect your information security, we strive to adopt various physical, electronic and management security measures that meet industry standards to protect your personal information, and establish a personal information protection compliance internal system to manage and regulate the storage and use of personal information. We implement comprehensive data security control through information contact confidentiality agreements, monitoring and auditing mechanisms to prevent your personal information from unauthorized access, public disclosure, use, modification, damage or loss. Our professional security team will strengthen the security of personal information (including sensitive information reporting, encrypted storage of sensitive information, access control, etc.). We will use no less than the same protection means and measures as we use for our own users' personal information to protect indirectly obtained personal information. For example, use encryption technology to ensure the confidentiality of data; use trusted protection mechanisms to prevent data from malicious attacks; deploy access control mechanisms to ensure that only authorized personnel can access personal information; and organize security and privacy protection training courses to strengthen employees' awareness of the importance of protecting personal information.
(iii) Agreements with third parties: Before receiving your personal information from a third party, we will clearly require the third party to collect and process your personal information after obtaining your explicit written consent and we will ask the third party to undertake to comply with the applicable privacy legislation. We formally commit the third party in the event of a violation of the law, who is required to assume full responsibility for their conduct. Before we share your personal information with our business partners, we ask them to formally commit to their information protection responsibilities. Before communicating personal information to them, we sign a data processing agreement, which stipulates the obligation of confidentiality of the partner and strict rules for the storage, use and disclosure of personal information. Our partners are subject to our control and accept our review, supervision, and verification. If they violate the law, they are required to take full responsibility for their conduct.
(iv) Events of security breach: In the event of an unfortunate personal information security incident, we will immediately set up a special emergency response team, activate the contingency plan, prevent the security incident from expanding.
In accordance with the legal requirements, we will promptly inform you of the incident, notifying you of: (i) the event that has occurred, (ii) its possible impact, (iii) the measures we have taken (iv) the measures that we will adopt to avoid a recurrence of the incident, (iv) any corrective plans that may be implemented by you to reduce the risk and impact of the incident that has occurred.
We will promptly inform you of the relevant circumstances of the accident by email, letter, phone call, push notification, etc. When it is difficult to inform the data subject one by one, we will advertise in a reasonable and effective manner. At the same time, we will promptly report the security incident to the regulatory authorities.
Please know and understand that the Internet is not an absolutely secure environment, and we strongly recommend that you help us ensure the security of your account through secure methods and strong passwords. If you find that your personal information has been leaked, especially your account or password, please contact us immediately according to the contact information provided in this privacy policy, so that we can take corresponding measures.
- 5. HOW WE SHARE, TRANSFER AND DISCLOSE YOUR PERSONAL INFORMATION5.1 Sharing the personal information with entrusted partners
In order to improve efficiency and reduce costs, we may entrust the processing of personal information, on our behalf, to companies, associations or natural persons, also affiliated to the Tod's Group , for:
(i) the provision of customer care services;
(ii) the provision of assistance or consultancy services;
(iii) the execution of maintenance and development of IT systems;
(iv) data processing;
(v) the supply of logistic services;
(vi) carrying out marketing and communication activities;
(vii) the provision of part of some services available on the website.
We agree with them, through written agreements, the purpose, term, method of processing, types of personal information, protection measures, rights and obligations of both parties and supervise their personal information processing activities, also through checks and audits.
5.2 Communicating the personal information to third parties for the achievement of own purposes
In order to successfully complete the process of purchasing our products, we will share your personal information, to the minimum extent necessary, with partners who will independently process your personal information, such as:
(i) companies that manage electronic payment services and tax exemption services;
(ii) companies that provide fraud prevention services through electronic payments;
(iii) companies that provide product shipping/delivery services. To receive further information relating to these operators (name of the third party, contact details, purpose of the processing, methods of processing and type of personal information processed), you can contact us by writing to the contacts indicated in art. 9 of the privacy policy.
Any other transfer of your personal information to third parties will only take place with your separate consent.
They will only process your personal information on their own behalf with your separate consent. These partners may have their own independent privacy policy and user service level agreement. We recommend that you read and abide by the partner's user service agreement and privacy policy.
Without prejudice to the provisions of art. 2.1 (ii) of the privacy policy, before the transfer of your personal information to such third parties, your distinct consent will be requested, and you will be provided with all the necessary accompanying information.
5.3 Personal information transferring due to corporate transactions
In principle, we will not transfer control of your personal information to any other company, organization or individual.
Mergers, acquisitions or bankruptcy liquidations may involve the transfer of your personal information.
In this case, we will communicate to you the recipient's name and contact information, requesting the recipient to continue to comply with our same commitments and legal obligations regarding the protection of personal information.
In case of modification of the purposes of the processing of personal information other than those indicated in this information, we will request again to obtain your prior consent, in accordance with the provisions of the law.
5.4 Public disclosure of personal information
We will not disclose your personal information unless you have given your separate consent.
We may publicly disclose your personal information in the event of specific statutory provisions, legal process, legal action or mandatory requirements of government authorities.
Please note that any comments or information that you voluntarily post or share while using our products/services may be personally identifiable or sensitive information, such as information about your transaction or information uploaded in the form of text, images or videos. We therefore invite you to pay close attention to any information you decide to share publicly.
5.5 Cross-border transfers
Your personal information will be transferred, subject to your consent, from your country of residence to our office in Italy. We would like to point out that the European data protection legislation to which we are subject (Regulation (EU) 2016/679) provides a level of protection for personal information comparable to that guaranteed by the legal framework of your country of residence.
Before to transfer your personal information outside of China, we will sign standard contractual clauses, released by the Cyberspace Administration of China, with the personal information importer to ensure an adequate level of protection of the personal information also outside the Chinese borders. Should it become necessary to transfer your personal information outside the European Economic Area (EEA), to companies of the Tod's Group and/or to third parties who carry out tasks of a technical and organisational nature on our behalf which are consistent with the pursuit of the purposes for which your data have been collected and processed, this will only take place where it is possible to guarantee a level of protection of personal information equivalent to that of the Community.
In fact, we guarantee that your personal information may only be transferred to a country outside the European Economic Area that does not have a European Commission (EC) Adequacy Decision, if at least one of the instruments recognised by the Regulation as guaranteeing an adequate level of protection for the personal information transferred has been adopted, namely:
i. the Adequacy Decisions adopted by the European Commission pursuant to Art. 45 of the Regulation;
ii. the provision of specific Standard Contract Clauses (EU Model Clauses), approved by the European Commission, in order to ensure that the level of protection of personal information processed by our partners outside the European Economic Area complies with that guaranteed within the European Economic Area.
We also undertake to carry out, in accordance with the law, any prior risk assessment regarding the transfer of personal information, adopting, where appropriate, any additional security measures in addition to the protections already guaranteed by the aforementioned transfer instruments.
You can write us to the contact points detailed in the art. 9 of the privacy policy to receive further information on data protection guarantees in case of transfer to countries outside the European Economic Area.
- 6. HOW LONG WE PROCESS AND KEEP YOUR PERSONAL INFORMATIONYour personal information will be processed for varying periods of time depending on the different purposes of the processing; in any event, only for the period of time strictly necessary to achieve the purposes for which the data were collected and processed. Reached the maximum terms of retention of personal information, based on the deadlines detailed below, these will be deleted or if made anonymous.
For the processing purposes set out below, the processing and storage of your personal information will be as follows:
6.1. Purposes of processing based on 'CONSENT', as referred to in art. 3.1 of the privacy policy:
(i) Marketing activities: until consent is revoked;
(ii) Profiling activities: 7 years from the date of issue of your consent, with automatic renewal in the event of a new purchase at a Tod's Group shop or website.
6.2. Processing purposes based on 'FULFILMENT OF CONTRACT OBLIGATIONS OR PRE-CONTRACT MEASURES', referred to in art. 3.2 of the privacy policy:
(i) Sale of Tod's Group products: three years from the date of completion of the sale;
(ii) Provision of services dedicated to Personal Account holders: until you close your Personal Account or 7 years from your last interaction with your Personal Account, whichever is earlier. With the closure of your personal account, all personal information contained therein will be deleted, without prejudice to what is indicated in point 6.3 of the privacy policy.
(iii) Provision of support services to users of the Web Site: until complete fulfilment of the commitments undertaken following your request for assistance, support or contact;
(iv) Other services available on the Website: until we have fully discharged our obligations in respect of your membership of the chosen service.
6.3. Purposes of processing based on 'LEGAL OBLIGATIONS', as referred to in art. 3.3 of the privacy policy: the storage of your personal information may be further extended, with respect to the timeframe indicated above, should the storage of your personal information be required by compulsory legal regulations, within the time limits provided for by the latter.
- 7. WHAT ARE YOUR PRIVACY RIGHTSWe would like to remind you that you have the right at any time to know what personal information we hold about you and how they are being processed, to request that they be updated or corrected and, in the cases provided for by current legislation, to obtain their deletion, restriction of processing or to object to their processing. If you wish, you may also receive your personal information in electronic format for the purpose of transfer to a third party indicated by you.
7.1. Request to access your personal information as well as receive information on the purpose of the processing, the categories of data processed, the recipients or categories of recipients to whom your personal information may be disclosed, the planned retention period, the application or non-application of profiling mechanisms and automated decision-making processes.
If you have a Personal Account, you can access the following personal information through:
- Section: My account - Personal information: (i) name; (ii) genre/title; (iii) dates of birth; (iv) password; (v) country
- Section: My account - My orders: (i) information on purchase orders placed If you have joined the Mini Program WeChat “Hogan boutique”
- Section My personal information: (i) name; (ii) genre/title; (iii) province; (iv) city; (v) address
- Section: My profile: (i) dates of birth; (ii) mobile number; (iii) information on purchase orders placed.
7.2. Request to rectify your personal information. This right allows you to correct or complete the data concerning you, although in some cases a prior verification of the correctness of the new data provided by you is necessary.
If you have a Personal Account, you can rectify the following personal information through the Section My account - Personal information: (i) name; (ii) genre/title; (iii) dates of birth; (iv) password; (v) country.
7.3. Request to delete your personal information. This right allows you to request the deletion or removal of your personal information if there are no valid reasons for continuing the processing. You also have the right to request the deletion or removal of your personal information if you have exercised your right to object to the processing and there is no other legal basis for us to keep it, or if we have processed your information in violation of the law or if we are obliged to delete your personal information in order to comply with a specific legal provision. Please note that we may not be able to comply with your request for deletion or may only be able to comply with it partially; for example, because of legal, juridical or fiscal constraints beyond our control that prevent us from deleting all or part of your personal information. The reasons for our total or partial impossibility of fulfilling your request will be submitted to you promptly.
Please note that when we decide to execute your deletion request, we will delete your information from the server as soon as possible, but due to applicable technological, legal and security restrictions, we may not be able to delete the corresponding information from the system. backup right away. In such cases, we will hold your personal information securely and isolate it from any further processing until the backup is deleted or anonymised. Learn more about how you can close your Personal Account and Mini-program Account
If you are the owner of a Personal Account and you decide to close it, remember that this involves the deletion of all personal information contained therein, if retention is not required by applicable laws and regulations. You can decide to close your Personal Account at any time, using the contacts indicated in art. 9 of the privacy policy.
7.4. Request for restriction of personal information processing. Said right enables you to request the suspension of the processing of your personal information in the following cases:
(a) if you request us to determine the correctness of your data.
(b) if you do not wish your data to be deleted, despite the fact that the use of the data by us is in breach of a regulation.
(c) if you wish your data to be retained even if the reasons for their retention by us have ceased to exist, because you wish to ascertain, exercise or defend a legally protected right.
(d) if you have objected to the use of your data but it is necessary for us to ascertain the existence of legal grounds for their use.
You have the right to restrict our processing of your personal information under certain circumstances, and the right to object us to use your personal information for automated decision-making, profiling, or the right to object us to process your publicly available personal Information, or to opt-out the share of your personal information with third parties if required by applicable law.
7.5. Request to object to the processing of your personal information. By exercising such right, you may obtain the cessation of the processing of your personal information in relation to the purpose(s) indicated by you. We would like to point out that our granting of your request for objection may or may not take place on the basis of the lawfulness of the processing itself.
7.6. Request for portability of your personal information. You have the right to obtain a copy of your personal information. Subject to identity verification and without prejudice to the limits defined by the applicable legislation, upon your request, we will send a copy of your personal information to a third party indicated by you, in the manner prescribed by current legislation / governmental authorities.
7.7. Revocation of consent. If the processing is carried out against your explicit consent, we will, within the timeframe provided for by the law, execute your request for revocation and cease the processing in question. For personal information obtained by us based on your consent, you have the right to change the scope of your consent or withdraw your consent by disabling device functions, setting privacy Settings, cancelling corporate customer identity authentication, or cancelling your account. Please understand that after you withdraw your consent, we will no longer process the personal information obtained based on your consent, which will affect the products or services provided to you corresponding to this part of personal information. However, your decision to withdraw your consent or authorization will not affect the prior processing of personal information based on your consent before .
With regard to revoking your consent to the processing of your personal information for marketing and/or profiling purposes, without prejudice to the possibility of exercising this right by writing to the e-mail address dataprivacyofficer@todsgroup.com (see art. 9 of the privacy policy), we would like to point out that in each of our communications, by e-mail or SMS, of a promotional nature, there is a function through which you may autonomously (i) proceed to block one or more of the communication channels used by us to contact you;
(ii) withdraw consent to the processing of your data for marketing purposes. In this case, any communication from us of an advertising and/or promotional nature will cease and any active newsletter service (relating to any Tod's Group brand) will be automatically deactivated;
(iii) withdraw consent for profiling purposes.
The same functions are available within your Personal Account, if you have activated one.
In addition, a functionality is available in each of our newsletters through which you can unsubscribe from the newsletter service.
Please note that you will not be discriminated against in any way for having exercised one or more of the rights recognised by the legislation, nor will such exercise have any repercussions on any existing relationship with the Company.
We would like to remind you that you may at any time decide to lodge a complaint with the Supervisory Authority, or appeal before the Judicial Authority, in the event of a breach of the rules on the protection of personal information and/or if you consider that one or more of your rights have been violated.
- 8. HOW EXERCISE YOUR PRIVACY RIGHTSWhen exercising the aforementioned rights, we reserve the right to request you, in the manner we deem most appropriate, for specific information to help us confirm your identity, in order to be reasonably sure that only you have access to your personal information and that they are not disclosed to third parties not entitled to receive them.
We undertake to verify your identity and to respond to your request, if founded, within 15 working days of receiving your request. Occasionally, within the time limits allowed by law, we may take longer if the request is particularly complex or if you have made multiple requests. In that case, we will notify you and keep you updated.
The exercise of your rights is completely free of charge.
Should your claims, however, be manifestly unfounded or excessive, particularly due to their repetitive nature, we reserve the right to
• the right to charge you a reasonable fee based on the administrative costs incurred in providing you with the information or communication or taking the requested action;
• to refuse to comply with your request.
If you exercise your rights on behalf of others, or if you, as a close relative of a deceased of our user, request us to access, copy, correct or delete the information related to the deceased, please provide proof of your identity and the other person's identity, as well as proof of the relationship, such as special power of attorney or death certificate of the deceased.
- 9. HOW TO CONTACT USIf you want to know more information about this privacy policy, including exercising your rights, complaints, or the rules of the processing of your personal information, if you have any questions, you can contact our contact information below detailed, we will respond to your request within the time frame required by laws.
(i) if your personal information is processed for the purpose of allowing you to purchase products (art. 3.2 (i) of the privacy policy), you may write to:
• mail: Personal Information Protection Officer - Tod's (Shanghai) Trading Co. Ltd, Floor 45, Wheelock Square, No. 1717 West Nanjing Road, Jing'an District, Shanghai
• e-mail: TodsChina.privacy@todsgroup.com.
(ii) for any other purpose of personal information processing described in the Privacy Policy, you may write to:
• mail: Data Protection Officer - Tod's S.p.A., Via Filippo Della Valle n. 1, 63811 Sant'Elpidio a Mare (FM) - Italy (EU).
• e-mail: dataprivacyofficer@todsgroup.com.
- 10. HOW WE UPDATE THIS PRIVACY POLICYThis privacy policy will be changed to adapt to the law, technological and practice changes.
However, we will not reduce your rights under this privacy policy without your express consent. We will post any changes to this privacy policy on this page. For major changes involving your rights, we will also provide more significant notifications, such as in- APP notification or email notification.
Please refer to the indication 'LAST UPDATED' at the top of this Privacy Policy. We therefore invite you to visit this page periodically.
We may also need to contact you to obtain your consent in order to allow you to continue using the services, if this is necessary due to changes in applicable law.