Privacy Policy (Updated)

2018-05-15

Giuseppe Zanotti S.p.A. e Giuseppe On Line S.r.l., with registered office in Via dell’Artigianato 28, 47030 San Mauro Pascoli (FC), Italy, in their quality of data controllers ("Giuseppe Zanotti" and "Giuseppe Online and jointly, the "Companies" ) which you may contact at the following email address: privacy@giuseppezanotti.com , would like to inform you, through this policy on the processing of personal data (the "Privacy Policy" ) about the ways and manners in which the Companies process the information collected through the website www.giuseppezanotti.com (the "Site" ), in compliance with the Legislative Decree 196/2003 (the "Privacy Code" ) and with the new European regulation n. 679/2016 on the processing of personal data (the "European Privacy Regulation" ), applicable from May 25th 2018.

CATEGORIES OF DATA

The Companies collect and process the following categories of data (the "Data" ):

a) personal data and contact details you provide when you create a personal account on the Site;

b) data related to purchases made through the Site;

c) browsing data on your use of the services available through the Site, which are collected using cookies, according to paragraph “DATA AUTOMATICALLY COLLECTED VIA TECHNOLOGY” below ;

d) data you provide when you request information or assistance;

e) data you provide during contests, online surveys and/or promotions offered through the Site

We do not process data related to your health or other special categories of data according to art. 9 of the European Privacy Regulation. Data of minors shall be processed in ways and manners described in paragraph 8 of this Privacy Policy.

The categories of Data mentioned above will only be processed to the extent necessary to the purposes described in paragraph 4.

PROCESSING OF DATA

Your Data will be processed using electronics means or in paper and will be protected with the implementation of adequate security measures to ensure safety and confidentiality of the Data. Specifically, the Companies implement technical and organizational measures necessary to ensure that Data are protected against loss, alteration, unauthorised disclosure of, or access to, Data transmitted, stored or otherwise processed .

When it is no longer necessary to process the Data for the purpose for which they were collected, or at the end of the retention period (further explained in paragraph 10), Giuseppe Zanotti and Giuseppe Online will anonymize personal data and will remove identifiers.

PURPOSES OF THE PROCESSING

Giuseppe Online processes your Data for the following purposes

i. to allow you to register to the Site by creating a personal account and performing all the activities which are subjected to the General Terms of Sale of the Site, including purchases, or to enjoy services offered by the Site, including customer service, and to enforce and defend rights toward users or third parties ("Contractual Purposes" );

ii. to comply with legal and regulatory obligations ("Legal Purposes" );

iii. to carry out activities which are functional to transfer of branches, acquisitions, mergers, divisions or other changes and to perform such operations ("Legitimate Interest for Business Purposes" ).

Furthermore, Giuseppe Zanotti processes your Data, with your previous consent:

a. to send you marketing communications, through paper and electronic means (including email, SMS, MMS, social network, instant messages, mobile applications, banner, fax, mail and phone) relating to its brands, products and/or services, to invite you to events and to conduct market analysis and statistics ("Marketing Purposes" );

b. to analyse your habits, interests and preferences in order to better tailor the abovementioned marketing communications to your specific needs ("Profiling Purposes" ).

Furthermore, Data related to your volumes of spending, categories of products, store where you purchase your products and your birthday, starting from May 25th 2018, can be used on the basis of the legitimate interest of Giuseppe Zanotti to provide a service which is more in line with the needs of its customers, adequately balanced with the interests and rights of the data subjects involved ("Legitimate Interest for Marketing Purposes" ).

LEGAL BASIS FOR THE PROCESSING

Processing of Data for Contractual Purposes is mandatory since it is necessary for the registration on the Site, for the performance of all activities related to the General Terms of Sale of the Site, for the purchase of products online, and to enjoy specific services offered through the Site. Processing of Data for Legal Purposes is mandatory since it is required by the applicable laws. If you do not want your Data to be processed for these purposes, you will not be able to register to the Site, nor to enjoy the services offered by the Companies through the Site

Processing for Legitimate Interests for Business Purposes is carried out according to art. 24 par. 1 d) of the Privacy Code and in order to pursue the legitimate interest of Giuseppe Online and his counterparts to carry out economic operations indicated therein, and according to art. 6 f) of the European Privacy Regulation, properly balanced with your interests, since the processing will only be limited to the extent necessary to perform such operations.

Processing for Marketing and Profiling Purposes is not mandatory, and subject to your prior consent. If you decide not to give your consent however, Giuseppe Zanotti will not be able to inform you about new product/services, promotions, personalized offers, or to carry out market surveys, or to send other communications and materials in line with your interests.

Processing for Legitimate Interest for Marketing Purposes is functional to the pursuit of a legitimate interest of Giuseppe Zanotti, properly balanced with the interests of the users and, considering the limitation to this form of processing explained in paragraph 4, and will be carried out starting from May 25th 2018.

DATA AUTOMATICALLY COLLECTED VIA TECHNOLOGY

• When you visit the Site, we passively collect data through the use of cookies on your computer and Internet connection, such as the IP address of your computer and/or Internet service provider, the date and time you access the Site, the Internet address of websites from which you link to our Site, the computer technology you are using and your movements and preferences on our Site. We may also use such cookies to collect information in connection with future visits to the Site (such as to remember your username and password), to recognize you as a previous visitor, and to track your activity on the Site. You may set your browser to notify you when a cookie is sent or to refuse cookies altogether, but certain features of the Site might not work without cookies.

• We reserve the right to use other technologies such as Internet tags, web beacons, pixel tags, and navigational data collection tools, including tools offered by third parties. We use data collected by such technologies primarily to:

 evaluate, analyses and improve our business;

 administer, protect, and improve our Site and our systems;

 better understand the preferences of our Site visitors;

 identify server problems;

 compile aggregated statistics about Site usage;

 help personalize your experience on our Site;

 advertise on other sites across the Internet;

 personalize offers; and

 help us track e-mail response rates, identify when our emails are viewed, and track whether our emails are forwarded.

• We may combine data gathered through cookies and other tracking technologies with personal data, although when we do, we treat all such data as personal data for purposes of this Privacy Policy.

• We may also use third parties to serve ads on the Site. Certain third parties may automatically collect information about your visits to this and other websites, your IP address, your ISP, the browser you use to visit our Site (but not your name, address, e-mail address or telephone number). They do this by using Cookies, Pixel Tags or other technologies. Information collected may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of our Site and the other sites tracked by these third parties. This policy does not apply to, and we are not responsible for, Cookies or Pixel Tags in third party ads, and we encourage you to check the privacy policies of advertisers and/or ad services to learn about their use of Cookies and other technologies. If you would like more information about this practice and to know your choices about not having this information used by these companies, click here: http://www.aboutads.info/choices or http://www.networkadvertising.org.

• This Site also uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze your use of the Site, compiling reports on website activity and providing other services relating to website activity and Internet usage. By using the Site, you consent to the processing of data about you by Google in the manner and for the purposes set out above. To view Google’s privacy policy, please visit http://www.google.com/intl/en/analytics/privacyoverview.html. If you would like to opt out of sending your data to Google for analytics purposes, you can install the Google Analytics Browser Add-On, details of which are available at http://tools.google.com/dlpage/gaoptout?hl=en

• How We Respond to Do Not Track Signals. We do not currently respond to “do not track” signals or other mechanisms that might enable consumers to opt out of tracking on our Site.

COMMUNICATIONS OF PERSONAL DATA

Data provide by the users will be processed by data processors and other people in charge of the processing appointed by Giuseppe Zanotti and Giuseppe Online as explained in this Privacy Policy, and they will not be disclosed in any case.

The Companies enter into different contracts with selected third parties, who provide different services, for example maintenance of the Site, management of the communications with the customers and other services. The services provided by third parties are: hosting, processing orders, anti-fraud checks, placing order and managing returns, elaboration of payments, customers service, shipment and delivery, correspondence and web marketing. Data collected through the Site can be accessed by said third parties, and only on behalf of the companies. In any case, those service providers are not allowed by law to use personal data of the users for other purposes. The Companies may also communicate Data to financial institutions or other third parties in relation to payment operations. Data of the users will not be communicated to other third parties, except if it is required by law, in relation to a legal claim or a legal proceeding, or when they are necessary to protect the rights and interests of the Companies.

OVERSEAS TRANSFER OF PERSONAL DATA

Data can be freely transferred outside the national territory to other European countries, but they may also be transferred to shops belonging to the Zanotti Group , which are located outside the European Union, and in particular in the USA and in China. Any transfer of Data outside the European Union, will be carried out by taking reasonable and appropriate safeguards to keep the Data safe, according to art. 44 of the Privacy Code and articles 45 and 46 of the European Privacy Regulation. You will have the right to obtain a copy of the Data held abroad and to receive information on the place where the Data are kept, by asking directly to Giuseppe Zanotti and Giuseppe Online, through the contact details provided in paragraph 9 of this document.

DATA SUBJECTS UNDER 18

The Site is not directly addressed to minors; however some of the services offered by the Site can be enjoyed also by subjects under 18. In this case, Giuseppe Zanotti and Giuseppe Online will collect and process Data of minors only for the purposes, and in the ways and manners explained in this Privacy Policy, in compliance with art. 8 of the European Privacy Regulation and with the prior consent of a parent or another legal guardian, whose data will be collected only for the purpose of obtaining such consent.

YOUR RIGHTS

You will always, and with no additional charge, have the right to: (a) obtain confirmation as to whether or not Data concerning you are being processed, and if this is the case, have access to the Data; (b) know the origin of the data, the purposes and the way in which they are processed and the logic applied to processing by automated means; (c) ask for the update, rectification or, if you are interested, the integration of the Data; (d) ask the erasure, the anonymization or the blocking of Data unlawfully processed or to object to the processing for legitimate reasons; (e) object, fully or partially, to the processing for purposes of direct marketing carried out either through automated or more traditional ways; (f) withdraw your consent at any time, without affecting the lawfulness of processing based on consent before the withdrawal.

Together with the abovementioned rights, starting from May 25th 2018, you will also enjoy the rights enshrined in paragraph 10 b) of this Privacy Policy.

You will be able, at any time, to exercise your rights, to change your contact details, to notify the Companies any update regarding your Data, to ask the removal of Data communicated to third parties and to obtain further information on the processing of your Data carried out by the Companies, by writing an email to the following address: privacy@giuseppezanotti.com.

FURTHER PROVISIONS APPLICABLE FROM MAY 25TH 2018

The following provisions will become fully effective starting from May 25th 2018, when the European Privacy Regulation becomes applicable

a) Periods of retention of the Data: the Companies will process your Data for the time necessary to fulfil the purposes for which they were initially collected. In any case, the following retention periods shall apply to the processing of Data for each specific purpose:

• Data collected for Contractual Purposes will be retained for the duration of the contract, and then for 10 years after its termination to exercise/defend a right of Giuseppe Online, both in court and outside, where a claim should arise relation to the contract ;

• Data collected for Legal Purposes will be retained in accordance with the specific limitation periods defined by law;

• Data collected for Marketing Purposes of Giuseppe Zanotti, for Profiling Purposes and for Legitimate Interest for Profiling Purposes will be retained for 7 years from the last contact we have with you (e.g. last purchase, last newsletter opened)

• Data collected for Legitimate Interest for Business Purposes will be retained for 10 years from the moment of their collection.

Once these terms have expired, your Data will be deleted/anonymized and/or aggregated.

a) Additional rights: at any time and in the ways and manners explained in the previous paragraph you will also have the right to: (a) ask for a restriction of the processing when: (i) you contest the accuracy of the Data, for a period necessary to the Companies to verify said accuracy; (ii) the processing is unlawful and you object to the erasure of the Data and ask for the restriction of their use instead; (iii) the Companies no longer need the Data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims; (iv) you have objected to processing pursuant to art. 21.1 of the European Privacy Regulation, pending the verification on whether the legitimate grounds of the controller override yours; (b) object to the processing; (c) ask for the erasure of your Data without undue delay; (d) ask for the portability of your Data; (e) where there are the conditions, bring a claim before the competent national authorities.

b) The Companies have appointed a Data Protection Officer, that you may contact through the following email address: DPO@giuseppezanotti.com.

UPDATES

This Privacy Policy will be effective from the date indicated in the heading. The Companies however, might change and/or integrate this Privacy Policy, also as a consequence of further modifications and/or integration to the European Privacy Regulation. Updates and modifications will be notified in advance, and in any case, you will always be able to view the updated Privacy Policy at Privacy Policy

If you have doubts, questions or complaints with regard to the collection and processing of your Data, you may contact the Companies through the contacts section on the Site.