Privacy Policy (Updated)

1)PURPOSES OF THE PRIVACY POLICY

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 as subsequently amended and supplemented;(the "Privacy Code" ) and with the new European regulation n. 679/2016 on the processing of personal data (the "European Privacy Regulation" ).

2)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, returns management and product warranty;

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.

3)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.

4)PURPOSES OF THE PROCESSING

Giuseppe Online and Giuseppe Zanotti processes your Data for the following purposes:

i. to allow you to register on the Website by creating a personal account and to carry out the activities regulated in the Website Terms and Conditions of Sale, including purchases on the Website, to use the services made available through the Website, including customer support services (i.e., warranty and returns) and to exercise and defend your rights against users and third parties ("Contract 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 for:

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" ).

In addition, data relating to the purchase volume, product category, shop where the purchase was made and date of birth may be processed based on the legitimate interest of Giuseppe Zanotti to provide a service that is more in line with the needs of data subjects, adequately balanced with the needs to protect the rights of data subjects, as well as to carry out statistical analyses on an anonymous basis on the performance of Giuseppe Zanotti’s business. ("Legitimate Marketing Interest Purposes").

5) 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;

 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.

6) 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.

7) 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.

8) 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.

9) 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.

At any time and in the manner set out in paragraph 9 above, you may (a) request the restriction of personal data processing in the event that (i) you contest the accuracy of your personal data, for the period necessary to verify the accuracy of such personal data; (ii) the processing is unlawful and you object to the erasure of your personal data and request instead that its use be restricted; (iii) although the company no longer needs them for the purposes of processing, personal data are necessary for you to establish, exercise or defend a right in court; (iv) You have objected to processing pursuant to article 21, paragraph 1, of the GDPR pending verification of whether the legitimate reasons of the data controller prevail over those of the data subject; (b) object at any time to the processing of personal data based on a legitimate interest; (c) request the deletion of personal data relating to you without undue delay; (d) obtain portability of personal data relating to you; (e) lodge a complaint with the Data Protection Authority where applicable.

At any time you may exercise the above rights, modify the contact methods, notify the companies of any updates of your data, request the removal of your personal data communicated by third parties, or to obtain further information about the use thereof by the Companies, by contacting them respectively at privacy@giuseppezanotti.com.

The Companies have appointed a Data Protection Officer, who can be contacted at the following address: DPO@giuseppezanotti.com.

10) RETENTION TERM

The Companies will process 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 Company, 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 Company, 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.

11)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.

12)IMPORTANT ADDITIONAL PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS

In this section, we provide information for California residents, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA”), which requires that we provide California residents certain specific information about how we handle their personal information, whether collected online or offline. Under the CCPA, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. It does not include publicly available data as defined by the CCPA.

This section does not address or apply to our handling of personal information that is subject to an exemption under Section 1798.145(c) – (f) of the CCPA. Since the CCPA requires that we disclose specific information about how we handle certain personal information collected about all California residents, the scope of this section may be different than the scope of our privacy policy.

Except for the Right to Opt-out and the Right of Non-Discrimination, this section does not apply to California residents with whom we transact or communicate solely in the context of providing or receiving a product or service to or from a company that employs such residents or engages such residents as contractors. This section also does not apply to personal information we collect about job applicants, independent contractors, or current or former full-time, part-time and temporary employees and staff, officers, directors or owners of Giuseppe Online Ltd and other companies part of the Giuseppe Zanotti Group.

Notice at Collection, Purposes of Use of Personal Information and Categories of Personal Information that We Collect, Disclose, and Sell

The table below sets out generally the categories of personal information (as defined by the CCPA) about California residents that we collect, sell, and disclose to others for a business purpose. We collect these categories of personal information from the sources described in the section above, and for the purposes described in the section above. Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident.

Categories of personal information	Do we collect?	Do we disclose for business purpose(s)?	Do we sell?
Name, Contact Information and other Identifiers: Identifiers such as a real name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name or other similar identifiers necessary for the shipping.	YES	YES	NO
Customer Records: Paper and electronic customer records containing personal information, such as name, signature, address, telephone number, bank account number, credit card number, debit card number, or any other financial or payment information.	YES	YES	NO
Protected Classifications: Characteristics of protected classifications under California or federal law: sex.	YES	YES	NO
Purchase History and Tendencies: Commercial information including records of personal property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.	YES	YES	NO
Biometric Information: Physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including DNA, imagery of the iris, retina, fingerprint, faceprint, hand, palm, vein patterns, and voice recordings, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.	NO	NO	NO
Usage Data: Internet or other electronic network activity information, including, but not limited to, browsing history, clickstream data, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement, including access logs and other activity information related to your use of any Giuseppe On Line S.r.l./Giuseppe On Line Ltd websites, applications or other online services	YES	YES	NO
Geolocation Data: Precise geographic location information about a particular individual or device.	NO	NO	NO
Audio, Video and other Electronic Data: Audio, electronic, visual, thermal, olfactory, or similar information such as CCTV footage, photographs, and call recordings and other audio recording (e.g., recorded meetings and webinars).	NO	NO	NO
Professional or employment-related information: Employment history, qualifications, licensing, disciplinary record.	NO	NO	NO
Education Information: Information about education history or background that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).	NO	NO	NO
Profiles and Inferences: Inferences drawn from any of the information identified above to create a profile reflecting a resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.	YES	YES	NO

California Resident Rights
California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below.

Right to Opt-out of Sale of Personal Information
California residents have the right to opt-out of our sale of their personal information. Opt-out rights can be exercised writing an email to

privacy@giuseppezanotti.com

Notice at Collection. At or before the point of collection of personal information, notice must be provided to California residents of the categories of personal information collected and the purposes for which such information is used.

Verifiable Requests to Delete and Requests to Know. Subject to certain exceptions, California residents have the right to make the following requests, at no charge:

Request to Delete: California residents have the right to request deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies.

Request to Know: California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the resident to transmit this information to another entity without hindrance. California residents also have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including the following:

categories of personal information collected;
categories of sources of personal information;
business and/or commercial purposes for collecting and selling their personal information;
categories of third parties/with whom we have disclosed or shared their personal information;
categories of personal information that we have disclosed or shared with a third party for a business purpose;
categories of personal information collected; and
categories of third parties to whom the residents’ personal information has been sold and the specific categories of personal information sold to each category of third party.

California residents may make Requests to Know up to twice every 12 months.

Submitting Requests. Requests to Opt-out of Sale of Personal Information, Requests to Know, and Requests to Delete may be submitted by going to our California Individual Rights Page at https://www.giuseppezanotti.com/us/info/customer-service/contacts, as well as by contacting us at 844 492 6688 (toll free) or by sending the request by emailing us at privacy@giuseppezanotti.com. We will respond to verifiable requests received from California consumers as required by law.

Right to Non-Discrimination. The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA. Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices, rates, or penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents’ data.

Financial Incentives. A business may offer financial incentives for the collection, sale or deletion of California residents’ personal information, provided the incentive is not unjust, unreasonable, coercive or usurious, and is made available in compliance with applicable transparency, informed consent, and opt-out requirements. California residents have the right to be notified of any financial incentive offers and their material terms, and the right to opt-out of such incentives at any time; residents may not be included in such incentives without their prior informed opt-in consent. We do not offer any incentives at this time.
For more information about our privacy practices, you may contact us as set forth in the section above.