1. Introduction
With this document, the Data Controller, Industries S.p.A., a company belonging to the Moncler Group, provides users of the site www.moncler.com (hereinafter, the “Site”) with some information on the cookies used.
2. What are cookies?
Cookies are strings of text that the Site visited by the user (so-called ‘first parties’), or other sites or web servers (so-called ‘third parties’) directly or indirectly place and store on the user’s terminal device (usually on the browser).
The information encoded in the cookies may include personal data such as an IP address, a username, a unique session identifier or an email address, but may also contain non-personal data such as language settings or information about the type of device a person is using to browse the website.
Cookies are used for different purposes such as monitoring browsing sessions, storing information on specific configurations of users accessing the server, promoting and selling customized products and services, and facilitating the use of online content.
Cookies differ from one another on the basis of their duration (session or permanent cookies) and the party using them (depending on whether they are installed by the site operator, acting as a ‘first party’, or by third parties). In this regard, it is possible to distinguish two macrocategories:
- Technical cookies, used for the sole purpose of “transmitting a communication over an electronic communications network, or to the extent strictly necessary for the provider of an information service explicitly requested by the contractor or user to provide such service” (see Article 122, paragraph 1, of the Personal Data Protection Code n. 196/2003, as amended by EU Regulation 679/2016).
These cookies may be installed on the user’s terminal without the user’s consent, on the basis of the need to provide the service requested by the user or the legitimate interest of the Data Controller to enable the proper functioning of the Site;
- Profiling cookies, used to link specific actions or recurring behavioral patterns in the use of the functions offered (patterns) to specific, identified or identifiable parties in order to group the various profiles within uniform clusters of various sizes, so that the Data Controller can modulate the provision of the service in an increasingly personalized manner beyond what is strictly necessary for the provision of the service, as well as send targeted advertising messages, i.e. in line with the preferences expressed by the user while browsing the web.
These cookies can be installed on the user’s terminal only with prior consent.
- Analytics cookies, used to assess the effectiveness of an information society service provided by a publisher, to design a website or to help measure its “traffic,” i.e., the number of visitors, including by geographic area, connection time or other characteristics.
These cookies can be installed on the user’s terminal only with prior consent.
- Social cookies, used to enable interaction and easy sharing of content on social networks and/or to enable the sending of targeted advertisements based on user preferences.
These cookies can be installed on the user’s terminal only with prior consent.
3. List of cookies in use on the site
(A) Technical cookies
The Site uses cookies for technical purposes in order to allow the Site to function properly and to recognise users who return to visit the Site. These cookies do not require the user’s prior consent to be installed and used.
The Site uses navigation or session cookies, by means of which normal navigation and use of the Site is ensured. They make it possible, for example, to make a purchase or authenticate oneself to access restricted areas. These cookies are necessary for a better use of the Site.
Although technical cookies do not require the user’s prior consent to be installed and used, they can still be managed by the user through the browser settings (as specified in the section “How to manage cookie settings” of the browser and in point 4 of this Cookie Policy). However, their deletion may affect the full enjoyment of the Site.
The technical cookies present on the Site are listed below. For each one, the Cookie ID, the type, a brief description of how it works and the retention period are indicated.
(B) Other types of cookies (profiling, analytics and social)
The Site also uses additional cookies for analytical and statistical purposes, in order to improve user interaction with the Site, including through access to social networks, and to customise the sending of information and communications of an advertising nature based on the interests expressed by the user (profiling).
For all information on third-party cookies and how to revoke consent to individual cookies, please refer to the respective privacy policy and the tool provided by the third party to revoke consent to individual cookies.
It is possible to revoke the consent given for third-party cookies (i.e. from companies that are part of the WebChoices platform of the Digital Advertising Alliance, including Facebook) installed on the user’s browser via the following link: https://optout.aboutads.info/?c=2&lang=EN.
To control user’s preferences and revoke the consent to the use of third-party cookies, the user can use the tool provided by “Your Online Choices”, available at the following link: www.youronlinechoices.com.
Alternatively, users can follow the instructions provided by their browser to change their preferences on the cookies used by the Site at any time.
The other cookies, other than technical cookies, used on the Site are listed below. For each one, the Cookie ID, the type, a brief description of how it works and the retention period are indicated.
(C) Other social functionalities (e.g., plugins)
In addition to the cookies mentioned above, the Website also incorporates plugins and/or buttons in order to allow easy sharing of content on the following social networks: Facebook, Instagram, Twitter and YouTube. If a user does not wish the social network to record data relating to their visit to the Website, they must log out of the social network account and delete the cookies that the social network has installed in the user’s browser.
For certain activities, the Data Controller and the social network operator may act as joint controllers within the meaning of Article 26 of the GDPR, specifically if the Data Controller determines jointly with the social network operator the purposes and means of processing through the collection and transmission of user data to the social network by means of a plugin installed on the Site. In these cases, the Data Controller shall comply with the contractual terms of the social network, which may include co-ownership agreements for the processing.
Finally, note that in any case joint control does not extend to processing carried out by social networks in relation to which the Company does not determine the purposes and means of processing (e.g. operations carried out by the social network after the User’s data have been disclosed by the Website).
With regard to the collection and use of information by social networks, please refer to their respective privacy policies:
4. How to manage cookies?
The first time you access the Website, a banner containing a simplified cookie policy will be displayed. By clicking on the “Accept all” button on the banner, you consent to the use of all cookies; by clicking the “Refuse all” button on the banner, you reject all cookies (except technical cookies for the installation of which consent is not required); by clicking “Personalise cookie choices” button you can select the cookies you wish to install.
If you do not wish to give consent, or wish to revoke consent, you can manage your preferences using the Cookie Centre accessible by clicking on the link contained in the cookie banner or in the “cookie settings” section in the footer of the Website.
In addition, cookies can be deactivated/activated or deleted at any time by using the settings of the web browser used by the user. The setting can be managed independently by the user in a specific and detailed manner by accessing the settings of their browser.
To do so, simply consult the information in the browser’s user manual or follow the directions below:
• Internet Explorer
Menu: Tools/Internet Options
Tab ‘Privacy’, then ‘Sites’: under Site Address enter the full address (URL) of the site whose privacy parameters the user wishes to customize:
To authorize the registration of cookies from the site in question on computer, click “Authorise”;
To prevent the registration of cookies from the site in question on computer, click “Block”.
• Safari
Preferences: Privacy tab and Configure Cookies
• Chrome
Click on the settings icon, located on the browser toolbar: Parameters; Click on View Advanced Parameters.
In the ‘Privacy’ section, click on Content Parameters.
In the “Cookies” section the user can change the following parameters: Delete cookies, Block cookies by default, Allow cookies by default, Define exceptions for cookies from certain websites or domains.
• Firefox
Click on Tools and then on Options.
Privacy Tab: under History Settings, select ‘use customised settings’.
Check the ‘accept cookies’ box and click on the exceptions to choose the websites that are to be authorised always or not with regard to the installation of cookies on the user’s terminal.
• Opera
Preferences > Advanced > Cookies
The cookie preferences allow the user to control the way Opera handles cookies. The default setting is to accept all cookies.
Users who have accepted the use of cookies by accessing the Site and passing the initial banner containing the short information notice may change the cookie setting at any time and decide to disable them.
5. Can cookies be deleted?
Yes, in this case too, the appropriate browser settings must be configured, following the instructions above (Art. 4).
6. Changes to the cookie policy
The Data Controller reserves the right to modify or simply update this Cookie Policy, in whole or in part, also as a result of any changes in the rules governing this matter and protecting user’s rights. Changes and updates to the Cookie Policy will be binding as soon as they are published. Users are therefore invited to access this section regularly to check its contents.
7. Contacts
The user can send an e-mail to privacy.roa@moncler.com if he/she has questions or information on the contents of this cookie policy.
1. Introduction
Welcome to the website https://www.moncler.com.
Industries S.p.A., part of the ‘Moncler Group’, provides the following information about the collection and processing of the user’s personal data. During the use of the site or its services (hereinafter, the “Website” and the “Services”), information and personal data concerning users of the Site are collected.
For this reason, in accordance with the provisions of the General Data Protection Regulation no. 2016/679 (“GDPR”) and applicable national legislation (together, “Privacy Legislation”), we have created this document (hereinafter “Privacy Policy”) for the purpose of describing what personal data we collect, the purposes and methods of its processing and the security measures used to protect it.
Pursuant to the GDPR, ‘processing’ is defined as any operation, including the mere collection and/or storage, of personal data of any natural person (hereinafter, the “Data Subject” or the “User”), ‘controller’ is defined as the natural or legal person who determines the purposes and means of the processing, and ‘personal data’ is defined as any information relating to a natural person, identified or identifiable even indirectly by reference to any other information.
2. Data Controller and Data Protection Officer
The Data Controller is Industries S.p.A., with registered office in Milan - 20144, via Stendhal, 47, VAT and Fiscal Code 04804070961 (hereinafter also “Moncler” or “Data Controller”).
The User can contact the Controller free of charge by writing to the e-mail address privacy.roa@moncler.com., or by sending a registered letter with acknowledgement of receipt to the registered office, as identified above.
Industries S.p.A. has appointed a Data Protection Officer (DPO), domiciled for the purpose at the offices of Industries S.p.A. and available at the following address: dpo@moncler.com.
3. Categories of personal data processed
The Data Controller will process the following categories of personal data (hereinafter collectively referred to as “Personal Data”):
3.1. Browsing data
During their normal operation, the computer systems used to operate the Website acquire some of the User’s Personal Data, the transmission of which is implicit in the use of Internet communication protocols.
This information is not collected for the purpose of identifying the User, but may lead his/her identification if, for example, it is combined with information held by a third party. This category of data includes the IP address and domain name of the computer, the URI (Uniform Resource Identifier) 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 reply, the numerical code indicating the status of the reply given by the server and other parameters relating to the operating system. We use this data for the sole purpose of obtaining anonymous statistical information on the use of the Website and to check it is working properly. The data collected is deleted immediately after processing. The data could be used to ascertain responsibility in the event of cybercrime committed to the detriment of the Services.
3.2. Registration information and further information provided by the User
Use of the Website does not require the creation of a personal account. However, to access certain pages reserved for registered users and, for example, to send us a request for information or feedback on the Services, the User must create a personal account and become a registered User. When creating an account, the User will be asked to enter certain Personal Data, such as (i) first and last name, (ii) e-mail address, (iii) date of birth, and to create a password.
In addition, personal data directly provided by the User when placing an order to purchase an item will be collected and processed, this consists of data collected by sending electronic mail, interacting with the functionality of the Website and requesting Services offered by the Website.
The Personal Data we collect and process for the purpose of order fulfilment include (i) first and last name, (ii) nationality, (iii) e-mail address, (iv) shipping address, (v) shipping and payment methods and, subject to consent, (vi) purchasing habits.
If the User wishes to use our online size suggestion service, we will collect Personal Data relating to his/her body measurements (e.g. height, weight, age).
If the User collects, processes and discloses information about third parties to us, he/she must do so in accordance with the provisions of the Privacy Policy and, therefore, the User must provide the third parties with prior notification of processing and, if necessary, obtain their free and express consent before processing.
4. Purpose of the processing and nature of data provision
Personal Data will be used exclusively for the following purposes:
(a) to create an account;
(b) to respond to and manage requests for information and/or User feedback, via the online form, the live chat available on the Site, the WhatsApp chat, by telephone on +61 1800 413 740 or by e-mail at client.service@moncler.com or privacy.roa@moncler.com.;
(c) to provide the services requested through the Website, including registration and subsequent updates and to manage the activities organized through the Website;
(d) to manage sales activities and to provide sales and after-sales services, such as administration, accounting, returns and guarantee management, customer relationship management;
(e) to ensure compliance with legal obligations, national and EU regulations (including anti-money laundering regulations), to prevent fraud and to exercise rights in legal proceedings;
(f) for direct marketing – with your previous consent, which is optional, Moncler will process your personal data for additional purposes like marketing activities, commercial or advertising communications, direct sales, market researches, by e-mail, (newsletter), phone, SMS, MMS, instant messaging;
(g) for profiling for marketing purposes –Moncler has realized a specific system composed by various applications and related infrastructure, called "Moncler Digital Data Architecture for Customer Profilation" (hereinafter also "Moncler Digital Data Architecture"), which collects, from different sources (i.e. your purchases instore, through Monclient App, from anti counterfeiting websites, from profiling cookies), and elaborates information related to preferences, purchase habits on purchases made by you worldwide even through other Moncler Group’s companies appointed as data processors for this purpose, in order to build individual profiles for the purposes of providing you, only with your previous content which is optional, with targeted communications by e-mail (newsletter), phone, SMS, MMS, instant messaging and traditional mail, or with a customized management of the relationship between Moncler and you;
(h) for online advertising and Social Media – in case of interaction with the Data Controller’s social media pages, if you granted your consent to the use of profiling cookie on the Website (which are mentioned in Section 10 below), Moncler shall process your personal data in order to show you marketing announcements and contents matching with your interests, in consideration of the preferences and of the purchase habits identified through cookie and/or other tracing systems of social media manager (like Meta) and/or after the analysis that social media carry out on their users. In particular, Moncler shall be able to show targeted marketing content through digital platforms in consideration of your interests or of your behavior and on the basis of all those information which could be collected through profiling activities carried out on the Website and shared with digital platforms, or using the instruments made available by social media;
(i) for aggregated analysis of strategic and business intelligence: through the Moncler Digital Data Architecture Moncler will also carry out aggregated analysis of strategic and business intelligence on the processed data and information, on the basis of legitimate interest, in consideration of entrepreneurial and market needs to conduct activities of general analysis and forecast, developing statistic elaborations and company’s strategic models, so improving products and services offered to its customers;
(j) to defend its own rights – Moncler will process personal data in order to protects its rights in judicial, administrative and extrajudicial proceedings and in any disputes arisen in relation to the Services;
(k) monitoring the quality and verifying the effectiveness of the assistance services offered by Moncler, managing any disputes and complaints eventually made by the User and managing customer relations, also by means of recording telephone calls with the Client Service.
The provision of the User’s Personal Data for purposes (a), (b) (c), (d), (e), (i), (j) and (k) is optional, but necessary in order to provide the Services requested. If the User refuses to provide such information, he/she will still be able to use the Site, but will not be able to access some of our Services reserved for registered users, purchase Moncler products and we will not be able to handle the User’s requests.
With specific reference to the purpose referred to in purpose (k), the User will be notified in advance of registration by a short information notice issued by a recorded voice at the beginning of the telephone call, with a reference to this full information notice.
Consent to the processing of Personal Data for the marketing and profiling purposes referred to in points (f), (g) and (h) is optional and refusal will have no consequences on the navigation of the Site and/or the purchase of Moncler products.
5. Legal basis for processing
The legal basis for the processing of the Personal Data referred to in Article 4 above is:
· with reference to points (a), (b), (c) and (d)
fulfilment of a contractual obligation, in particular the provision of Services requested by the User via the Site or, in the case of point (b), by WhatsApp chat or by telephone call or e-mail;
· with reference to point (e)
fulfilment of a legal obligation to which the Data Controller is subject in the course of its business;
· with reference to points (f), (g) and (h)
consent of the Data Subject, given by means of a specific and separately expressed expression of will, only after having read this Privacy Policy. The User may at any time specify the preferred method of contact from among those listed above and he/she may refuse to receive promotional communications through any or all of the contact methods.
In relation to the consent for letter (h), we make reference to the cookie policy (section 10); in such case the consent is granted through the specific banner which can be found when you access the Website and can be revoked at any time with the modalities specified in the same cookie control panel.
· with reference to point (i)
Moncler legitimate interest (section 6 (1) (f) GDPR) to verify and improve the quality of the offered services and the company processes efficiency;
· with reference to point (j)
Moncler legitimate interest to protect its rights (section 6 (1) (f) GDPR).
· with reference to point (k)
fulfilment of a contractual obligation, in particular the provision of the Services requested by the User through a phone call to the Client Service.
No new and specific data collection is required as Moncler will pursue this additional purpose, if necessary, by processing data collected for the above mentioned purposes.
6. Data processing and archiving methods
User’s Personal Data will be processed both in paper form and using electronic means and always in compliance with the security requirements of applicable legislation, with particular but not exclusive reference to art. 32 of the GDPR. Our security measures include contractual arrangements with any entity (e.g. service providers) in order to protect the security and confidentiality of the User’s Personal Data in accordance with the provisions of this Policy.
7. Period of use and storage of Personal Data
We will retain the User’s Personal Data until the purpose for their use is achieved according to our internal data retention policy.
For the personal data as of Section 5 and 6 above, letter (a), (b), (c) and (d) we have a retention period of 10 years from the time of initial collection for User’s Personal Data that is processed for our invoicing and accounting purposes, save for the circumstances in which national applicable law may provide for different retention requirements. In principle, we will promptly destroy User’s Personal Data in our possession once we achieve the purpose of collection and use of the Personal Data.
However, we will retain the following categories of Personal Data for the duration indicated below:
- User registered data: this data will be stored for as long as the account is active and for the subsequent 10 years from the last purchase, for administrative purposes.;
- payment data: these data will be retained until such time as the payment has been confirmed and the administrative and accounting formalities relating hereto have been completed and for the subsequent 10 years from the last purchase, for administrative purposes.
- data collected in connection with the use of Services offered on the Website (e.g. “pick-up in store”, “return in store”, “click from store”, “click and reserve”): such data is stored until the service has been fully performed and for the subsequent 10 years from the last purchase, for administrative purposes.
- data related to User requests to our Customer Service department: relevant data will be retained until the request is resolved.
For the personal data as of Section 5 and 6 above, letter (f), (g) and (h) the Personal Data processed for marketing and/or profiling purposes will be kept a period of 7 years as per the authorization obtained from the Italian Data Protection Authority, issued on May 25, 2018, in favor of Industries S.p.A. After this retention period, the data will be automatically deleted or permanently and irreversibly anonymized.
For the data retention period of the cookie we make reference to what set out in deep in cookie policy
For the personal data as of Section 5 and 6 above, letter (i) (j), the personal data processed for analysis purposes will be retained for the time set out in relation to the main purposes for which they have been collected, save for the objection right, and for the time necessary in order to protect the specific right (sub. j).
7.1. Procedure and modalities for the storage and destruction of Personal Data
In principle, we will promptly destroy User’s Personal Data in our possession once we achieve the purpose of collection and use of his/her Personal Data.
8. Scope of communication
8.1. Internal and external communication of Personal Data
Personal Data is accessible to duly authorized Moncler personnel (e.g., Digital, CRM, Retail, IT) as necessary and is disclosed to third parties in the following cases: (i) when disclosure is required by laws and regulations applicable to legitimate third party recipients, such as authorities and public bodies for their respective institutional purposes, e.g. anti-money laundering legislation, court authorities; (ii) in the event of extraordinary transactions (e.g. mergers, acquisitions, sale of business, etc.); (iii) in charge of fraud prevention services.
Personal Data is also shared with our service providers, e.g. for services of a technical and organizational nature that are necessary for the purposes referred to in Article 4, such as independent partners, including associates, shipping companies, marketing, payment management, etc, the list of which could be communicated to the Data Subject upon request. We provide such parties only with the data necessary to perform the agreed services and they act as data processors in accordance with art. 28 GDPR, based on instructions received from Industries S.p.A.
Industries S.p.A. declares that it does not disclose the User’s Personal Data to third parties for marketing or profiling purposes.
However, with reference to profiling, marketing and customer relationship management (to provide the User with the same level of service worldwide), other companies in the Moncler Group may access User’s Personal Data as data processors in accordance with art. 28 GDPR, based on instructions received from Industries S.p.A.
8.2. Data transfer abroad
For the performance of certain processing of User’s Personal Data, Moncler may communicate such data to external parties located in countries that do not belong to the European Union (EU) or the European Economic Area (EEA) (hereinafter “Third Countries”).
In particular, Moncler informs the User that his/her Personal Data may be transferred to Third Countries, the list of which will be updated from time to time and available upon request by the Data Subject. The lawfulness of such transfer is in any case guaranteed through the mechanisms envisaged by art. 46 of the GDPR, since Moncler has executed the Standard Contractual Clauses approved by the European Commission (supplemented by additional technical/organizational/legal measures) or, as applicable, due to the existence of an adequacy decision pursuant to art. 45 of the GDPR issued by the European Commission.
These external parties will process User’s Personal Data as independent data controllers or as data processors, regularly appointed by Moncler in accordance with the Privacy Legislation regulating data protection and depending on their respective role in relation to the processing.
9. Rights of the Data Subject
As a Data Subject, the User may at any time exercise the rights recognized by the Privacy Policy regarding the specific processing of his/her personal data. If the User is not of the legal age required by law, the legal guardians will also enjoy the rights described below.
Below is a general description of the rights and how to exercise them:
- when the User disputes the accuracy of the Personal Data for the period necessary for Moncler to verify its accuracy;
- when the processing is unlawful, but the User objects to the deletion of his/her Personal Data;
- when, although the Personal Data is no longer necessary to Moncler for the purpose of the processing, the User needs it to ascertain, exercise or defend his/her rights in Court;
- when the User objects to the processing, pending verification of whether Industries S.p.A. has legitimate reasons for continuing to process the Personal Data;
National laws may provide for additional data subjects rights. For additional information please contact us at the contact details indicated below.
To exercise the rights described above:
If the User believes that Personal Data has not been processed correctly, he/she may lodge a complaint with the local data protection authority.
To obtain the list of our external data processors, of the third parties with whom Moncler share User’s Personal Data please contact the Data Controller through the modalities set forth above.
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