1. Scope and information that this Online Privacy Notice covers
This Online Privacy and Cookie Notice (this “Privacy Notice”) applies only to Personal Information (defined below) collected on our websites, mobile applications, or cloud-based services and communication platforms with a link to this Privacy Notice (collectively, the “Site”). This Privacy Notice includes information on how we collect, use, share, and otherwise process Personal Information since this Privacy Notice was posted. References to “Personal Information” in this Privacy Notice means information that identifies or can reasonably identify users of the Site (“you”) personally.
Summary of Key Points
Collection
We generally collect Personal Information that you provide to us. Additionally, the computer systems used to operate the Website may acquire some of your Personal Information.
Use
We generally use Personal Information to collect anonymous statistical information on the use of the Website and to ensure it is working properly. The data collected is deleted immediately after processing. Further information about the use of your Personal Information in support of our business activities is available below.
Sharing
We only process and share your Personal Information to the extent reasonably necessary to fulfill your requests and meet our legitimate business and legal objectives. Personal Information is accessible to our duly authorized personnel 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; and (ii) disclosure to third parties in the event of extraordinary transactions. Personal Information is also shared with our service providers. We provide such parties only with the data necessary to perform the agreed services. Further information about the use, processing, and disclosure of your Personal Information is available below.
Security
Our security measures include contractual arrangements with any contractor (e.g. service providers) or other party to protect the security and confidentiality of your Personal Information, prevent unauthorized access or disclosure of Personal Information in our custody or control, and maintain data accuracy in accordance with the provisions of our Privacy Policy.
Data Transfers Abroad
Your Personal Information may be transferred outside of your home country to third party recipients established within the EU, and to third party recipients and countries outside the EU, which may not guarantee the same level of data protection as the EU. If you are located in a jurisdiction that does not consider the outside country to provide an adequate level of protection, cross-border transfer of your information is necessary for the conclusion or performance of a transaction that you requested, and for the establishment, exercise, an defense of legal claims. However, you are advised that such transfer to third party countries will always be in accordance with the provisions of the Privacy Policy. Further information about the transfer of your Personal Information abroad is available below.
Data Retention
Depending on the program or service, we will retain your Personal Information only for the period necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by a law or regulation that applies to us or the data retention for the program or service.
Children
Persons under the age of 16 are ineligible to use any services on our Site.
Changes
We may amend this Privacy and Cookie Policy at any time. If we make any material change in how we collect, use, disclose, or otherwise process Personal Information, we will prominently post an updated Privacy and Cookie Policy on our Website.
Contact Us
Moncler USA Inc. can be contacted by writing to privacy@moncler.us
Industries S.p.A. can be contacted by writing to Industries S.p.A., via Stendhal n. 47, 20144 - Milan (MI), Italy or privacy@moncler.com or dpo@moncler.com.
2. CONTACT INFORMATION FOR DATA CONTROLLERS AND THEIR RESPECTIVE DATA PROTECTION OFFICERS
Moncler USA Inc. and Industries S.p.A., Moncler USA’s parent company act as independent data controllers.
As an independent data controller, Moncler USA Inc. will process your Personal Information in order to manage online sales activity (e.g. managing orders and payments), as well as for “pick-up in store”, “return in store”, “click from store” and “click and reserve” services.
· Contact: Moncler USA Inc. can be contacted by writing to privacy@moncler.us
As an independent data controller, Industries S.p.A. will process your Personal Information in order to carry out marketing activities (e.g. newsletters) as well as profiling.
· Contact: Industries S.p.A. can be contacted by writing to Industries S.p.A., via Stendhal n. 47, 20144 - Milan (MI), Italy or privacy@moncler.us or dpo@moncler.com.
3. COLLECTION OF DATA AND THE PURPOSES OF DATA PROCESSING
Registration and other information provided
You are not required to create a personal account. For public areas of our Site, we generally collect and process only Personal Information you voluntarily provide to us. We don’t require you to give us Personal Information to access certain public areas of our Site. This is true unless you live in a jurisdiction that defines Personal Information to include network identifiers like your Internet Protocol addresses. For some secure areas of our Site, however, we require you to provide Personal Information, including your login credentials. We also collect your Personal Information on the Site to perform services on our Site, enhance the services we offer you, maintain and improve the Site, to secure you and our Site, comply with legal obligations, and inform you about other services and products that may be available through us, our affiliated companies, and our marketing partners.
If you choose not to provide us with the Personal Information that we legitimately require, we may be unable to provide you with the information or services you have requested. Public areas of our Sites ask for Personal Information from you when you engage in the following activities:
Personal Information may include any or all of the following:
1. First name and surname;
2. Postal or billing address;
3. E-mail address;
4. Date of birth;
5. Telephone or mobile number;
6. Location via IP address;
7. Device being used (for our mobile site);
8. Previous login history and purchase history with our Site; and
9. Other relevant data, including any information you provide when contacting us.
Even if you do not send us any Personal Information, we may collect certain non-personal information about how you use our Site. This non-personal information cannot reasonably identify you, and is used for statistical purposes.
Information Collected Through Technology
We may also obtain information in other ways through technology. Some of this information may be linked to you personally. We process this information to help our Sites function correctly, and better understand the needs of our customers.
Device Information. Depending on the permissions you’ve granted and other factors, we may receive information about your location and your mobile device, including a unique identifier for your device. Examples of the device information we collect include:
Most mobile devices allow you to turn off location services, and we encourage you to contact your device manufacturer for detailed instructions on how to do that.
Purpose of the processing
We do not share your Personal Information with unaffiliated third parties solely for their own direct marketing purposes. We will not sell your Personal Information. Whatever the purpose may be – whether we share with service providers or other external entities – we only process and share your Personal Information to the extent reasonably necessary to fulfill your requests and meet our legitimate business and legal objectives.
Providing the above registration information is necessary in order to create an account and also:
· to respond to and manage questions, complaints, reviews of our services, requests for information, and/or user feedback;
· to provide the services requested through the Website, including registration and subsequent updates and to manage the activities organized through the Website;
· to carry out statistical analysis and surveys;
· to manage sales activities; and
· to provide sales and after-sales services, such as administration, accounting, returns and guarantee management, fraud prevention, customer relationship management, including compliance with legal obligations, regulations and EU regulations (including anti-money laundering regulations) and to exercise rights in legal proceedings
Any refusal by you to provide this information would still allow you to use the Website, but would prevent you from using some of our Services reserved for registered users.
In addition, your Personal Information must be processed in order to fulfill the contractual relationship arising from the purchase of Moncler products. You are free to disclose your data to us or not, but in the absence of the requested data you will not be able to purchase Moncler products and it will not be possible to handle your requests.
Further purposes of the processing
If we receive your consent, we will use your Personal Information for other purposes such as commercial or advertising communications, direct sales, in-store sales support worldwide through email (newsletter), telephone, SMS/MMS, or other marketing related communications. You may, at any time, indicate your preferred means of contact from among those listed above and you may refuse the receipt of promotional communication by any or all of these means of contact.
With your consent, which is optional, Moncler collects information about your preferences, habits and lifestyle as well as details of purchases made in order to use these to create group and individual profiles (“profiling”) and to send you personalized communications. Personalized communication may be sent by email (newsletter), phone, SMS, MMS, chat, instant messaging, social networking and traditional mail. You may at any time indicate your preferred means of contact from among those listed above and you may refuse the receipt of promotional communication by any or all of these means of contact.
Consent for the above marketing and profiling purposes is optional and refusal will not have any consequences. Data may be provided by you on registration at our points of sale by means of paper and/or electronic forms, acquired during visits to our stores belonging to the Moncler Group or through interaction with websites, internet applications and mobile applications belonging to the Moncler Group.
Legal grounds for the collection, use, sharing and other processing of Personal Information
Certain jurisdictions require the identification of the legal grounds for the collection, use, sharing, and other processing of Personal Information. We rely on the following legal grounds for the collection, use, sharing, and processing of Personal Information as described in this Privacy and Cookie Policy:
· Necessary to provide information or otherwise carry out the performance of a contract with you as an individual;
Information collected through cookies and other technologies
Cookies are small files sent by websites that you visit and that are stored on the device you use to access those websites. When users visit the same site again, your browser reads the cookies stored on your device and sends the information back to the site that originally created the cookies. Our site also uses different types of cookies and other technologies to read and store information on the user’s device. We do not use cookies that are able to launch programs on your devices or send viruses to them, or that allow us to control your devices.
On the Website you may also find social buttons/widgets, in other words those distinctive “buttons” showing social network icons like Facebook, Instagram and Twitter. These buttons allow users who are browsing the Website to share and interact with social networks with a simple “click”.
Cookies for our Services generally fall into the following categories:
Technical Cookies: Technical cookies are necessary for the functioning of the Website, including the provision of the Services offered by the Website. This category of cookies includes analytics, session and functionality cookies, used by the owner to, for example, collect information, in aggregate form, about the number of users and how they use the Website or to save your browsing preferences, such as the language. This category of cookies does not require the users consent.
· Our Own and Third Party Profiling Cookies: Our own and third party profiling cookies are designed to create user profiles and used to send and display advertising messages in line with the preferences expressed by users during their browsing. This category of cookies always requires the user’s optional consent.
The above cookies may be:
· temporary, when they are automatically deleted at the end of the connection;
· permanent, when they remain on the user’s hard drive, unless the user deletes them;
· first party, when they are issued and managed directly by the Website administrator;
· third party, when they are managed by a domain other than the one visited by the user.
While the use of technical cookies does not require the user’s consent, the use of profiling cookies always requires the user’s optional consent and the user can choose which profiling cookies to consent to. Cookies can be managed and disabled using the browser settings (e.g. Internet Explorer, Google Chrome, Safari, Firefox). Once on the site, the user will be able to access the “cookie selection” area and view the list of third party companies that place cookies on our site; check the presence and activity status of the installed cookie (“Status”) and selectively manage your consent (“On/Off”). Expanding the entry (Info) for each company will provide more information about the company and will link to the specific privacy and cookie policy.
4. SECURITY
The security and confidentiality of your Personal Information matters to us. Our security measures include contractual arrangements with any contractor (e.g. service providers) or other party in order to protect the security and confidentiality of your Personal Information, prevent unauthorized access or disclosure of Personal Information in our custody or control, and maintain data accuracy in accordance with the provisions of our Privacy Policy.
5. METHODS OF DATA PROCESSING AND DATA STORAGE
Your Personal Information will be processed both in paper form and using electronic means and always in compliance with the security requirements of applicable legislation. Personal Information
Your Personal Information is stored in compliance with the following terms and criteria:
1. Data collected to conclude and execute agreements for the purchase of products on the Website: until the administrative and accounting formalities have been completed. Billing information will be retained for ten years from the date of the original invoice;
2. Registered user data: this data will be stored for as long as the account is active. Even after the account is closed, we will retain your information if it is necessary to do so in order to comply with legal or regulatory obligations, to protect our rights, to prevent fraud, or to comply with this Privacy Policy;
3. Data relating to payment: until such time as the payment has been confirmed and the administrative and accounting formalities relating thereto have been completed, after the expiry of the right of withdrawal and after the deadline for contesting the payment;
4. 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;
5. Data related to user requests to our Client Service department: relevant data will be retained until your request is resolved;
6. If you have consented to your Personal Information being processed, the data relating to your purchases will be kept for marketing and profiling purposes for a period of seven (7) years, after which time the data will be automatically deleted or permanently and irreversibly anonymized.
In any case, for technical reasons, the termination of the processing and the subsequent cancellation or irreversible anonymization of the related Personal Information will be final within thirty (30) days of the terms indicated above.
6. SCOPE OF DISCLOSURE
Internal and external communication of Personal Information
Sale of the Businesses. If we sell all or part of our business, Personal Information may be transferred to the purchaser in connection with that transaction. We will use reasonable efforts to include contractual provisions that require the purchaser to treat your Personal Information consistent with the terms of this Privacy Notice.
Other Disclosures. We may otherwise disclose Personal Information as permitted or required by law, when we believe in good faith it is necessary for safety purposes, required for legal reporting, or to protect our legal rights or enforce our Site’s terms and conditions or any applicable rules, or to protect the rights of others. We may also disclose Personal Information to our auditors, legal advisors, or to respond to a subpoena. We may also aggregate information that we gather about you (e.g., online sales, traffic patterns) and provide these statistics to others in aggregate form.
Any access to your Personal Information is restricted to those individuals who have a need to receive or access this data in order to fulfill their job responsibilities. We may also disclose your Personal Information as required or permitted by applicable law to governmental authorities, courts, external advisors, and similar third parties.
Finally, for the purposes of profiling, marketing and customer relationship management (to provide you with the same level of service worldwide), other companies in the Moncler Group may access your Personal Information as data processors, based on instructions received from Moncler.
Data transfer abroad
Your Personal Information may be transferred outside of your home country to third party recipients established within the EU, and to third party countries, not belonging to the EU, which do not guarantee the same level of data protection as the EU. If you are located in a jurisdiction that does not consider the outside country to provide an adequate level of protection as the EU, cross-border transfer of your information is necessary for the conclusion or performance of a transaction that you requested, and for the establishment, exercise, an defense of legal claims. However, you are advised that such transfer to third party countries will always be in accordance with the provisions of the Privacy Policy, i.e. by obtaining your consent, when necessary, or by adopting any other measure necessary to ensure the security of the data being transferred. To the extent permitted by local law, your use of this Website or provision of any Personal Information constitutes, where legally permitted, your consent to the cross-border transfer of Personal Information and other activities identified in this Privacy and Cookie Policy.
7. RIGHTS OF THE DATA SUBJECT
As a data subject, you may at any time exercise the rights under applicable Privacy Legislation and as acknowledged by the Privacy Policy with regard to the specific processing of your Personal Information. Please note that these rights might be limited under the applicable national data protection law.
Below is a general description of them and how to exercise them:
8. INFORMATION FOR US RESIDENTS: CALIFORNIA AND COLORADO
Under the California Consumer Privacy Act ("CCPA"), as amended by the Consumer Privacy Rights Act (“CPRA”) (collectively, "California Privacy Law") and the Colorado Privacy Act (“CPA”), (collectively, “US Privacy Law”), we provide specific disclosures about how we use and disclose your information. If you are a California or Colorado resident, please note the following about how we have collected, used, disclosed and otherwise processed your personal information over the past 12 months, as well as additional rights you may have with respect to your personal information. This Notice does not reflect our processing of California or Colorado residents' personal information where an exception under California or Colorado law applies.
Personal Information. Consistent with the "Collection of Data and the Purposes of Data Processing" section above, we may collect certain categories of information ("Personal Information") about California and Colorado residents, such as:
Certain Personal Information that we collect about you may be considered Sensitive Personal Information within the meaning of US Privacy Law, including: precise geolocation information (for providing services). We only use and disclose Sensitive Personal Information as necessary in connection with the performance of services and the provision of goods, compliance with federal, state, or local laws, and as otherwise permitted by US Privacy Law.
Sources of Personal Information. Consistent with the "Collection of Data and the Purposes of Data Processing" section above, we may collect Personal Information from you when you interact with our Site.
Uses and Disclosures of Personal Information. We use and disclose Personal Information as described in the "Purpose of Processing," "Further Purposes of Processing" and “Scope of Disclosure” sections above.
Disclosures to Third-Parties.
· Disclosure of Personal Information for Business Purposes. We disclose the following categories of personal data for business purposes: Identifiers, Commercial Information, Internet or Other Electronic Network Activity, Geolocation Data, Audio Information, and Other Information to web hosting, payment processing, business analytics, customer service, and business partners.
· Disclosure of Personal Information for Commercial Purposes. We disclose the following categories of personal data for commercial purposes: Identifiers, specifically, preferences and interests on our Site, collected via Cookies to advertising technology providers and, in limited instances, email addresses in hashed format, to social media companies, marketing, and survey service providers. These are sharing activities that may be considered a sale under California Privacy Law or targeted advertising under the CPA.
Right to Opt-out of Sale, Sharing, or Targeted Advertising. In addition to the rights stated below, California and Colorado residents have the right to opt-out of the selling, sharing, or targeted advertising of their Personal Information, as such terms are defined under US Privacy Law. To exercise this right, please click here [https://www.moncler.com/en-us/client-service/contact/]. In addition, we have configured our cookie management tool to honor opt-out preference signals sent by Global Privacy Control ("GPC") within the browser. Please note that due to technical limitations, the GPC signal is only honored within the particular browser. Beyond GPC, we do not currently respond to web browser “do not track” signals or other mechanisms that indicate your preference for not having information collected over time and across different Web sites or digital apps following your visit to one of our Sites.
Data Retention. We keep your Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with you; (ii) as required by a legal obligation to which we are subject to; or (iii) as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations).We may remove Personal Information for inactive accounts from our database, subject to any applicable legal or regulatory obligations. Furthermore, we may delete Personal Information from our database at any time and without providing any reason.
US Privacy Law Rights. You may have the right to access, correct or delete your Personal Information, subject to certain exceptions. Specifically, you have the right to request:
1. Deletion of your Personal Information;
2. Correction of your inaccurate Personal Information;
3. Know/access the categories of Personal Information that we collected about you, including the specific pieces of Personal Information;
4. Categories of Personal Information disclosed for a business purpose; and
5. Specific to California residents, information about the categories of Personal Information about you that we have shared (as such term is defined under California Privacy Law) and the categories of third parties to whom the Personal Information was shared.
In some instances, we may decline to honor your request. For example, we may decline to honor your request if we cannot verify your identity or confirm that the Personal Information that we maintain relates to you. In other instances, we may decline to honor your request where an exception under US Privacy Law applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer.
If you are a California or Colorado resident, to make a request described above relating to Personal Information that we collected about you that is not subject to an exception under US Privacy Law, you may:
Authorized representative. You can designate an authorized agent to make a request under US Privacy Law on your behalf in certain circumstances. If you use an authorized agent for this purpose, we may ask you to verify your identity or that you provided the authorized agent signed permission to submit a request on your behalf. In California, if you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with California law.
You will not be penalized for exercising your rights to your Personal Information. And, if we deny your request, we will explain why.
Shine the Light Law. California residents are entitled once per year to request and obtain certain information regarding our disclosure, if any, of your personally identifiable information to third parties for their direct marketing purposes during the immediately prior calendar year. To make such a request, please send an email to privacy@moncler.us with your full name, email address, and postal address in your message. In response to your request, we will provide you with a notice describing the cost-free means to opt-out of our sharing your personally identifiable information with third parties with whom we do not share the same brand name, if the third party will use it for their direct marketing purposes.
Do-not-track (“DNT“) signals sent via browsers
Given the divergent practices of organizations that offer browsers and the lack of a standard in the marketplace, we generally do not respond to DNT signals at this time.
9. CHILDREN
We do not knowingly collect Personal Information from children under the age of 16. If a child under the age of 16 has provided us with Personal Information, we ask that a parent or guardian contact us at the contact details provided above.
10. COMPLAINTS
If you believe that your Personal Information has not been correctly processed, you may contact us using the contact information noted in Section 2 above. For Colorado residents, you may appeal a decision we make regarding a rights request by emailing us at [EMAIL ADDRESS].
You also have the right to lodge a complaint with a competent data protection supervisory authority. To exercise your rights, please contact us as set out below.
· call the toll-free number +1(888)320-9162 from Monday to Friday from 10 a.m. to 7 p.m., excluding public holidays;
· write to Client Service by selecting the “privacy” topic in the relevant form in the “Contact us” section of the Website; or
· contact Moncler USA Inc. and Moncler directly at the addresses indicated in Section 2 above.
11. CHANGES OR OTHER UPDATES TO THIS PRIVACY AND COOKIE POLICY
We may amend this Privacy and Cookie Policy at any time. If we make any material change in how we collect, use, disclose, or otherwise process Personal Information, we will prominently post an updated Privacy and Cookie Policy on our Website. Any changes to this Privacy and Cookie Policy will be effective immediately upon posting of the updated Privacy and Cookie Policy or as otherwise required by applicable law. Where required to do so by law, we will seek your prior consent to any material changes we make to this Privacy and Cookie Policy.
The user’s prior consent is not required for the installation of technical cookies. In any case, all browsers allow changing cookie settings.
(B) Other types of cookies (profiling, analytics, social)
Below we list the name, the relevant third party if the cookie is not first party, the purpose, and the duration for each cookie used by the Website that does not fall into the category of technical cookies.
For all information relating to third-party cookies and how to opt out of individual cookies, see the respective policies and the tool provided by the third party to opt out of the individual cookie.
Using the following link it is possible to opt out of third-party cookies (i.e. companies that are members of the WebChoices tool of the Digital Advertising Alliance, including Facebook) installed on the user’s browser: https://optout.aboutads.info/?c=2&lang=EN
The following tool provided by Your Online Choices can also be used to control your preferences by opting out of third-party cookies: https://www.youronlinechoices.com/
(A) Other social functions (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, 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 Company and social networks may also act as joint controllers pursuant to art. 26 of the GDPR, specifically when the Company jointly determines the purposes and means of the processing with the social network through the collection and transmission of the user's data to the social network via a plugin. In such cases the Company adheres to the contractual terms of the social network, which may include joint controller agreements.
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.
‒ Facebook (cookie policy link)
‒ Instagram (cookie policy link)
‒ Twitter (cookie policy link)
‒ YouTube (cookie policy link)
4.Methods of data processing and data storage
Your 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 your personal data in accordance with the provisions of this Policy.
Period of Use and Retention of Personal Data
We will retain your personal data until the purpose for their use is achieved according to our internal data retention policy. In particular, we hereby specify that we have a general retention period of 10 years from the time of initial collection for your 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 your personal data in our possession once we achieve the purpose of collection and use of your personal data. However, the following categories of your personal data will be retained by us for the duration of the periods specified below.
Registered user data: this data will be stored for as long as the account is active to the extent that is strictly necessary to provide the user with the services. Even after the account is closed, we will retain your information if it is necessary to do so in order to comply with legal or regulatory obligations, to protect our rights, to prevent fraud, or to comply with this Policy.
Data relating to payment: until such time as the payment has been confirmed and the administrative and accounting formalities relating thereto have been completed, after the expiry of the right of withdrawal and after the deadline for contesting the payment.
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.
data related to user requests to our Customer Service department: relevant data will be retained until your request is resolved.
With particular reference to the legal protection of our rights, we hereby specify that we keep data in accordance with any restrictions imposed by local regulations.
If you have consented to your personal data being processed for marketing and profiling purposes, the data relating to your purchases 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., which is the entity in charge of such processing operations. After this retention period, the data will be automatically deleted or permanently
In any case, for technical reasons, the termination of the processing and the subsequent cancellation or irreversible anonymization of the related personal data will be final within thirty days of the terms indicated above.
Procedure and Method for Destruction of Personal Data
In principle, we will promptly destroy your personal data in our possession once we achieve the purpose of collection and use of your personal data.
The process and means of destroying your personal data are as follows.
A. Procedure
Your personal data will be transferred to a separate database (or separate document file for paper documents) and destroyed after storage for a certain period pursuant to our internal policy or applicable laws and regulations (please refer to the provisions on retention and use period). Such personal data will not be used for any purpose other than the purpose permitted under the applicable laws and regulations.
B. Method
Paper documents containing personal data will be shredded through the use of document shredder or incinerated.
The personal data stored in electronic file format will be deleted by using technical means that will not allow data recovery.
5.Scope of disclosure
5.1 Internal and external communication of personal data
Personal data is accessible to our duly authorized personnel (e.g., Digital, CRM, Retail, IT personnel) 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) disclosure to third parties in the event of extraordinary transactions (e.g. mergers, acquisitions, sale of business, etc.); (iii) communication to the third party 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 indicated above, such as independent partners, including associates, shipping companies, marketing, payment management, etc, the list of which could be communicated 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. It is expressly stated that Industries does not disclose your personal data to third parties for marketing or profiling purposes.
Finally, for the purposes of profiling, marketing and customer relationship management (to provide you with the same level of service worldwide), other companies in the Moncler Group may access your personal data as data processors in accordance with art. 28 GDPR, based on instructions received from Industries.
5.2 Data transfer abroad
For the performance of certain processing of your 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 referred to as "Third Countries”).
In particular, Moncler informs you that your Personal Data may be transferred to Third Countries, the list of which will be updated from time to time and/or available upon request. 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 your Personal Data as independent data controllers or as data processors, regularly appointed by Moncler in accordance with the legislation regulating data protection (depending on the role they have in relation to the processing).
6.Rights of the data subject
As a data subject, you may at any time exercise the rights acknowledged by the Privacy Policy with regard to the specific processing of your personal data. If you are under the legal age of indicated by the law, your legal guardians will also have the rights described below.
Below is a general description of them and how to exercise them:
§ When you challenge the accuracy of your personal data for the period necessary for Moncler to verify the accuracy of such data.
§ When the processing is unlawful, but you object to the deletion of your data.
§ When, although your data is no longer needed by Moncler for processing purposes, you need it to ascertain, exercise or defend your rights in legal proceedings.
§ When you object to the processing, pending verification of whether the Moncler Local Company or Industries have legitimate grounds to continue processing the data.
National laws may provide for additional data subjects rights. For additional information you can contact us at the contact details indicated below.
To exercise the rights described above, you can:
If you believe that your personal data has not been processed correctly, you may lodge a complaint with the local supervisory authority.
To obtain the list of our external data processors, of the third parties with whom Moncler share your personal data please contact the controllers through the modalities set forth above.
Disclosures for Business Purposes. California residents also have the right to know the categories of personal data we have disclosed for "business purposes", as such term is defined under the California Consumer Privacy Act. We may have disclosed certain categories of personal data for business purposes described under the sections above titled (i) Browsing data, (ii) Registration information and further information provided by the user, and (iii) Information collected through cookies and other technologies, including registered user data, data relating to payments, and data related to customer requests.
6.1 Do Not Sell My Information
In addition to the above, California residents also have the right to opt-out of the "sale" of their personal data, as such term is defined under the California Consumer Privacy Act. To opt-out of the "sale" of your personal data, please visit our "Do Not Sell My Personal Data" web page. California residents also have the right to know the categories of personal data we have sold. We may have shared your profiling and marketing information, and contact details to the Moncler Group and ad tech providers to send promotional materials, which could be considered a "sale" under California law.
To ensure that the data of users of the Website is not compromised or misused by third parties, prior to accepting your request to exercise any of the rights listed above, you may be asked to provide certain information to confirm your identity.
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