PRIVACY POLICY

(updated 25 May 2018)

Introduction
Haeres Equita srl a Socio Unico ​​is committed to protecting the user's privacy. This privacy policy ("Privacy Policy") applies to the website www.borsalino.com ("Site") operated by Haeres Equita srl a Socio Unico. In compliance with the applicable privacy law, the Privacy Policy describes the methods for collecting and using data through the Site on the part of Haeres Equita srl a Socio Unico, which data are collected, the scope of communication of the data to third parties, the measures taken to protect the data, the privacy rights of the user and the ways in which the user can exercise his rights in matters of privacy. The Privacy Policy does not apply to data that Haeres Equita srl a Socio Unico collects offline or through sources other than the Site.

Ownership and management of the user's personal information
Haeres Equita srl a Socio Unico, based in Corso Matteotti 41 in Valenza (Alessandria), is the owner of the processing of personal data for the management of the Site, for purposes related to purchases and for marketing and profiling purposes, in compliance with applicable law.
The person in charge of the treatment by Haeres Equita srl a Socio Unico for the aforementioned purposes is the CRM Manager pro tempore, domiciled for the position at the headquarters of the owner indicated above.

Nature and types of data processed
Browsing the site by the user usually involves only the collection of so-called navigation data, which are the data necessary for the technical functioning of the Site and the Internet communication protocols. The navigation data includes, for example: the IP addresses or domain names of the computers used to visit the Site and other parameters related to the operating system. Haeres Equita srl a Socio Unico also collects data such as the number of visits and the time spent on the Site for statistical purposes to allow the proper functioning of the Site and improve its functionality. By their very nature, navigation data may allow identification of users through associations with other data held by third parties. Haeres Equita srl a Socio Unico does not collect browsing data to identify users. The navigation data may be used by Haeres Equita srl a Socio Unico to ascertain any responsibility concerning computer crimes committed against the Site or through use of the Site. Apart from this eventuality, the navigation data are stored by Haeres Equita srl a Socio Unico only temporarily and in compliance with applicable law.

Haeres Equita srl a Socio Unico collects and uses the personal data provided voluntarily by the user when interacting with the functionality of the Site and required for the services offered on the Site, for example in the case of registration on the Site, for our newsletters, purchase of products, participation in initiatives undertaken through the Site, requests for information or sending communications. In compliance with the applicable privacy law, Haeres Equita srl a Socio Unico may also process the user's personal data collected from third parties in the course of its business activities. Only with the express consent of the user may Haeres Equita srl a Socio Unico process the user's personal data for survey purposes and market research, profiling, marketing and for promotional purposes. For further information on the purposes of processing, please refer to the following section: "Purposes and methods of processing personal data". The personal data that Haeres Equita srl a Socio Unico collects and processes may include: name, gender, place and date of birth, nationality, identification codes such as a social security number, contact information such as the address, telephone number, e-mail and other information on an optional basis. When personal data are collected on the Site, a specific privacy policy is published and the user's consent is required, in compliance with the applicable privacy law. If the user provides personal data of third parties (for example, in the case of use of the 'send to a friend' feature that allows the user to send information on the Site and our products and initiatives to a third party), the user must ensure that the communication and subsequent use of the data for the specific purposes is compliant with the applicable privacy law, for which the user can provide personal data of a third party only after having duly informed him and having obtained his consent to the processing, when required according to the law.

Place of storage of personal data
Personal data is stored and processed through computer systems owned and operated by Haeres Equita srl a Socio Unico or by third party technical service providers on behalf of Haeres Equita srl a Socio Unico; for more details please refer to the section below " Scope of personal data communication and transfer abroad". The data is processed exclusively by specifically authorized personnel, including personnel assigned to carry out extraordinary maintenance operations.

Cookies
Cookies are small files stored on the hard disk of the user's computer. The Site uses cookies and to obtain more information about cookies and how to disable their use, we suggest that you read our Cookie Policy. The Site may contain links to other sites. We have no access or control over cookies, web bacon and other tracking technologies used on third party sites to which the user may gain access from the Site, nor on availability or any content and material that is published or obtained through such sites and on the relative modalities of processing of personal data, and expressly disclaim any related liability. The user should check the privacy policy of third party sites accessed by the site in order to understand the conditions applicable to the processing of data, as the present Privacy Policy applies only to the Site.

Purposes and methods of processing personal data
In addition to the data collected passively, data actively supplied by the user to the Site when interacting with the Site, its functionalities and services are collected and used. Haeres Equita srl a Socio Unico processes your personal information for the following purposes: management of registration on the Site, for newsletters or mailing lists, management of the user's participation in promotions and other initiatives organized through the Site, response and management of requests for information, questions, communications or feedback from users to Haeres Equita srl a Socio Unico. The user's personal data is also processed by Haeres Equita srl a Socio Unico to fulfill obligations under the laws, regulations and community legislation and to assert or defend a right of Haeres Equita srl a Socio Unico in court.

For sales activities, Haeres Equita srl a Socio Unico uses personal data for the management of purchases made through the Site (which include all the activities necessary for the sale and after-sales services, for example the prevention of fraud, the management of returns, guarantees , customer service, interaction with our customer service).
With the user's consent, Haeres Equita srl a Socio Unico may also process the user's personal data (which may include data on preferences, habits, lifestyles, purchase details) for marketing operations, commercial or advertising communications, direct sales, market research, sales support through e-mail, phone, text messages, mms, chat, social networks and traditional mail, including the possible sending of invitations to Haeres Equita srl a Socio Unico events. With the user's consent, Haeres Equita srl a Socio Unico can define individual and group profiles (for profiling purposes) and send personalized communications. The user can always indicate his or her preferred contact methods and refuse to receive promotional communications through all or only some of the contact methods indicated above. Consent for the purposes of marketing and profiling is optional and any refusal to provide the user will have no consequences.

Information collected with the user's consent for marketing and profiling purposes is kept for a period of 30 years, as authorized, unless otherwise provided by local law. Upon expiry of this period, or if the user revokes their consent, the information relating to purchases will be automatically deleted or made anonymous in a permanent and non-reversible manner.

Security of personal data
Haeres Equita srl a Socio Unico undertakes to protect the security of the user's personal data and to comply with the security provisions of the applicable law and regulations in order to avoid data loss, illegitimate or illegal use of data and unauthorized access to this information. Haeres Equita srl a Socio Unico uses multiple advanced security technologies and procedures designed to promote the protection of users' personal data; for example, personal data is stored on secure servers located in places with controlled access. In addition, for the transmission of certain data via the Internet, up-to-date encryption technologies are used. The user can help to update and keep their personal data correct by communicating to Haeres Equita srl a Socio Unico any changes relating to their address, their qualification, their telephone number or e-mail address or any other data concerning them. The user can perform the above operations online by following the instructions on the pages of his or her user profile.

Scope of personal data communication and transfer abroad
The user's personal data are communicated in accordance with the Privacy Policy and the privacy policies published on the Site where the data are collected. The personal data of the user are accessible by authorized personnel who need to know them in order to perform their duties and to the manager in charge of the processing at Haeres Equita srl a Socio Unico, indicated above. The updated list of the data handlers and persons to whom the data are communicated is available to the user, free of charge, upon request to Haeres Equita srl a Socio Unico and the manager.

The user's personal data may be disclosed to public bodies, banks, third parties involved in corporate and extraordinary transactions. Furthermore, personal data are communicated to consultants and service providers of a professional and technical nature on the basis of specific contracts for data processing.

Data can be viewed by store personnel worldwide for sales support purposes.
Third parties are provided only with the information necessary for the performance of their functions.
Personal data may not be disclosed to unidentified subjects.
The user's personal data may also be disclosed to the legitimate recipients under applicable laws or, for example, in the case of court proceedings, requests by courts and relevant authorities or in relation to other legal obligations, and if Haeres Equita srl a Socio Unico believes in good faith that the disclosure of information is necessary to fulfill obligations arising from applicable law and to protect and defend the rights and property of Haeres Equita srl a Socio Unico.

Some of the subjects to whom the data are communicated may be established in third countries, which do not ensure an adequate level of personal data protection as foreseen by the EEA. Your personal data will be transferred outside the EEA with the precautions provided for by the applicable privacy law in order to guarantee its protection, security and confidentiality.

Provision of personal data
The provision of personal data is necessary to allow Haeres Equita srl a Socio Unico to fulfill legal obligations and to provide the services and functionalities offered by the Site and requested by the user, for example registration on the Site, management of product purchases ( which includes all the necessary sales and after-sales services, such as fraud prevention, returns management, guarantees, customer assistance and interaction with customer service) and of promotions and other initiatives implemented by means of the Site, the response and management of requests for information, questions, communications or feedback. The refusal by the user to provide personal data in the circumstances indicated above makes it impossible to provide the user with the services, products or information requested, as specified above.

The provision of data to Haeres Equita srl a Socio Unico for purposes of survey and market research, profiling, marketing and promotional purposes as specified in the section "Purposes and methods of processing personal data" is optional and the refusal on the part of the user to provide such information will have no consequences with respect to the provision of the services, products and information requested.

User rights
The user can at any time exercise the privacy rights recognized by the applicable law, including, for example, the right to obtain confirmation of the existence (or not) of personal data concerning his or her person, to verify the content, accuracy, request the inclusion, updating, rectification, cancellation, blocking of data processed in violation of the law, and to refuse processing for legitimate reasons.

For an updated list of the persons responsible for the processing at Haeres Equita srl a Socio Unico and the subjects to whom the data are communicated, for further information about the processing of data and to exercise his or her privacy rights, the user can contact Haeres Equita srl a Socio Unico or its managers responsible for processing at any time. The Privacy Policy is subject to changes and updates. The version published on the Site is the one currently in force. Changes to the Privacy Policy will be communicated by publishing on the Site a note referring to "recently amended Privacy Policy" or similar wording. Haeres Equita srl a Socio Unico invites the user to check the Privacy Policy periodically in order to be informed of any changes.

PRIVACY POLICY (updated May 25, 2018)

Haeres Equita srl a Socio Unico s.r.l., as data controller, informs users of the following:

1• Collection of data and purposes of processing.
Haeres Equita srl a Socio Unico collects the personal information provided by users when registering online and subsequently during the course of its online sales activity, including the details of the purchases made, for the following purposes: to comply with legal obligations, to assert its rights and to provide after-sales services requested by users (including, for example, fraud prevention, returns, guarantees and customer support).
Online activities include the management of user interaction with the Haeres Equita srl a Socio Unico websites (registration on websites and online initiatives such as newsletters, mailing lists and promotions) and the provision of information/materials on request; see our Privacy Policy on  www.borsalino.com.

Providing data for the above purposes is necessary and a possible refusal to provide this information would prevent provision of the products or services requested by users. The data can be used to update and/or correct information regarding users obtained previously.

2 • Additional data processing purposes.
With the consent of the users, which is optional, Haeres may collect data on preferences, habits and lifestyle of users at points of sale and through the use of paper and/or electronic forms, or online.

With the consent of the user this information, as well as the details regarding the purchases made, is used for marketing operations, commercial or advertising communications, direct sales, market research, support for in-store sales all over the world through e-mail, phone, sms, mms, chat, social networks and traditional mail, including sending invitations to Haeres Equita srl a Socio Unico events.

With the consent of the user the information is also used for defining individual and group profiles (profiling purposes) and for sending personalized communications. The user can always indicate the preferred method of contact and can object at any time to receiving promotional communications through all or only some of the contact methods indicated above. The consent for the marketing and profiling purposes identified above is optional and any refusal to provide will not have any consequences.

The data relating to purchases used with the consent of the user are stored by Haeres Equita srl a Socio Unico for marketing and profiling purposes for a period of 30 years, as authorized. Upon expiry of this period, or at the request of the user at any time, personal data will be deleted automatically or made permanently and irreversibly anonymous.

3 • Methods of data processing and data security.
The data are processed on paper and in electronic format in compliance with the security requirements established by applicable laws; our data controllers indicated below and the personnel in charge of processing (e.g. CRM, IT and retail offices) can access the data based on criteria determining the need to know.

4 • Scope of communication and transfer of data abroad.
Personal data are communicated to public entities, banks, third parties involved in corporate and extraordinary transactions, to recipients deemed legitimate by law and in addition to consultants, professional and technical service providers who are necessary for the purposes indicated above, such as those responsible for processing. These third parties are provided only with the information necessary to perform their relevant functions. The data may also be accessed by companies controlled directly or indirectly by Haeres Equita srl a Socio Unico, joint ventures and franchisees in their role as data controllers at Haeres Equita srl a Socio Unico for the purposes of profiling, marketing and managing the relationship with customers (in order to ensure the same customer benefits all over the world).

The data provided with the user's consent for marketing activities may be viewed by store personnel worldwide for sales support purposes.
Personal data may be accessed by parties outside the European Union after adopting the precautions required by applicable law.
Personal data are not disclosed.

5 • Rights of the interested party - Owners and managers - Information.
The user may at any time exercise his/her privacy rights as foreseen by applicable law, for example he/she may access data, verify the content, origin, accuracy, request additions, updates, modifications, deletions, blocking due to violation of the law.
The user can at any time refuse processing of personal data by revoking the optional consent given.
For the purposes set out in this privacy policy, the Haeres Equita srl a Socio Unico data controller is the CRM manager pro tempore, domiciled at Haeres Equita srl a Socio Unico. For more information about the processing of personal data and to exercise your rights of privacy, for example to obtain the updated list of other persons responsible for processing by Haeres Equita srl a Socio Unico and the subjects to whom the data are communicated, the user can contact Haeres Equita srl a Socio Unico s.r.l., ​​with registered offices in Corso Matteotti, 41 in Valenza (Alessandria), tel. +39 02 86 46 30 28, email: privacy@borsalino.com

COOKIES POLICY (updated 25 May 2018)
The terms in capital letters used in this Cookies Policy have the same meaning attributed to them in the Privacy Policy of Haeres Equita srl a Socio Unico (Haeres), which is here expressly referred to together with the "Privacy Notice".
Cookies are small text files sent to the user's device from the website visited. Cookies are stored on the computer's hard disk, thus allowing the website to recognize users and store certain information about them, for the purpose of making possible or improving the service offered. There are different types of cookies.
Some are necessary in order to be able to browse the site, others have different purposes such as ensuring internal security, administering the system and performing statistical analyses, understanding which sections of the site are of the greatest interest to users or offer a personalized experience on the site.
The Site uses cookies that do not have the ability to run programs on the user's computer or to load viruses on it and that do not allow any type of control over the user's computer. Haeres does not use cookies to access information on the device, to store data on it or to monitor its activities. The foregoing refers to both the user's computer and any other device that the user may use to access the Site.

So-called 'Session cookies' are temporarily stored on the device and are deleted when the user closes the browser.
If the user registers on the Site, Haeres may use cookies to collect personal data in order to identify the user on the occasion of subsequent visits and to facilitate access, login to the Site (for example, keeping the user's username and nationality) and navigation on it.
Haeres uses cookies for system administration purposes, to offer a personalized visit of the Site and, with the prior consent of the user, to profile the user's preferences for commercial and marketing purposes.

Disabling cookies may limit the ability to browse the site and prevent you from fully enjoying the features and services offered on the Site. To decide which cookies to accept and which to refuse, a description of the cookies used by the Site is shown below.

Types of cookies
First-party cookies: First-party cookies are set by the website that the user visits; its address appears in the URL window.

Third-party cookies: Third-party cookies are set by a different domain than the one visited by the user. If a user visits a site and a different company makes use of the site to sends information, third-party cookies are present.

Session cookies: These cookies are stored temporarily and are deleted when the user closes the navigation window.

Persistent cookies: Persistent cookies are stored on the user's device between browser sessions, allowing storage of user preferences or user actions on a site. They can be used for different purposes, for example to remember the preferences and choices made when using a site.

Essential cookies: These cookies are strictly necessary for the functioning of a site. Without the use of such cookies some parts of a site would not work. They include, for example, cookies that allow access to protected areas of a site. These cookies do not collect information for marketing purposes and cannot be deactivated.

Functional cookies: These cookies are used to recognize a user who returns to visit a site. They permit customization of content and remember preferences expressed by the user (for example, the chosen language or the geographical region). These cookies do not collect information that can identify the user. All information collected is anonymous.

Social network sharing cookies: These cookies facilitate the sharing of the contents of a site through social networks such as Facebook and Twitter. To view the respective privacy and cookies policies you can visit the social network websites. In the case of Facebook and Twitter, the user can visit https://www.facebook.com/help/cookies and https://twitter.com/privacy.

Analytics cookies: These cookies are used to collect aggregate information on the activities that the user performs on the Site and are collected for statistical purposes.

Profiling cookies: These cookies are aimed at creating user profiles. They require the prior consent of the user and are used to send advertising messages that conform to the preferences shown by the user while browsing.

How to change the settings on cookies
Most browsers automatically accept cookies, but the user can normally change the settings to disable this function. It is possible to block all types of cookies, or to accept to receive only some and to disable others.
The "Options" or "Preferences" sections in the browser menu allow you to avoid receiving cookies and other user tracking technologies and explain how to be notified by the browser when these technologies are activated. Alternatively, it is possible to manage cookies by consulting the "Help" section of the toolbar present in most browsers and to visit the relevant reference sites, such as Internet Explorer, Chrome, Safari, Firefox, Opera, Windows Phone, Blackberry, etc.

Data processing
The processing of the data obtained using cookies is performed by means of IT and telematic instruments by internal individuals appointed for this purpose. The data are stored in electronic archives and with full assurance of the base levels of security required by the legislator.
For everything concerning the processing of data, please refer to the "Privacy Policy" and "Privacy Information" sections.

Communication and dissemination of data
The data collected will not be disclosed or disseminated. Communication to third parties other than the owner, by data controllers within and also by those external to the company, and by the persons assigned to data processing, is foreseen to third parties (such as suppliers and IT support that guarantee the proper functioning of the portal), and will take place in the correct manner and in compliance with the legal provisions in force in the Privacy Policy.

Owner and data controller
The owner is Haeres Equita srl a Socio Unico s.r.l., based in Corso Matteotti, 41 in Valenza (Alessandria). Tel. +39 02 86 46 30 28, email: privacy@borsalino.com. The data processing manager at Haeres Equita srl a Socio Unico s.r.l. ​​is the CRM manager pro tempore, who can be reached at the headquarters of the data controller. An updated list of the persons responsible, named by the Owner, is available on request from Haeres Equita srl a Socio Unico.

Data conservation time
The data are kept for 30 years, and in any case until the right of refusal is expressly exercised by the interested party.