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INFORMATION PURSUANT TO ART. 13 – 14 OF EU REGULATION N. 2016/679

This privacy notice describes which of your personal data are collected by Zerogrey S.r.l. and Haeres Equita S.r.l., for which purposes and how they are processed. Below you will also find the necessary information to enforce your rights provided for by GDPR.

In general, we collect your personal data when you create an account on our online store www.borsalino.com (hereinafter ‘Store’), when you purchase products available for sale on the Store, when you subscribe to the newsletter, when you email or contact us asking for assistance. We hereby inform you that the personal data collected during such procedures will be processed in order to reply to your requests, to allow you to benefit from the services offered on the Store through reserved areas (e.g., to process your orders and carry out the related activities, including those required to fulfil tax and administrative obligations, and, whenever requested by you, to send newsletters and information material) as well as to provide better services, marketing and support services for you and other customers, as specified below.

1. Who processes your data: Data Controllers

Zerogrey S.r.l. with registered office in Via L. Colli, 15 10128 Torino, VAT number 08003340018, (hereinafter “Zerogrey”) and Haeres Equita S.r.l., with registered office in Corso Garibaldi 122 -15048- Valenza (AL), VAT number 02471250064 (hereinafter “Borsalino”) are joint controllers of the processing of your personal data.

Pursuant to art. 26 GDPR, we inform you that Zerogrey is data controller of the processing of your personal data and shall process them in order to: manage and process your purchase orders, ship to you the products that you buy, provide you with the required post-sales assistance, process the product returns procedure, comply with tax regulations.

Pursuant to art. 26 GDPR, we inform you that Borsalino is the data controller of your personal data and shall process them for managing your Store account, also in order to consent any possible transfer to a new service provider or to internalize all services provided by Zerogrey, to assist Zerogrey in processing your data for the purposes of legal or contractual guarantees, including the management of product return procedures, for the Store maintenance, for the provision of specific services and experiences for shopping also through its boutiques and, upon your consent, for marketing purposes.

2. Which data we process - Type of processed data

Your contact and purchase data. We will store the details you provide us with (e.g., name, surname, address, telephone number, e-mail, country, date of birth, gender) when you create an account on the Store, when you purchase a product and/or participate in contests or promotions.

Your payment and invoicing data. Zerogrey will retain the payment and invoicing data that you provide to us with (e.g., your credit card number, zip code and address) when you purchase a product, in order to process your order and ship the products. Upon your request, we can also store your payment and billing information in order to make it easier to purchase products in the future.

Information on the use of the website and on your activities on the Store. Your use of the website implies the processing of the browsing data and the device that you are using and your IP address (i.e. the number that identifies a specific device connected to the internet and is required in order for your device to communicate with websites). Moreover, we may analyse the website you browsed from, what you did and what you did not do on our website.

3. Where do we get your data - Data collection methods:

Directly from you. For instance, if you register in order to make a purchase on the Store, if you create an account, if you participate in a contest, if you ask us a question, or contact Customer Care.

If you do not provide us with your personal data, you will not be able to register on the Store, and you will not be able to purchase any of the products for sale.

Through the use of Store’s functionalities. We use cookies and other technologies, such as pixel tags on the website and in emails in order to collect data concerning your behavioural information and to improve promotion targeting. Should you like to learn more, please read our Cookie Policy.

Third party data provided directly by you. The possible indication (e.g., for the shipment of the product and/or when purchasing a gift card) of personal data and contact details of any third party other than you represents a processing of personal data with respect to which you are a data controller, thus assuming all the obligations and responsibilities provided for by current legislation on personal data. On this regard, you guarantee to Borsalino and Zerogrey that any data of third parties that will be indicated by you have been collected by you in full compliance with current legislation on personal data, and that there is an appropriate legal basis that allows the communication of such third party personal data to Borsalino and Zerogrey , relieving them from any dispute, claim, request for compensation for damages from any third party resulting from the aforementioned communication that may be received by Borsalino and Zerogrey .

4. Why and for how long we process your data - Purpose and legal basis for data processing; data retention period

a) To provide you with the products and services you purchased and to give you information about your orders and payments. For example, we will use your data to manage your order and/or the purchase of a gift card and/or the purchase of a personalisation service, to confirm your purchase and to manage ancillary services such as the shipment of purchased products. Without your data we will not be able to manage and process your order.

The legal basis of such data processing is the performance of the purchase agreement, which you become a party of since you accept the Store’s general conditions of sale.

The data retention period of your data is equal to the period required to process the order, subject to a further retention period for the purposes set out below of up to 10 years from the date of the last purchase.

b) To allow you to register for a Store account. We will process your personal data in order for you to create an account on the Store, whether you make a purchase on the Store or not.

The legal basis of such data processing is the performance of a contractual/pre-contractual request submitted by you.

The retention period of your data, in addition to what is necessary to process your order if any, shall be equal to the period of validity of your account, which shall be in any case deactivated after 24 months from your last access or from the last action taken by you in your account.

c) To give you an update on product availability. Following your explicit request, we will process your personal data, in particular your e-mail address, in order to update you on the availability of the product you have requested in the Store. Borsalino will also process your personal data in order to update you on the availability of the products in the physical Borsalino stores.

The legal basis of such data processing is the performance of a contractual/pre-contractual request submitted by you.

The retention period of your data is equal to the period necessary to process the request.

d) To allow you to book an appointment as part of the "Made to measure" service. Borsalino processes your personal data, such as your first and last name, your telephone number and your email address, to allow you to book an appointment at a boutique of your choice to use the "Made to measure" service.

The legal basis for this processing is the execution of a contractual/pre-contractual request on your part.

The retention period is equal to the period necessary to process the request, i.e. until the appointment is made following the confirmation of the relevant booking or the definitive cancellation of the same.

e) To provide you with the required after-sales assistance in compliance with the applicable legislation related to the product warranty. For example, we will use your data to provide you with support, in order to manage the return and/or repair of the products that you purchased from the Store in accordance with applicable law.

f) To allow you to take benefit of our "Virtual Personal Shopping Experience" service and/or to respond to requests for information addressed directly to our boutiques. Borsalino will process your personal data to allow you to take advantage of the Virtual Personal Shopping Experience service. For further information on the processing of your personal data click here.

The legal basis of such data processing is the compliance with legal obligations and the data retention period is equal to that required by law (specifically, by the Italian Consumer Code).

g) To manage your administrative status correctly. We will process your data for accounting, administrative and tax purposes, directly connected to joint controllers’ business activities as required by the applicable legislation.

The legal basis of such data processing is the compliance with the legal obligations and the retention period is equal to that required by law (specifically, civil, tax, anti-money laundering, banking and public security law).

h) To let you to interact with customer care operators. We may use your e-mail and telephone number, such as your name and/or address, to assist you should you require support while using the products purchased from the Store.

The legal basis of such data processing is the performance of the sale and purchase agreement that you executed with Zerogrey when you accepted the Store’s general conditions of sale and the compliance with the obligations provided for by applicable law in terms of warranties and customer care. The retention period is equal to the time necessary to manage your request.

We might also collect information regarding customer assistance or issues occurred to our service. To improve quality of customer care services, subject to applicable legislations, Zerogrey may also record and listen conversations with customer care operators. The legal basis of this processing is the legitimate interest of Zerogrey to improve the quality of the services provided to its customers. In addition, Zerogrey might analyze any feedbacks provided voluntarily through surveys submitted to the client. The legal basis of this processing is the consent of the data subject.

In the above cases, the retention period of your data shall be equal to the period of validity of your account

i) To prevent or control unlawful conducts or to protect and enforce rights. For example, we may use your data to prevent infringement of their intellectual property rights (e.g., counterfeiting of our trademarks and/or our partners’) or theft (including credit card cloning and theft that we presume may occur during a contest or an event) or other unlawful acts, as allowed by applicable law.

The legal basis for such data processing is the legitimate interest of the joint controllers.

The period of retention of your data is equal to the time reasonably necessary to enforce our rights from the moment we become aware of the offence or the potential commission of it.

j) For direct marketing purposes. Upon your consent, you may be contacted by Borsalino by email, sms, telephone or other telematic communication means with information or promotions of products and services (including newsletter), also following your subscription to the newsletter by entering your email address.

The legal basis for such data processing is your explicit consent.

The retention period of your data is 24 months from the collection of your data.

k) To monitor and improve our products and the Store. Upon your consent, Borsalino analyses your product usage, preference and use data to improve its approach to you and its customers in general, through automated processing including profiling. It does this so that it can make better decisions about services, advertising, products and content based on a better understanding of how its customers use our services and to provide you with a more personalised experience. For this purpose Borsalino may also collect your mobile device's advertising identifier (IDFA - Identifier for Advertising - for iOS devices and AAID - Google Advertising ID - for Android devices) to always provide you with targeted and relevant ads based on your preferences and interests.

The legal basis for such processing is your explicit consent.

The retention period of your data is 12 months from the collection of your data.

l) To send commercial proposals and offer products in line with your preferences. With your consent and after completing the formalities required by law, Borsalino will process your data to understand your preferences in order to improve its offer and to make your shopping experience more personalized.

The legal basis for this processing is your explicit consent.

The retention period of your data is 12 months from the collection of your data.

5. Nature of the provision of personal data

For the purposes of subparagraphs from a) to i) above, the provision of data is necessary to allow you to create an account on the website, make purchases on the Shop and receive other services on the website.

For the purposes of subparagraphs from j) to l) above, the provision of data is optional, a refusal will not cause any prejudice for the purposes of subparagraphs from a) to f). Data subject may withdraw his/her consent at any time, but this shall not affect the lawfulness of processing carried out by Borsalino based on consent before its withdrawal.

6. Where your data are processed – Transfer of data

The data shall be processed and stored at the offices of Zerogrey at Via L. Colli n. 15 Torino and, for Borsalino, at its operating headquarters located in Zona D5, via Gambalera 170 - 15122 - Spinetta Marengo (AL), at its showroom in via Sant'Andrea 5 - 20121 - Milano and at its its own Borsalino’s boutiques located in Italy and France, whose references are listed on a specific page of the site.

Personal data may also be communicated, for administrative purposes, to companies of the group to which Zerogrey belongs in UE.

7. Who we share your data with – recipients of personal data

Provided that, where required by law, we will obtain your prior consent and complete any formalities required by law, we may share your data with the following third parties (also acting as data processors):

Our service providers. We may share your data with third parties in order for them to provide us with services (e.g., couriers, companies managing customer care’s services, companies managing warehouses and providing logistics services, legal, tax and accounting advisors), we will enter into an agreement with them pursuant to Article 28 GDPR in order to protect your data. These parties will only be in possession of the data required to perform their functions and shall only use them for the purpose of providing services on our behalf or complying with the law. You may find out the details of such data processors, pursuant to Article 28 GDPR, by sending an email to privacy@zerogrey.com or to privacy@borsalino.com.

Where we deem it necessary in order to comply with legal obligations or to protect Ourselves or third parties from a judicial standpoint. Where permitted or required by law, we may also share the data requested by a government agency or by another authorised third party or organisation, in order to protect or enforce Our rights or those of third parties, or to limit or prevent fraud (including credit card fraud or other fraud, which we believe that may occur during a promotion or an event) and other offences.

8. Minors

Our Store is not intended for minors under the age of 18, but for adults. If you are a parent or guardian and you believe that your child may have sent us some personal data, please contact us.

9. Security Measures

We adopt the security measures required by law.

We adopt security measures to protect your data. The standard security measures that we use depend on the type of data that we process, and such measures meet the requirements provided for by law and by the standards of European government agencies.

10. Your rights

You may contact Borsalino and/or Zerogrey in order to request the access to, the rectification or erasure of your personal data, or restriction of the processing, to object such processing and to request the portability of your data; you may also withdraw your consent at any time (and this shall not affect the lawfulness of the processing based on consent granted before such withdrawal).

When you exercise your right of access, you have the right to know whether your data is being processed or not, as well as the purpose of the processing, the categories of data being processed, the recipients or categories of recipients who your data have been disclosed with (and, if they are located in a third country, the guarantees in place), the retention period of your data (or the criteria in order to determine such retention period), whether an automated processing is being carried out or not (e.g., through profiling), the logic involved behind such processing, and the source of the data (when not initially collected by Us).

You have the right to lodge a complaint with the Italian Data Protection Authority and to request to the Data Controller, at any time, information about the processors and the parties that are authorised to process your data.

You may exercise your rights by contacting Borsalino or Zerogrey at the above-mentioned address or by sending an email to privacy@borsalino.com or to privacy@zerogrey.com.

You can withdraw your consent to receive marketing communications including newsletters. In order for you to stop receiving marketing communications, you may access your account and change your settings or follow the instructions shown in the promotional message that you receive. Alternatively, you may withdraw your consent by sending an email to privacy@borsalino.com.

You may control and disable cookies and other profiling tools. To learn how we use cookies and other profiling tools, click here.

As for marketing emails and data processing through profiling, you may amend your preferences in the privacy settings of your account or by sending an email to privacy@borsalino.com.

11. What happens if we amend this Policy

We may make amendments to our privacy policy. We will publish an updated version of it on our website. It will have a different version number from the one shown below. Please visit the site periodically to check for updates.

Version updated to June 4th 2021

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