PRIVACY POLICY FOR SITE MANAGEMENT AND MARKETING ACTIVITIES

Last Updated: October 28 2024

The Ermenegildo Zegna Group is aware that the personal data of its customers are important. This Privacy Policy describes how we collect, use, and disclose information that you submit to us or that we collect through this website (the “Website”), are handled. By using the website and/or your selection concerning cookies, you are consenting to this use and handling of the data. 

The section entitled “Privacy Notice for California Residents” specifically relates to the personal information of California residents. We may update and make changes to this policy, so we encourage you to review it regularly. 

1) The Data Controller of the data collected and processed through the Website and the Data Protection Officer

The Data Controller of the data collected on the Website is: 

- EZ Service S.r.l., Viale Roma 99/100, 13835 VALDILANA (BI), ITALY (hereinafter referred to as, “Zegna”, “we”, “us”, “our”).

To contact the Data Protection Officer you may write to privacy@zegna.com. 

2) What data will be collected through the Website, and purposes of their processing

The data collected and processed through the Website are of different types. Such data are processed for various purposes and with different methods. They include: 

(a) Cookies - The data concerning your browsing of the Website are processed to ensure that the Website works properly, and for marketing purposes. The Website’s cookie banner also includes an option to change your previous preferences concerning cookies. The Website uses the following cookies:

Technical cookies- These cookies allow the Website to function correctly making it possible to view its contents in the related language and market from the user’s first visit. They are able to recognize the country from which the user is making the connection and ensure that the user is automatically orientated to the version of the Website applicable for his or her country on each visit. They also make it possible to create an account, to log in and manage orders. If you are a registered user, the Website will be able to recognize you when accessing the services offered to registered users as a result of the cookies. These cookies are able to tell if users purchase products on the Website through an affiliated or partner Site, making it possible for us to fulfill our obligations in relation to such partner Sites. These cookies are necessary for the functioning of the Website.

Functional cookies- These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

Analytical cookies- These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. These cookies are used to create statistical analyses and they help us to know which pages are the most and least popular and see how visitors move around the site. If you do not allow us to use these cookies for analytics, we will not know when you have visited our site, and will not be able to monitor its performance.

(b) Web beacons- A web beacon is a small image file on a web page that may be used to collect certain information from your device. This information may include the IP address, time of access, browser, and identification of cookies. Zegna, or our vendors, utilize web beacons to track visitor statistics and manage cookies.

(c) Log file and addressing information- This information is sent automatically to Zegna by your browser each time you visit the Website. This is not dependent on the presence or use of cookies and is unaffected by your opt-in or opt-out election concerning cookies. These logs may contain information such as the Internet domain from which you access the Website; the date and time you visited the Website; the areas of the  Website that you viewed; your computer’s IP address that is automatically assigned when you log onto the Internet; the type of browser and operating system you use; the address of the web site you came from, if any; and the webpage addresses requested by or sent to you. 

(d) Location Data- Zegna utilizes a feature that, when you access the Website by or through a mobile device or through your browser, accesses, collects, monitors and/or remotely stores “location data,” and may include GPS coordinates (longitude and latitude) or similar information regarding the location of your device. This data may be used to convey information about how you browse and use the Website, as well as provide you personalized information based on that location data. You may opt-in or opt-out of sharing location data from your device.

(e) Registration and Services - Any data that you have voluntarily provided (included personal details and information, password you chose while filling in the registration form of your Zegna personal account and financial account information for purchases), or the data that were lawfully acquired in any other manner, are processed for acknowledging receipt of your requests and delivering the service, providing you with all necessary assistance and information in relation to the products and Zegna’s world. The data (you directly provided us personal information relating you and your working and study experience) for submitting you curriculum vitae to Zegna are processed to evaluate your possible career within Zegna. 

(f) Social Media Network Log-In - Please note that using your social media network profile to log-in, some specific data will be communicated by the Social Media Network you selected (such as name, surname, e-mail address and some other data about you that are on the same Social Media Network). Therefore, we will ask for your approval to proceed before logging you to your personal account using the social log-in. Please also note that Social Media Networks may ask for feedback and information about the social log-in use. For more information, please refer to the Social Media Networks’ privacy policies  
Facebook( https://www.facebook.com/about/privacy/update?ref=old_policy ) 
Google + ( https://policies.google.com/privacy )

(g) Marketing - By giving your express consent, in addition to consenting to this Policy, you will allow Zegna to process your data for marketing purposes, namely, for sending you, through newsletters, emails, SMS and MMS and through postal mails and telephone, information and updates on products, sales, promotional campaigns, events and other initiatives promoted by Zegna, also in collaboration with its business partners, and carrying out specific market researches. 

(h) Study of preferences - By giving your express consent, you will allow Zegna to process your data for analyzing your spending habits and preferences, and enabling it to adapt its products and initiatives to your tastes and meet best your requirements.

(i) Communication to third parties - By giving your express consent, in addition to consenting to this Policy, you will allow Zegna to transfer your personal data to the other companies belonging to the Zegna Group, and its commercial partners working in the luxury industry as well as car industry, travel industry and consiergerie industry in order to enable them to process your data for marketing purposes, namely, for sending you, through newsletters, emails, SMS and mms, and through postal mails and telephone, information and updates on products, sales, promotional campaigns, events and other initiatives. 

3) Source of personal data and relevant legal basis of the processing

Zegna collects personal data directly from the user, with the exception of the data collected with navigation such as via technical cookies, Log File or Web Beacons,  - per sections 2 (a)-(c) above – and data collected with the social media log-in as per section 2 (f) above). 

- For Cookies- as per section 2(a)- When users access any page on the Website, they will see a banner displaying brief information about cookies. Through the banner, you are free to provide your personal data for the purposes of analysis for advertising and marketing and enhancing functionality and personalization of the Website. The legal basis for this processing lies in the consent given as indicated on the related Website banner. Failure to consent does not have any consequence on the basic use of the Website (except that of not receiving any more suggestions to purchase and enhanced personalization and functionality of the Website). Consent is not required for the use of technical cookies; they are thus processed on the basis of the business’s legitimate interest in providing improved navigation and use of the Website.

- For web beacons– as per section 2(b)- the legal basis is the legitimate interest in monitoring user engagement with the Website, enhancing user experience and for advertising and marketing.

- For log file and addressing information – as per section 2(c)- log file information helps us design our Website’s appearance, identify popular features, resolve user hardware and software problems, analytics, and make the Website more useful for users, including customers. Additionally, addressing information sent from or sent to you—as one example, the webpage addresses requested by or sent to you—can be used for a variety of purposes and may be shared with third parties via cookies or other means for a variety of reasons, including but not limited to: helping design the look of the sites, operations and attributes of the sites; identifying popular features; resolving visitor hardware and software problems; analytics; tailoring website content and advertising for specific visitors; and helping enhance the visitor’s experience. The legal basis for collecting log file information is the legitimate interest in enhancing the user’s experience and for advertising and marketing.

- For the Registration and Services activities - as per section 2 (e) - the legal basis is the legitimate interest to provide general site services, information requested by the users (and the contractual obligation in case Zegna offers the users specific services as “book an appointment” or “Made to Measure” Services) and process sales. The legal basis for the processing of job applications is the legitimate interest to evaluate the same for recruiting purposes. 

- For Location Data, Social Log-In, Marketing, and Study of Preferences, Communication of data to third parties (as per sections 2 (d), (f), (g), (h) and (i) above, the legal basis is the specific explicit consent given by the user.

4) Analysis of user’s buying habits and selections

As indicated in Section 2(e) above, with the user’s express consent, Zegna may also process the user’s personal data for the purposes of analyzing user’s habits, purchases and selections, in order to make the Zegna products, services and initiatives more responsive to its customers’ tastes and needs.

Zegna will process, by automatic means, the lifestyle, the value purchased within a framework of time, the frequency of the purchases (even if the purchases are made during the sale period) and the kind of product purchased (accessories, clothes, haute couture, pret-a-porter). The study is only intended to propose to clients and users, products, services and initiatives more responsive to their tastes and needs. Zegna will not proceed with an intrusive study of the users’ behavior. 

Moreover, please note that as per sections 2(a), with the user’s express consent given on the Website’s cookie banner, Zegna can process personal data through automatic means to study cookies. This analysis helps verify the user’s navigation through the Website, and proposes products and services in line with the navigation.

5) How your personal data will be processed

The data collected through the Website will be mainly processed by electronic means, adopting all security measures as necessary to reduce to a minimum any risk of destruction or loss of the data, including accidental loss, unauthorized access, unlawful processing, or processing that are not compliant with the purposes for which the data were collected as specified in this Privacy Policy.

However, since the data will be transmitted via electronic networks, the above measures cannot limit or completely exclude the risk of unauthorized access or dissemination of the data. To this end, we recommend you check regularly that your PC is endowed with software capable of providing adequate protection (like updated antivirus systems) for the online transmission, inbound and outbound, of the data, and that your Internet Service Provider has adopted adequate security measures for a secure transmission online of your data (like, for instance, firewall and anti-spamming). 

6) Storage period

We will keep your personal information, including sensitive personal information, for as long as we need it, or as otherwise prescribed by law, for the purposes set out above. This period will vary depending on your interactions with us. We may retain your personal information for a longer period if there are valid legal grounds for doing so, for example, in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information, we consider many factors, including the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We may retain your personal information for a longer period if there are valid legal grounds for doing so, for example, in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. For more information, please contact the Privacy Officer.

7) Obligatory or voluntary nature of providing the requested data

With the exception of the data related to your surfing activity (i.e., cookies, web beacons, log file information) the provision on any other data collected through the Website for answering your requests, providing information, as well as for marketing purposes and for analyzing your spending habits and preferences is free, voluntary and optional. Any failure by you to provide the data shall not limit your use of the Website, such failure may however make it impossible for Zegna to respond to your queries and requests for information, or send materials, updates, newsletters, invitations to the events organized by the Zegna Group and/or its business partners.

8) Categories of recipients of personal data

Zegna may disclose your personal data as indicated below:

(a) To the other companies belonging to the Zegna Group or to its commercial partners for marketing and advertising purposes.

(b) To Zegna’s employees and consultants.

(c) To other companies of the Zegna Group, acting as data processors in order to carry out contractual activities and services.

(d) To companies which, acting in their capacity as data processors, provide to Zegna specific technical and organizational services in relation to the Website and to the management of marketing and communication activities.

(e) To third parties approved by the consumer.

(f)  In the event of a change in ownership or control, such as a sale or merger.

(g) Your data may also be disclosed to police officers and judicial authorities, in compliance with the law and upon their request, or in case there are good reasons to believe that such disclosure is reasonably necessary to (1) investigate, prevent or take initiatives in relation to suspected unlawful activities, or assist national supervisory authorities; (2) prepare a defense against third party claims or charges, protect the security of the Website and of the company; or (3) exercise or protect the rights, property or security of Zegna, the Zegna Group companies, its affiliates, customers, employees and third parties.

Certain data collection and processing on our website may be deemed by applicable state laws as a “sale” or “sharing” of personal information. For example, the personal identifiers and usage data collected by the cookies, web beacons and log files described above in section 2 may be shared with our analytics vendors that may use such information for the purposes of targeted behavioral advertising across different platforms. Such disclosure is treated as a sale of personal data in certain jurisdictions. To submit a request to opt out of the sale or sharing of your personal information, you may click the “Do Not Sell or Share My Personal Information” link.

Your data may also be disclosed to police officers and judicial authorities, in compliance with the law and upon their request, or in case there are good reasons to believe that such disclosure is reasonably necessary to (1) investigate, prevent or take initiatives in relation to suspected unlawful activities, or assist national supervisory authorities; (2) prepare a defense against third party claims or charges, protect the security of the website and of the company; (3) exercise or protect the rights, property or security of Zegna, the Zegna Group companies, its affiliates, customers, employees and third parties. 

9) Cross-border data transfer

Your data will be disseminated and transferred abroad only if adequate levels of protection and sufficient safeguards, as provided for by the law, are guaranteed, such as “Standard Model Clauses” approved by the European Commission. For more information about the location of data, please contact the Privacy Officer.

10) Data subject’s rights under the privacy law

You shall be entitled to obtain, at any time, access to your personal data, confirmation from Zegna as to whether or not the personal data concerning you exists, regardless of whether such data has already been recorded, and communication of such data in intelligible form. You shall also be entitled to be informed of the source of the personal data; of the purposes and methods of the processing; of the logic applied to the processing, if the latter is carried out with the help of electronic means; of the identification data concerning the data controller and the data processors; of the entities or categories of entities to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as data processors or persons in charge of the processing.

You shall also have the right to obtain the updating, rectification or, where interested therein, integration of the data, restriction of processing, erasure, anonymization or blocking of your personal data that has been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed. Furthermore, you shall have the right to obtain certification that the above actions have been notified, as also related to their contents, to the entities to whom or which the data were communicated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected. You can ask for the portability of your data; you also have the right to be forgotten, to lodge a complaint with a supervisory authority, as well as the right to withdraw the consent previously given. 

You shall have in any case the right to object, in whole or in part, on legitimate grounds, to the processing of your personal data , even though they are relevant to the purpose of the collection, where the purpose is to send advertising materials or to direct selling or else for the performance of market or commercial communication surveys. The right to object may be exercised also in relation to how the marketing messages are being sent.

11) How to exercise data subject’s rights

The above rights may be exercised by sending the relevant request to Zegna, to the attention of the Data Protection Officer, at the following address: privacy@zegna.com. 

12) Your State Privacy Rights

In the United States, state consumer privacy laws may provide their residents with additional rights regarding our use of their personal information.

California (see “Privacy Notice for California Residents”), Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia provide (now or in the future) their state residents with rights to:

  • Confirm whether we process their personal information.
  • Access and delete certain personal information.
  • Correct inaccuracies in their personal information.
  • Data portability.
  • Opt-out of personal data processing for (i) targeted advertising, (ii) sales or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects.
  • Opt-out of or prohibition of certain automated decision-making.
  • Either limit (opt-out of) or require consent to process sensitive personal data.

The scope of these rights varies by state. The privacy laws of some states may not offer one or more of these rights, and we may not be subject to one or more state privacy laws. To exercise any of these rights to the extent permitted under applicable law, please send us a request at privacy@zegna.com.

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PRIVACY POLICY FOR ONLINE SALES

The Ermenegildo Zegna Group is aware that the personal data of its customers are important and it therefore intends to inform them on how their personal data is collected and processed during the purchases made on this website are handled (the “Website”).

1) Joint Data Controllers, Data Processors and Data Protection Officer

With reference to the data connected to the online sales carried out through the Website and to any activity related to such sales:

- EZ Service S.r.l., Viale Roma 99/100, 13835 VALDILANA (BI), ITALY (hereinafter referred to as, “Zegna”); 

- Ermenegildo Zegna Corporation a company having its registered office in 10 East 53rd Street 7th Floor New York, NY 10022, registered with the Taxpayer Identification Number 13-2814304 (hereinafter referred to as, “Company”);

together hereinafter referred to as, the “Joint Data Controllers”. 

To contact the Data Protection Officer of Zegna and to contact the Company, you may write to privacy@zegna.com

2) Data collected by the Joint Data Controllers and purposes of the processing

Joint Data Controllers will collect personal data directly from the users during their registration or when they place their orders for the products, complete their e-transactions, exchange correspondence in relation to activities that are incidental and conducive to the sales, as well as when they receive pre-sale and post-sale support. Further specific purposes will be illustrated in greater detail in specific privacy policies posted from time to time on the Website.

3) Source of personal data and relevant legal basis

Join Data Controllers collect personal data directly from the user (during the purchase steps). The processing activity as per point 2 is for the fulfilment of contractual and pre/post contractual obligations.

4) How data will be processed and storage period

The data collected through the Website during any activity that is incidental and conducive to the sales of the product and to any other related activity, will be mainly processed by electronic means, adopting security measures as to mitigate any risk of destruction or loss of the data, including accidental loss, unauthorized access, unlawful processing, or processing that are not compliant with the purposes for which the data were collected as specified in this Privacy Policy.

However, since the data will be transmitted via electronic networks, the above measures cannot limit or completely exclude the risk of unauthorized access or dissemination of the data. To this end, we recommend you check regularly that your PC is endowed with software capable of providing adequate protection (like updated antivirus systems) for the online transmission, inbound and outbound, of the data, and that your Internet Service Provider has adopted adequate security measures for a secure transmission online of your data (like, for instance, firewall and anti-spamming). 

Personal data linked to the purchase will be stored in accordance with the legal and fiscal requirements of laws.

5) Obligatory or voluntary nature of providing the requested data

The provision of the data, especially personal details, email address, postal address, telephone number, and bank details in case of credit card payments, is compulsory for executing, through the Website, the product purchase agreement.

Some of said data, however, may be necessary for providing to the user other services made available on the Website in connection with the sales, or for discharging the obligations deriving from the law or regulatory provisions. 

Any failure to provide some of the data required for such purposes might result in us being unable to perform the agreement for the products purchased through the Website, or to provide the user with other services related to their purchase - such as, for instance, support services (Customer Care), use of the Wish List - or, also, to correctly perform the obligations provided for by the law and regulatory provisions. Any failure by the data subject to provide us with the data may therefore constitute, as the case may be, a lawful and justified reason for not performing the agreement of the products purchased on the Website and not providing the related services.

The provisions of data other than the data for which the provision is mandatory, for the purposes of complying with legal or contractual obligations or for providing, upon request, specific services, is instead voluntary and it does neither affect the purchase of the products nor any of the connected/related services. 

The mandatory or voluntary nature of the data to be provided will be, if necessary, and as the case may be, indicated by means of a special character (*) placed next to the relevant information or to the data the provision of which is necessary for the purpose of providing the services and for purchasing the products on the Website. Any failure to furnish the data, the provision of which is voluntary, does not entail obligations or disadvantages of whatever type.

6) Categories of recipient of personal data

Your data may be disclosed to third parties which, acting in their capacity as Data Processors, carry out on behalf of the Joint Data Controllers specific services (including, without limitation, logistics services and IT services), companies of the same group, and other recipients of the data collected by the Joint Data Controllers, which will process the data for the sole purpose of completing the transaction concerning products purchased on the Website (including the financial institutions in charge of providing remote card payment services through credit/debit cards) and only if such purpose is not in conflict with the purposes for which the data were collected and subsequently processed and, in any case, in a manner that is consistent with the law.

None of the data will be communicated, transferred or otherwise disclosed to third parties other than the parties mentioned above, unless the relevant data subjects have been previously informed of and have consented (if their consent is required by the law) to any such communication, transfer or disclosure. The data will not be disseminated, and will be transferred abroad only and if adequate levels of protection and sufficient safeguards, as provided for by the law, have been guaranteed with the use of the Standard Contractual Clauses. 

7) Data subjects’ rights under the privacy law

The data subject shall be entitled to obtain at any time access to personal data concerning him/her, confirmation from Zegna as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form. The data subject shall also be entitled to be informed of the source of the personal data; of the purposes and methods of the processing; of the logic applied to the processing, if the latter is carried out with the help of electronic means; of the identification data concerning the data controller and the data processors; of the entities or categories of entities to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as data processors or persons in charge of the processing. 

The data subject shall also have the right to obtain the updating, rectification or, where interested therein, integration of the data, restriction of processing, erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed; certification to the effect that the above operations have been notified, as also related to their contents, to the entities to whom or which the data were communicated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected. The user can ask for the portability of his/her data; the user also has the right to be forgotten, to lodge a complaint with a supervisory authority as well as the right to withdraw the consent previously given.

The data subject shall have in any case the right to object, in whole or in part, on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys. The right to object may be exercised also in relation to how the marketing messages are being sent. 

The above rights may be exercised by sending the relevant request to Zegna, to the attention of the Data Protection Officer, at the following address: privacy@zegna.com.