PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This section supplements our Privacy Policy, and applies solely to the processing of California residents’ personal information. This section is intended to address the relevant notice requirements of the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), and uses certain terms having the meaning given in the CCPA and related regulations.

Please refer to the sections in the Privacy Policy explaining 1) what data we collect and the purposes of such collection, 2) the sources of such information, 3) how we use such data, 4) the categories of recipients with which we disclose the information and whether such information is sold and shared, and 5) the retention or storage period of such information.

1) Personal information we have collected
Listed below is the categories of consumer personal information we have collected in the preceding 12 months, the business purposes for which it was collected and the sources of the information:

  • CATEGORY OF PERSONAL INFORMATION: Identifiers (include information such as name, address, email address, IP address)

    BUSINESS PURPOSES FOR COLLECTING AND USING PERSONAL INFORMATION:
    - For advertising and marketing services;
    - Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, providing analytic services for advertising and marketing, and processing payments.

    SOURCE OF PERSONAL INFORMATION:
    - Directly from you;
    - Social media networks;
    - Automated information collection.
     
  • CATEGORY OF PERSONAL INFORMATION: Personal Information Classifications (include details like name, signature, address, phone number, education, and employment history)

    BUSINESS PURPOSES FOR COLLECTING AND USING PERSONAL INFORMATION:
    - For advertising and marketing services;
    - Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing analytic services, and hiring and retention services

    SOURCE OF PERSONAL INFORMATION:
    - Directly from you;
    - Social media networks;
    - Credit reporting agencies;
    - Automated information collection.
     
  • CATEGORY OF PERSONAL INFORMATION: Commercial Information (includes records of Client Services, financial data, and payment information, excluding credit/debit card numbers and related credit/debit card data)

    BUSINESS PURPOSES FOR COLLECTING AND USING PERSONAL INFORMATION:
    - Providing analytic services to business or service provider.

    SOURCE OF PERSONAL INFORMATION:
    - Directly from you.
     
  • CATEGORY OF PERSONAL INFORMATION: Internet or Electronic Network Activity Information (includes data such as IP addresses, login information, browsing history on the Website, and interactions with websites, applications, or advertisement).

    BUSINESS PURPOSES FOR COLLECTING AND USING PERSONAL INFORMATION:
    - Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, and providing analytic services;
    - Debugging to identify and repair technology-related errors that impair existing intended functionality;
    - Helping to ensure the security and integrity of the Website;
    - To improve the user experience on the Website.

    SOURCE OF PERSONAL INFORMATION:
    - Automated information collection.
     
  • CATEGORY OF PERSONAL INFORMATION: Geolocation Data (includes information regarding IP addresses and device locations used to determine general geographic location)

    BUSINESS PURPOSES FOR COLLECTING AND USING PERSONAL INFORMATION:
    - For advertising and marketing services;
    - Helping to ensure the security and integrity of the Website;
    - To improve the user experience on the Website.SOURCE OF

    PERSONAL INFORMATION:
    - Directly from you;
    - Automated information collection.
     
  • CATEGORY OF PERSONAL INFORMATION: Inferences Drawn from Other Personal Information (refers to profiles reflecting preferences, characteristics, psychological trends, behaviours, attitudes, intelligence, abilities, and aptitudes)

    BUSINESS PURPOSES FOR COLLECTING AND USING PERSONAL INFORMATION:
    - For advertising and marketing services;
    - Undertaking internal research for technological development and demonstration;
    - Analytic services;
    - To improve the user experience on the Website.

    SOURCE OF PERSONAL INFORMATION:
    - Analytic Service Providers.
     
  • CATEGORY OF PERSONAL INFORMATION: Sensitive Personal Information (such as Social Security, driver’s license, state identification card, or passport number, or account log-in, financial account, debit card, or credit card number with any required security code, password, or credentials allowing access to an account, or precise geolocation, or contents of mail, email and text messages unless Zegna is the intended recipient of communication, etc.)

    BUSINESS PURPOSES FOR COLLECTING AND USING PERSONAL INFORMATION:
    - Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, and processing payments.

    SOURCE OF PERSONAL INFORMATION:
    - Directly from you.

A legitimate interest is present when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

We only use sensitive personal information for the business purposes described above.

2) Sale or sharing of personal information, purposes for sale or sharing, and receiving third parties

Certain data collection and processing on our Website may be deemed by the CCPA as a “sale” or “sharing” of Personal Information. Under the CCPA, sharing solely refers to the disclosure of personal information for cross-contextual behavioural advertising and is treated similarly under the law to the selling of personal information in exchange for consideration.

In the preceding 12 months, we have shared the following personal information to third parties, and we continue to share personal information to third parties, as specified below:

  • CATEGORY OF PERSONAL INFORMATION SOLD OR SHARED: Identifiers (include information such as name, address, email address, IP address)

    BUSINESS PURPOSES FOR SELLING OR SHARING PERSONAL INFORMATION:
    - For advertising and marketing services;
    - To improve the user experience on the website.

    CATEGORIES OF RECEIVING THIRD PARTIES:
    - Advertising networks.
     
  • CATEGORY OF PERSONAL INFORMATION SOLD OR SHARED: Internet or Electronic Network Activity Information (includes data such as IP addresses, login information, browsing history on the Website, and interactions with other websites, applications or advertisements, search terms, uploads and downloads, the URL that referred you to the Website)

    BUSINESS PURPOSES FOR SELLING OR SHARING PERSONAL INFORMATION:
    - For advertising and marketing services;
    - To improve the user experience on the website

    CATEGORIES OF RECEIVING THIRD PARTIES:
    - Advertising networks.
     
  • CATEGORY OF PERSONAL INFORMATION SOLD OR SHARED: Geolocation Data (includes information regarding IP addresses and device locations used to determine general geographic location)

    BUSINESS PURPOSES FOR SELLING OR SHARING PERSONAL INFORMATION:
    - For advertising and marketing services;
    - To improve the user experience on the website

    CATEGORIES OF RECEIVING THIRD PARTIES:
    - Advertising networks.

We do not knowingly provide services to anyone under the age of 16 nor do we have actual knowledge that we sell or share the personal information of consumers under 16 years of age.

3) Categories of Personal Information Disclosed for a Business Purpose, reason for disclosure, and receiving third parties
In the preceding 12 months we have disclosed the following categories of personal information for the business purposes indicated to the following categories of third parties:

  • CATEGORY OF PERSONAL INFORMATION DISCLOSED FOR A BUSINESS PURPOSE: Identifiers (include information such as name, address, email address, IP address)

    BUSINESS PURPOSES FOR DISCLOSING PERSONAL INFORMATION:
    - For advertising and marketing services;
    - Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, providing analytic services, and processing payments.

    CATEGORIES OF RECEIVING THIRD PARTIES:
    - Service Providers (such as analytic service providers, payment service providers, delivery companies);
    - Affiliates.
     
  • CATEGORY OF PERSONAL INFORMATION DISCLOSED FOR A BUSINESS PURPOSE: Personal Information Classifications (include details like name, signature, address, phone number, education, and employment history)

    BUSINESS PURPOSES FOR DISCLOSING PERSONAL INFORMATION:
    - For advertising and marketing services;
    - Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing analytic services, and hiring and retention services.

    CATEGORIES OF RECEIVING THIRD PARTIES:
    - Service Providers (such as analytic service providers, payment service providers, delivery companies);
    - Credit Reporting Agencies.
     
  • CATEGORY OF PERSONAL INFORMATION DISCLOSED FOR A BUSINESS PURPOSE: Commercial Information (includes records of Client Services, financial data, and payment information, excluding credit/debit card numbers and related credit/debit card data)

    BUSINESS PURPOSES FOR DISCLOSING PERSONAL INFORMATION:
    - For advertising and marketing services;
    - Providing analytic services to business or service provider.

    CATEGORIES OF RECEIVING THIRD PARTIES:
    - Service Providers (such as analytic service providers, payment service providers);
    - Affiliates.
     
  • CATEGORY OF PERSONAL INFORMATION DISCLOSED FOR A BUSINESS PURPOSE: Internet or Electronic Network Activity Information (includes data such as IP addresses, login information, browsing history on the Website, and interactions with other websites, applications or advertisements, search terms, uploads and downloads, the URL that referred you to the Website)

    BUSINESS PURPOSES FOR DISCLOSING PERSONAL INFORMATION:
    - Providing analytic services;
    - Debugging to identify and repair technology-related errors that impair existing intended functionality;
    - Helping to ensure the security and integrity of the Website;
    - To improve the user experience on the Website.

    CATEGORIES OF RECEIVING THIRD PARTIES:
    - Service Providers (such as analytic service providers, website hosts);
    - Affiliates.
     
  • CATEGORY OF PERSONAL INFORMATION DISCLOSED FOR A BUSINESS PURPOSE: Geolocation Data (includes information regarding IP addresses and device locations used to determine general geographic location)

    BUSINESS PURPOSES FOR DISCLOSING PERSONAL INFORMATION:
    - Helping to ensure the security and integrity of the Website;
    - To improve the user experience on the Website.

    CATEGORIES OF RECEIVING THIRD PARTIES:
    - Service Providers Service Providers (such as analytic service providers, website hosts);
    - Affiliates.
     
  • CATEGORY OF PERSONAL INFORMATION DISCLOSED FOR A BUSINESS PURPOSE: Sensitive Personal Information (such as Social Security, driver’s license, state identification card, or passport number, or account log-in, financial account, debit card, or credit card number with any required security code, password, or credentials allowing access to an account, or precise geolocation, or contents of mail, email and text messages unless Zegna is the intended recipient of communication, etc.)

    BUSINESS PURPOSES FOR DISCLOSING PERSONAL INFORMATION:
    - Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, and processing payments.

    CATEGORIES OF RECEIVING THIRD PARTIES:
    - Service Providers (such as payment service providers).

 

4) Your Rights under the CCPA
You have the right under the CCPA, to exercise, free of charge, the following rights:

a.    Right to Know. You have the right to request information about the personal information we have collected about you, including the categories of personal information, sources of collection, and the business purposes for collecting it.

You have the right to request information about the personal information we sold, shared or disclosed, including the categories of personal information, the categories of third parties to whom the information was sold, shared, or disclosed, and the business purposes for collecting, sharing or disclosing it. Additionally, you have the right to request specific pieces of personal information in a portable and structured format.

b.    Right to Correct. You can request the correction of inaccuracies in your personal information.

c.     Right to Delete. In certain circumstances, you have the right to request the deletion or de-identification of your personal information. However, please note that this right does not apply in specific situations, such as when the information is necessary to provide services, fulfill a contract, protect security and rights, comply with legal obligations, or engage in research or other lawful uses.

d.    Right to Opt-Out. You have the right to opt-out of the sale of your personal information or sharing of your personal information for the purpose of cross-contextual behavioral advertising. You may opt-out of sale or sharing of your personal information by clicking on this “Do Not Sell or Share my Personal Information”.

5) How to exercise your rights

  • To exercise your rights, described above, you can:
  • call the number 844-609-3462 from Monday to Friday from 9:00am to 9:00pm (EST, excluding public holidays); or
  • write to our Customer Care at the address customer.care@zegna.com;
  • contact us directly at privacy@zegna.com.

Please note that Zegna can deny a CPPA-related data access or data portability disclosure request if you already made such request twice within a 12-month period.

If you choose to contact us directly by phone or email, you will need to provide us with: (i) enough information to identify you; (ii) proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and (iii) description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

You may designate an authorized agent to exercise your rights outlined above in 4. If you utilize an authorized agent to exercise a CCPA right, the following proof that the agent has been authorized to act on your behalf will need to be provided:

  • Your written permission for the authorized agent to act on your behalf and separate verification of your identity; or
  • Proof that the authorized agent holds a power of attorney to act on your behalf pursuant to Cal. Probate Code §§ 4121--4130.

 

6) No Discrimination
If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us.

7) Security and Retention of Your Personal Information
We use reasonable and appropriate measures to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing undertaken and the nature of the personal information we collect.

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.

8) Do not track
Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. This Website does not currently respond to those signals.

9) Contact Us
If you have any questions regarding this California Privacy Addendum, and/or Zegna’s privacy and information practices, you can direct them to us by:

 

10) Conflicts
This Privacy Notice for California Residents is supplementary to and incorporated into our Privacy Policy. In the event of any conflict between this California Privacy Addendum and the Privacy Policy, the California Privacy Addendum shall prevail solely concerning personal information governed by California Privacy Laws.