PRIVACY POLICY FOR SITE MANAGEMENT AND MARKETING ACTIVITIES
The Ermenegildo Zegna Group is aware that the personal data of its customers are important and it therefore intends to inform and provide them with as much control as possible on how their personal data, collected through this website (the “Website”), are handled.
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").
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 a different type. 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. Please see in this respect our specific Cookie Policy;
(b) Registration and Services - any data that you have voluntarily provided (email address, personal details and information, password you gave filling-in the registration form of your Zegna personal account), 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 you possible career within Zegna.
(c) Social Log-In - Please note that using your social profile to log-in, some specific Data will be communicated by the Social Network you selected (such as name, surname, e-mail address and some other Data about you that are on the same Social Network). Therefore, we will ask you your approval Social to proceed before logging you to your personal account using the social log-in. Please also note that Social Networks may ask for feedback and information about the social log-in use. For more information, please refer to the Social Networks privacy policies
Facebook( https://www.facebook.com/about/privacy/update?ref=old_policy )
Google + ( https://policies.google.com/privacy )
(d) Marketing - by giving your express consent, you will allow Zegna to process your data for marketing purposes, namely, 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.
(e) Study of preferences - By giving your express consent, you will allow Zegna to process your data for analysing your spending habits and preferences, and enabling it to adapt its products and initiatives to your tastes and meet best your requirements.
(f) Communication to third parties - By giving your express consent, 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 the navigation as per Cookie - section 2 (a) above - and data collected with the social log-in as per section 2 (c) above).
With the exception of the data related to your surfing activity, ruled by our Cookie Policy, the data processing is based on:
- For the Registration and Services activities - as per point 2 (b) - the legal basis is the legitimate interest to provide the notes, general site services and the 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). The legal basis for the processing of working applications is the legitimate interest to evaluate the same for recruiting purposes.
- For Social Log-In, Marketing, Study of Preferences, Communication of data to third parties (as per sections 2 (c), (d), € and (f) 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 latter's personal data for the purposes of analysing user's habits, buyings 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’ behaviour.
Moreover, please note that as per Section 2 (a), with the user's express consent, Zegna can process personal data through an automatic means to study cookies in order to verify the navigation through the Website and too purpose products and services in line with the navigation.
5) How your personal data will be processed and storage period
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).
Personal data provided during the surfing activity and related to the surfing activity itself are kept for the period no longer than one year. Personal data processed to reply to the user or provide a service are kept as long as necessary for replying or providing the service. Personal data provided for the application activity are kept for the period necessary to evaluate the application. Personal data provided for profiling activities are kept for a limited period of time, no longer than 5 years, in order to allow Zegna to understand user’s preferences within the luxury sector, respecting his privacy and consent. Personal data provided for marketing activities are kept no longer than 5 years, also with reference to the specific sector of activity (luxury products) and considering the interest demonstrated by the clients to be updated on the products, events and runaways of Zegna. For more information, please contact the Privacy Officer.
6) Obligatory or voluntary nature of providing the requested data
With the exception of the data related to your surfing activity - the provision and collection of which are governed by our Cookie Policy - the provision on any other data collected through the Website for answering your requests, providing information, as well as for marketing purposes and for analysing 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.
7) Categories of recipient of personal data
Zegna communicates your data only as permitted by the law and as indicated below. Further to what indicated in point 2 (f). (namely the transmit of your personal Data to the other companies belonging to the Zegna Group or to its commercial partners by giving your express consent) and in point 2 (c). (namely the Social log-in) your data will be processed and disclosed to- (i) Zegna’s employees and consultants, , (ii) other companies of the Zegna Group, acting as data processors in order to carry out contractual activities and services - and (iii) 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.
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 defence against third party claims or charges, protect the security of its own 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.
Your data will not be disseminated and will be transferred abroad, also to non-UE countries - only and 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.
8) Data subject’s 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.
