Privacy Policy

Last Updated Dec., 2017
This Privacy Policy –provided for the purposes set out under sect. 13 of the Italian legislative decree of 30 June 2003 no. 196 (Italian Data Protection Code) and reflecting the privacy laws of those countries where we offer our Website services – describes the processing of personal data provided, or collected, on the sites where this Privacy Policy is posted (“Website”), whether or not you are registered on the Website. This Privacy Policy tells you also how we use your personal data collected for marketing purposes at our stores (and in addition to any privacy notice provided on that occasion) or in the occasion of special events. Please read it carefully.
This Website is owned and managed by GIADA S.p.A.
At GIADA, we recognize the importance of protecting the personal data of our customers (e.g. identification data, financial information such as, for instance, credit card numbers) and the information of the users of our Website(s). For this reason GIADA adopts specific policies and security measures to comply with applicable data protection laws and to protect your personal data.

GENERAL INFORMATION

a) Definitions
The term “personal data” is defined under the European Union Directive 95/46/EC concerning the protection of personal data and it means any information that relates to you and that could be used, either directly or indirectly, to identify you.

In this Privacy Policy, “we”, “us”, “our” and “GIADA” refer to GIADA S.p.A., an Italian company, with registered office in Via Sant’ Andrea 23, 20121 Milano Italy, VAT no. 05331910967 (“GIADA”), subject to the management and coordination of Redstone Haute Couture Co. Ltd., a Chinese company with registered offices in Shenzhen, and, if applicable, its local affiliate(s) in the country where the GIADA store collecting your information for the purposes described below and/or managing any direct customer service contacts with you (e.g. one of our regional headquarters identified by GIADA to care for our relationship with you) is located. “You” and “your” refer to a specific user of the Website, whether registered or not.

b) Controller
Unless otherwise specified in this Privacy Policy, the owner and the controller of the processing of personal data described in this Privacy Policy, for the purposes set out under the European Union legislation on data protection is GIADA.

c) Consent
By using the Website(s), uploading or providing any personal data to the Website(s) or GIADA, other than for career purposes, you accept and agree that your navigation data and/or personal data will be processed and disclosed by GIADA as described in this Privacy Policy and in the Cookie Policy (for more information about cookies, see section A.1 below), except for the processing for which we ask for your express consent pursuant to the applicable laws.

Indeed, you may be offered the choice to provide express consent for processing operations when so required by applicable laws, e.g. we may wish to analyze your interaction with us both online and at our stores, or also under specific circumstances (e.g. GIADA events), for tailored services and marketing purposes. In those events you will be free to consent to that specific processing operation and, if you click on the relevant available tick box, you agree to the collection, storing, transmission, disclosure and use of your personal data for that specific purpose as set out in this Privacy Policy or Cookies Policy.

d) Sharing of Your Personal Data
Without prejudice to other information about possible sharing of your personal data as set out in other sections of this Privacy Policy,

(i) we may use vendors, GIADA affiliates or other companies within Redstone Group to provide you the specific services available on the Website(s) depending on the services that you use; they will process your personal data as our processors based on contractual obligations to comply with our instructions to protect your data;

(ii) we may share your personal data with Redstone Haute Couture Co. Ltd., and other companies within Redstone Group, for them to centrally retain and host personal data as data controllers;

(iii) we may share your details in connection with a substantial corporate transaction, such as a merger, consolidation, asset sale, or in the unlikely event of bankruptcy. Where required by applicable law, a notice informing you of any such business transfer will be sent to you if you have previously provided us with your contact information;

(iv) we may also disclose information about our users, including contact information, where we have a legal duty to do so, including in response to court orders or legal process, and to comply with other legal obligations imposed on us;

(v) we may disclose information to protect and defend the legal rights, interests, and safety of the Website(s), the GIADA Division and/or Redstone Group and to protect the safety and security of users of the Website(s).

e) Minimum Age
GIADA does not accept registrations or orders submitted by, and will not knowingly collect or use personally identifiable data from, anyone under the age of eighteen (18) years, or age of majority in his/her country. If you are under this age, please do not register or proceed with the online purchase and ask an adult to proceed with the required procedures.

f) Applicability of Other Privacy Policies
If you are registered with other services of GIADA that do not expressly refer to this Privacy Policy, additional privacy policies and statements may apply to you, and this Privacy Policy does not replace any other privacy policy or statement that may be applicable to personal data collected or used by GIADA in relation to that specific relationship.

g) External Links to Other Sites
This Privacy Policy only covers websites that we own and control. It does not cover links from our Website(s) to other third party websites and any information collected by the parties who own and control those websites or their use of cookies. GIADA is not responsible for how other organizations collect, use, disclose, or secure the information that you provide them when you access third party websites; we strongly recommend that you refer to the specific privacy policy and cookies policy of the third party website as these may differ from our own, and contact the relevant organization if you have concerns regarding the way your personal information will be used on other websites.

h) Security
GIADA is committed to protecting your personal data. We have implemented physical, technical and organizational security measures to help protect your personal data from misuse, loss and unauthorized alteration. However, despite our best efforts to protect your personal data, including reviewing our security procedures against new technology, please be aware that no security measures (including security related to the Internet data transmission or storage) can be guaranteed to be infallible from access by unintended recipients. We want you to feel confident using our Website(s) but we cannot ensure or warrant the security of any information you transmit to us. By submitting your personal data you accept it and will not hold us responsible for any breach of security.

i) International Transfer Of Personal Data
Your personal data may be collected in your country, for instance in relation to your visits to our stores if you chosen to register with our GIADA Customer Database (see section Relational Marketing Activities), and subsequently transferred and stored to another country where our group of companies or vendors have their servers. This transfer is done in accordance with applicable law for the purposes set out in this Privacy Policy (e.g. to provide you with the services you may request or with tailored services in any of our stores globally in the world, to share your data with other companies within the Redstone Group or merely because the servers where your data is stored are located in third countries, especially China). The local privacy and data protection laws in those countries may not be equivalent to the privacy and data protection laws in your country of residence. We will take steps to ensure that your data is treated securely and in accordance with this Privacy Policy wherever in the world it may be transferred, which steps may include use of the standard contractual clauses for data transfers approved by the European Commission (i.e. specific mandatory contractual obligations to be entered into by the vendor/provider) and/or certification of the receiving entity with the U.S. Safe Harbor program, if applicable, or other legal bases, e.g. binding corporate rules, if deemed appropriate in the future.

In case of your registration with the GIADA Customer Database your information may be stored and processed in Italy and/or China.

When allowed in your jurisdiction, by using the Website(s) or providing us with your information for the purpose of this Privacy Policy, you fully understand and unambiguously consent to the transfer of the personal information across international borders in accordance with GIADA’s standard operations, including the collection, storage, and processing of such information in the United States of America.

l) Retention
We will retain your personal data only for the period of time necessary to fulfill the specific purposes for which the data were collected or further processed, if for compatible purposes.

m) Changes to the Privacy Policy
We may occasionally change this Privacy Policy, to, for example, comply with new requirements imposed by the applicable laws or technical requirements. We will post the updated Policy on our Website; we may also notify you in case of material changes and seek your consent to those changes, where required by applicable law. You are thus encouraged to periodically review this page.

The paragraphs below will provide you with more detailed information about how we may process your personal data and is intended to supplement the information contained in this General Information section.
A - Navigation on the Website

This section clarifies what information we may collect when you simply browse the Website(s), without being logged on the Website(s), and how we process such information.

Unless otherwise provided on the Website by means of specific actions required by you to comply with local laws, by accessing and using this Website, you consent to this section of this Privacy Policy.

We do not collect or process personal data to ensure your navigation on the Website; however, if you are logged on the Website (e.g. on our online shop), navigation information may potentially be combined with your personal data and, if you agreed to, be used to get to know you better and to enhance our services.

The GIADA staff or otherwise employed by GIADA, or any other entity of the GIADA Division engaged to carry out specific operations on the Website may process the information collected during your navigation on the Website(s) and/or provided by you when using the Website(s) and its services.

Cookies

This Website uses cookies. “Cookies” are small text files that are placed on your computer or mobile device by the Website and automatically collect some information that you do not provide directly.

We use them in order (i) to make the Website work, or work more efficiently and be more user friendly, and (ii) to obtain data for statistical purposes on the use of the Website (e.g. to find out what pages are visited and how often). If you use our Website, whether as a registered user or not, we may use cookies also to enhance your experience on the Website and to provide certain services that require the identification of the user’s path through the navigation pages.

For more information about our use of Cookies, pixel tags, flash cookies, and similar technologies, and your choices regarding the use of Cookies, please read our Cookie Policy.
B – CONTACT US & SIGN UP FOR OUR MARKETING COMMUNICATIONS
This section clarifies what information we may collect when you contact us and/or you request to receive our commercial communications, and how we process such information.

1. Contact Us

We may receive your personal data (mainly, your name and contact information) when you contact us for a specific reason, such has for technical assistance regarding navigation or the use of the online store. In this case, your personal data will be used by our staff in the GIADA department that is relevant to your request exclusively to manage your request and may be disclosed to our service providers, if necessary to manage your request and depending on its subject.

We may contact you for the above purposes by telephone call, email, postal mail, SMS or other means as appropriate.

2. Sign Up For Our Marketing Communications

Source of Personal Data
When you subscribe on the Website(s), or at our stores, to receive GIADA announcements and communications by e-mail you will provide us with your contact and identification details. The set of personal data is required in order to receive our communications. You can also choose to receive such marketing communications from us when you create an account in the 'my account' area of the Website.

Please ensure that your data is accurate and, in case of any change to the personal data that you have provided us, please timely write to GIADA (see contact details) or amend your information online, if you are also registered at ‘my account’, to enable us to keep your personal data updated.

How We Use Personal Data
Your personal data will be stored and used, primarily through automated processing, to keep you informed by e-mail about us and our products, services, promotions, as well as charity and cultural initiatives and/or social events organized or sponsored by GIADA.

How We Share Personal Data
Your personal data will be processed by our authorized staff, mainly in the marketing, relational marketing, information system and security departments. This may include persons within GIADA or any GIADA affiliates engaged to operate with these marketing communications.

We will not share your personal data with third parties for direct marketing purposes or sell your information. However, we may need to share your contact and identification details within the GIADA Division and Redstone Group and with our service providers (e.g. technical service providers) acting as our data processors, or with other third parties (e.g. select third party service providers that assist GIADA in providing an optimal customer experience or partners of initiatives and/or events sponsored by GIADA, and their technical service providers, such as organizations providing mailing services).

How You Can Opt-Out From Receiving Our Marketing Communications
At any time, you can tell us that you do not want us to use your details for the purposes of marketing, by writing to us (see contact details).

You can also opt-out from all future communications from us and withdraw your consent to receive electronic communications from us by using the unsubscribe link from any of our email communications.
C - REGISTERING

This section clarifies what information we may collect when you create your account on our Website(s), and how we process such information.

You may create your own account on the Website to use or facilitate the use of some of the services available on the Website, e.g. ‘wish list’.

Source of Personal Data and Mandatory Information
When you create your own account on the Website you will provide us your contact and identification details. You acknowledge that some of the information that you are asked to provide to complete the registration process is essential to complete the process and that failure or refusal to provide accurate information will prevent us from satisfying your request. Essential information is properly marked as such on the Website.

Additional information is optional and, if you provide it, we may use it to, for example, send you a special thought on your birthday.

You also acknowledge that, when you use some of the services provided on the Website, we will collect additional information connected to your online activity on the Website(s), e.g. products placed in your ‘wish list’, and your interaction with us, e.g. products placed in your shopping basket and not deleted before leaving our Website, or your preferences regarding the use of the Website functionalities.

Please ensure that your data is accurate and, in case of any change, to the personal data that you have provided us, please timely write to GIADA (see contact details) or amend your information online, , if you are also registered at ‘my account’, to enable us to keep your personal data updated.

How We Use Personal Data
We will not use this information for purposes other than providing you the services connected with your account, which may include specific services related to your possible online purchases, unless you agree to our use of your personal data also for enhancing your shopping experience online and in our stores (see Online Purchases and Relational Marketing Activities section). We may then combine your personal data related to your account with other information collected and use that information as described in the Relational Marketing Activities section.

Your personal data will be stored and used, substantially through automated processing.

How We Share Personal Data
Your personal data will be processed by our authorized staff, mainly in the digital, marketing, information system and security departments. This may include persons within GIADA or within other entities in the GIADA Division, and/or within Redstone Group engaged to assist with the management of your account.

We will not pass your personal data to third parties for direct marketing purposes and we do not sell your information. However, we may need to share your contact and identification details within the GIADA Division, the Redstone Group companies and with our service providers (e.g. technical service providers) acting as our data processors upon instructions of GIADA, or with other third parties if so required to manage your account and your choices about processing of your personal data and for storing and retaining data.
D - ONLINE PURCHASES
This section clarifies what information we may collect when you use our online shop, whether or not you are logged in as a registered user of our Website(s), and how we process such information.
When using our online shop you can access the service either as registered user (see section C – Registering) or as a ‘guest’.
Important Notice about the Controller
The personal data collected for the purpose of managing, administering and processing your online purchases on our Website is under the control of the vendor of the product (the “Vendor”). The Vendor may be required to process your personal data in accordance with the data protection rules applicable in the country where it is based. Nevertheless, except in case of any conflicting mandatory rule applicable in that jurisdiction, the Vendor is obligated to process your personal data according to the principles declared under this Privacy Policy.
GIADA will remain the controller for any other purpose described under this Privacy Policy.
Source of Personal Data and Mandatory Information
When you use our online shop you provide the Vendor with personal data including your name, mailing address, phone number(s), email address, and financial information (e.g. credit card details). In some jurisdictions the Vendor may be required by local laws to collect more information (e.g. your ID number); when this is required you will be informed that providing this information is mandatory to proceed with your purchase. Failure or refusal to provide accurate information when mandatory will result in the inability to process your request.
You acknowledge that some of the information that you are asked to provide to complete the order process is essential to completing that process and that failure or refusal to provide accurate information will prevent the Vendor from satisfying your request. In particular, essential information is properly marked as such on the Website. You may choose not to provide the Vendor with optional information and will still continue to successfully use and purchase from the Website.
Please ensure that your data is accurate and, in case of any change, to the personal data that you have provided to the Vendor, please timely write to the Vendor (see contact details) or amend your information online, if you are also registered at ‘my account’, to enable us to keep your personal data updated.

How We Use Personal Data
This information will not be used for purposes other than (i) to offer and manage the online operations for your submission of the order; (ii) to verify that the information provided for the transaction is complete, valid, correct, and clear of fraudulent markers; (iii) to process your order, and to deliver the products; (iv) to provide you any customer care related service, including returns or repairs; (v) to contact you, including communications by email, for any issue related to the management of your order or of your subsequent order-related requests; and (vi) to comply with mandatory accounting and tax requirements and other mandatory applicable legislations or the legitimate order of competent authorities.

If you agree to our use of your personal data for enhancing your shopping experience online and in our stores, we may also combine your personal data – especially your purchase history and information related to your interactions with us (no financial information will be used for this additional and optional purpose) – as described under the Relational Marketing Activities section.

Your personal data will be stored in secure databases on GIADA servers or on servers of our trusted service providers (e.g. hosting providers) acting as data processors and mainly through automated processing. Your personal data may be also used for statistical and market analysis, and may be processed in an aggregate form.

How We Share Personal Data
Your personal data will be processed by the authorized staff of the Vendor handling the online orders.
Some of the processing operations related to the online purchases are provided by Vendor’s trusted third parties based in Italy or in other countries, within or outside the European Union, including entities within Redstone Group supporting and technically operating the Website, shipping agents, entities providing services of data entry, customer care, banking and credit verification entities, consultants, as well as companies which carry out activities of storage and management of files.

The Vendor will not share your personal data with third parties for marketing purposes or sell your information. However, we may need to share your contact and identification details within the GIADA Division, the Redstone Group companies and with our service providers (e.g. technical service providers) acting as our data processors, or with other third parties if so required to manage your account and your choices about processing of your personal data and for storing and retaining data.

If you choose to be registered in the GIADA Customer Database, your personal data will be made available to GIADA and processed also according to section E below.
E - RELATIONAL MARKETING ACTIVITIES
This section clarifies what information we may collect, and how we process such information, when you voluntarily register with our relational marketing customer database (‘GIADA Customer Database’), at our stores by filling-in our registration card or online by selecting to agree to our analysis of your data and, if applicable, to our personalized marketing services and communications.

It is of primary interest to GIADA to constantly improve the services provided and anticipate your needs and expectations of our products and services in a way which is increasingly tailored and efficient. This goal changes constantly depending on the needs and expectations of the market and the different types of GIADA customers. Thus it is important for GIADA to find out more about its customers, by analyzing data related to their preferences for certain categories of products (either purchased or of interest), the frequency of their visits at our online shops or at our stores or their requests concerning the purchased items.

Optional Registration
Registration with the GIADA Customer Database is entirely optional; if you register with our database you agree to have your customer profile analyzed by GIADA and benefit from our ongoing enhancing services, and to receive our marketing communications, either tailored or not, and to benefit from specific customer services.

At any time, you can tell us that you no longer want us to use your details for profiling and/or marketing purposes by writing to us (see contact details).

Source of Personal Data and Optional Information
If you choose to register with our GIADA Customer Database at our stores, by filling-in our registration card, or online, by selecting to agree to our analysis of your data and, if applicable, to our tailored marketing activities, your personal data collected in relation to your use of our services on the Website(s), and/or when interacting with us or one of our business partners in-store, will be used by GIADA for the purposes described below. Such personal data are collected (for example when you make purchases or when you return or repair goods) in any of our stores in the world or when you submit your online orders; in many circumstances data will be collected through other entities of the GIADA Division or Redstone Group.

Should we carry out any specific campaign or survey to learn more about you and your lifestyle for the purposes below, it is at your sole discretion to provide us with that additional information requested. This campaign or survey will help us to offer you an increasingly comfortable shopping experience and, if you decide not to provide us such information, you will be able to continue to use all our services.

How We Use Personal Data
We will use your personal data:

(i) to analyze your preferences and habits and to anticipate your needs based on our analysis of your profile.
We may then combine your personal data – especially your preferences, interests, preferred GIADA store(s), purchase history, personal relationship – collected in different circumstances, e.g. online when you use our services or browse our Website, when you purchase our products on the Website and/or at our stores, when participating in our events and initiatives, or being in touch with our staff (e.g. in case of surveys or simply being assisted in your purchase experience) to analyze your behaviour, preferences and trends and to serve you more tailored assistance.
Your data are constantly enriched with information collected during your interactions with us, e.g. preferences for certain categories of products, frequency of your visits to our stores and our online shops;

(ii) to offer you our marketing services including
·to send you – by e-mail, postal mail, SMS, telephone and/or through other online channels (e.g. social media), based on your choices – our marketing communications about us and our products, services, promotions, as well as charity and cultural initiatives and/or social events organized or sponsored by GIADA, and to contact you for customer satisfactions purposes.
·if you have agreed to have your customer profile being analyzed by GIADA, we may send you communications tailored to what we believe may be of interest to you and to benefit from a more personalized sale service (e.g. recommended looks, dedicated sales assistant, etc.).
Data may be aggregated with other information related individually to you or to other customers with similar profiles and be used for statistical purposes.

Who Can Access Your Personal Data
Access to the GIADA Customer Database is allowed exclusively to authorized staff of GIADA.

By agreeing to be registered with the GIADA Customer Database you acknowledge that certain details of your personal data may be accessed, for the purposes set out above under this section E, by the staff members of any of our stores worldwide who have been properly authorized, instructed and trained to process your personal data according to very strict rules in order to ensure your privacy and the protection of your data from unauthorized uses and/or disclosures.

How We Share Personal Data
We may share your information, mainly for the delivery of our marketing communications, with other GIADA Division or Redstone Group companies or with our trusted service providers (e.g. providers of email and postal mail services, as well as digital marketing providers based in Italy, or in other countries, within or outside the European Union). All these companies will act according to GIADA’s instructions as data processors.

Retention Period
We will retain your personal data related to your profile for the maximum period allowed by the applicable laws; upon expiring of that retention period, your profiling data will be automatically deleted or made anonymous and used in such a way that is no longer possible to identify you.
CONTACT US – EXERCISE YOUR RIGHTS
If you have questions, comments, complaints or requests regarding this Privacy Policy or our privacy practices please send an e-mail to .

The legislation (including article 7 of the Italian Data Protection Code) protects your rights: you are entitled to ask us if we hold your data, what details of yours we hold, where we have collected them, how and why we hold or process them, to whom we have disclosed or may disclose them and details of the controller and/or of its processors. If you are able to establish that your data is not accurate, complete and up-to-date, GIADA must take reasonable steps to correct the data. You are also entitled to ask us to delete, anonymize or block the processing of your data in case of unlawful processing and, under certain legitimate circumstances (e.g. for relational marketing activities), you can also ask to stop processing your data, including opting out, free of charge, from any of our targeting activities if you ever opted-in.
If you have subscribed or agreed to receive our marketing communications you can opt-out at any time, free of charge, requesting the deletion of your data from the mailing list by following the unsubscribe link that you will find in any electronic communication or by writing to the Customer Relations Department c/o GIADA S.p.A.