CUSTOMER PRIVACY POLICY

Effective Date: 24/05/2024

1.  WHAT IS COVERED BY THIS PRIVACY POLICY AND DO OTHER POLICIES APPLY TO YOU?  3

2.  WHAT SPECIFIC TERMS APPLY TO YOU DEPENDING ON YOUR COUNTRY OF RESIDENCE?  4

3.  WHO COLLECTS & USES YOUR PERSONAL INFORMATION?. 5

4.  WHY DO WE COLLECT YOUR PERSONAL INFORMATION?. 6

5.  WHAT PERSONAL INFORMATION DO WE COLLECT?. 17

6.  WHEN DO WE COLLECT YOUR PERSONAL INFORMATION?. 20

7.  HOW DO WE COLLECT YOUR PERSONAL INFORMATION?. 21

8.  WHO ARE OUR THIRD-PARTY SOURCES?. 22

9.  SHOULD YOU ALWAYS SHARE YOUR PERSONAL INFORMATION WITH US?. 23

10.  FOR HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?. 24

11.  HOW DO WE PROTECT YOUR PERSONAL INFORMATION?. 26

12.  WHERE DO WE TRANSFER & STORE YOUR PERSONAL INFORMATION?. 27

13.  WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?. 28

14.  HOW DO WE ADDRESS THE PRIVACY OF CHILDREN?. 32

15.  WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION?. 33

16.  CAN THE PRIVACY POLICY CHANGE?. 37

17.  DO WE USE COOKIES OR OTHER ONLINE ADVERTISING TECHNOLOGIES?. 38

18.  HOW CAN YOU CONTACT US?. 42

APPENDIX 1 - Specific information for Australian residents ABOUT THE USE OF YOUR PERSONAL INFORMATION. 43

APPENDIX 2 - Specific information for residents of Qatar, Vietnam, China, Kuwait, SAUDI ARABIA, Mexico, Chile, South Korea OR AZERBAIJAN about the use of your personal information. 49

APPENDIX 3 - Specific information on text and instant messages for residents of the United States or Guam residents. 67

APPENDIX 4 – SPECIFIC INFORMATION FOR US RESIDENTS. 68

1. WHAT IS COVERED BY THIS PRIVACY POLICY AND DO OTHER POLICIES APPLY TO YOU?

This privacy policy covers situations where we, GINORI 1735, access, collect, store, process, use, disclose or transfer your personal information in paper or electronic form. It also covers situations where approved partners or other members of Kering use your personal information on our behalf.

In some cases, other policies apply to you. It may be the case when you use certain products or services, and in this event: 

• You will be notified of these other policies while using the products or services they apply to.
• Such policies will supersede this privacy policy unless they expressly refer to it.

This privacy policy does not cover products or services you might use as provided by other companies acting on their own account.

Our privacy policy does not extend to services provided by other companies acting on their own account, such as franchisees and licensees or when you share information through social media (WeChat, WhatsApp, Baidu, Kakao Talk, Facebook, Twitter, Instagram, etc.), or other online platforms owned and managed by other companies. These other companies have their own privacy policies in place, so remember that the way they use any personal information you give them will be subject to their rules and not ours.

Want to know more? You may be interested in the following sections of our Privacy Policy:

Who collects & uses your personal information?

With whom do we share your personal information?

What are your rights regarding your personal information?

2. WHAT SPECIFIC TERMS APPLY TO YOU DEPENDING ON YOUR COUNTRY OF RESIDENCE?

The protection of your personal information is an essential part of our activities. In order to provide you with a personalized experience, we will apply the data protection laws of your country of residence. This approach would also be consistent with consumer laws of the country of your habitual residence, and would hence allow us to better meet your expectations regarding the protection of your personal information.

If you are a resident of any of the following countries/regions, please make sure that you refer to the Annex containing specific information for your jurisdiction:

• If you are an Australian resident, please refer to Appendix 1 - Specific information for Australian residents about the use of your personal information to obtain information about the reasons for which we may process your personal information;
• If you are a resident of Qatar, Vietnam, China, Kuwait, Saudi Arabia, Mexico, Chile, South Korea or Azerbaijan, please refer to Appendix 2 - Specific information for residents of Qatar, Vietnam, China, Kuwait, Saudi Arabia, Mexico, Chile, South Korea or Azerbaijan about the use of your personal information to obtain information about the reasons for which we may process your personal information and the legal bases we may use;
• If you are a resident of the United States or Guam, please refer to Appendix 3 - Specific information on text and instant messages for residents of the United States or Guam residentsto obtain information about how and when we may use your phone number to send you messages;
• If you are a resident of California or of certain other US states, please refer to Appendix 4 – Specific information for U.S. residents   to obtain information about the categories of personal information we may use, the sale of your personal information and your rights over your personal information. 

3. WHO COLLECTS & USES YOUR PERSONAL INFORMATION?

We, GINORI 1735, active in the field of luxury, act as the “data controller”, which means that we determine “why” and “how” your personal information is collected and used. We are an Italian corporation, located in Viale Giulio Cesare n. 50, 50019 - Sesto Fiorentino (FI), Italy, and registered under number 05795200483 with the company registry of Florence.

To be able to deliver our products and services to you, we need to share your personal information with approved partners or other members of Kering who generally act as our “data processors”. All are bound by an obligation to implement appropriate security measures to protect personal information in their possession and are bound by a strict confidentiality agreement and specific contractual terms on “how” and “when” they are allowed to use your personal information on our behalf.

Please be aware that certain approved partners, such as our franchisees and licensees or social media, could also determine “why” and “how” your personal information is used. They have their own privacy and cookies policies, so remember that the personal information you give them will be subject to their rules and not ours.

Your local legislation may not refer to the terms “data controller” or “data processor”, but respectively to terms such as “data user”, “owner”, “business”, “responsible party”, etc., and as “data intermediary”, “operator”, etc. In order to understand our role, please note that we, GINORI 1735, are the entity who decides on the methods and purposes of the processing of your personal information by determining “why” and “how” your personal information is collected and used. Our “data processors” are entities who use your personal information on our behalf by receiving instructions from us on “how” and “when” they are allowed to use it.

Want to know more? You may be interested in the following sections of our Privacy Policy:

Why do we collect your personal information?

How do we collect your personal information?

With whom do we share your personal information?

What are your rights regarding your personal information?

4. WHY DO WE COLLECT YOUR PERSONAL INFORMATION?

GINORI 1735 will collect, record, hold, organize, structure, store, update, adapt, combine, consult, use, transfer and disclose your personal information for the purposes described in this section. Your personal information will not be further used for purposes incompatible or inconsistent with the purposes for which it was collected, unless permitted by the applicable legislation.

The processing of your personal information will comply with your privacy legislation and rely on the legal bases set out in this section. The legal bases listed in this section will also apply when we share your data with third parties (as listed in the section With whom do we share your personal information?) for the purposes mentioned below.

If you would like more information on the purposes and legal bases, you can contact us at [email protected] (or see How can you contact us?).

The processing of your personal information will rely on the legal bases set out below, unless you are a resident of one of the following countries:

• If you are an Australian resident, please jump to Appendix 1 - Specific information for Australian residents about the use of your personal information.
• If you are a resident of  Qatar, Vietnam, China, Kuwait, Mexico, Chile, Saudi Arabia, South Korea or Azerbaijan, please jump to Appendix 2 - Specific information for residents of Qatar, Vietnam, China, Kuwait, Mexico, Chile,Saudi Arabia, South Korea or Azerbaijan about the use of your personal information.

1. To provide you with the products and services you have purchased or otherwise requested

We will use your personal information to manage our relationship with you and to perform our obligations under the contract you conclude with us when you purchase or otherwise request products or services from us. This can cover various activities such as internal accounting, processing your payment or delivery.

To provide you with the products and services you have requested, we will access, collect, store, process, use, disclose and transfer your personal information for invoicing, payment management and internal accounting.

Some of the operations mentioned above can be implemented by partners of ours as identified in section “With whom do we share your personal information?” below, in particular the registration, payment and delivery of your order. Your information may be communicated, used or collected directly via the information system of our partner.

Certain specific information may be required to provide you with gift cards, customization services, or when you reserve a product or a service, request the repair of a product, or purchase products or services by phone, or on our website or a marketplace. In such cases, we could access, collect, store and use your personal information for delivery, warehouse and return management.

During your visit to our store, we may need to collect your information in order to allow you to access our premises or when you wish to obtain a particular service: request for tax on products or in connection with our after-sales service, etc.

2. To manage your GINORI 1735 profile.

Once you have requested us to create your GINORI 1735 profile, via GINORI 1735 websites or any other means, including our customer service, your personal information will be linked to this profile, where we will keep all the information we have on you. This could include personal information we obtain directly from you as well as from other sources in accordance with applicable legislation. This could also include information about the purchases made when checking out as a guest or when checking out using a profile. The information in your GINORI 1735 profile is crucial to provide you with the GINORI 1735 personalized and tailored experience, and in some cases is necessary in order to access to some specific services or to purchase from our website, and thus it needs to be kept up to date for the best experience.

Once you have asked us to create your GINORI 1735 profile, we will supplement it with personal information such as your purchases, preferences and contact details. In this context, please be aware that we use personal identification information, such as your email address or phone number, to link an interaction or a purchase with your GINORI 1735 profile. This also applies when checking-out as a guest on our website when making a purchase, as mentioned above, or in case you bind your social media open ID account with your GINORI 1735 profile (by using dedicated QR Codes for example). In addition, we may use your date of birth to determine that you are old enough to use our services.

In order to keep your personal information accurate, we will take every reasonable step to ensure that personal information we hold is properly updated. Subject to your applicable privacy legislation you may have the right to have your information rectified at any time, and in any event please let us know if any of your information needs updating or correcting, and we will make our best efforts to detect and correct inaccurate personal information (data cleansing) and delete any duplicated dataset. This may require us to correct typographical errors or inconsistent personal information.

3. To provide you with tailored customer service and assistance.

You should have the same unified experience no matter how we communicate. Whether this happens in our stores, on our website, by chat, by phone or by video, and whether you contact us or we contact you, we want to provide you with relevant and tailored customer service. 

For this purpose of providing you the GINORI 1735 experience, we will collect, store, process, use, disclose and transfer your personal information to be able to identify you. This will allow us to provide you with the tailored assistance you are asking for or to share relevant information with you. In addition, when you contact us, we may retain the personal information you share with us to always provide you with such a customised and personalised experience. This could happen if you are an existing or potential customer. Your personal information will be linked to your GINORI 1735 profile, if you have requested us to create one, or to a temporary record.

To provide you with a smooth and enjoyable customer experience, know you better to provide you with tailored answers, and to improve the quality and security of our services, we may rely on your consent, proceed in accordance with our contract with you, or take all reasonable steps to enter into a contract with you, or rely on our legitimate interest to improve our services.

We will use the information we have about you to try to identify you when you contact us (whether by phone, video chat, text message, chat, social media, etc.). When we can identify you, we will be able to access personal information available in your GINORI 1735 profile or in your temporary record, to know when you have previously interacted with us and to provide you with the tailored assistance you are asking for. This could include real-time or subsequent monitoring of your interaction with us (for example on our website or in a store) to identify the products you are looking at or what could be your specific need.

To provide you with adequate customer service, you may be asked if you need further assistance when you are on our website or in a store. On our website, if you do not want to be contacted, kindly close the chat navigation window. This service was implemented for you to enjoy the same service as in one of our physical stores.

If we are not able to identify you, we may create a temporary record to allow you to have a unified purchase experience. Indeed, however you interact with us, we will do our best to avoid asking you again for information you have already shared with us.

Your personal information, in particular your GINORI 1735 profile if you have created one or the temporary record we may create about you, could enable our sales associates to contact you directly in relation to the products and services you have purchased or otherwise requested, such as when a product becomes available again or when an order you have placed has been received in store, or to share with you any other information you have requested from us.

In addition, the monitoring of our interaction  enables us to improve the quality and safety of our services and to provide you with tailored answers.

All our customers are important to us. However, some of our customers and potential customers benefit from a more personalized experience due to the important relationship they keep with GINORI 1735. Our teams may need to collect and gather information on such customers or potential customers in order to identify personalities who correspond to the image and values of GINORI 1735 to offer them unique support. This may be the case when you participate in one of our selective projects or when our Sales Associates offers you to participate in events or contacts you for certain special occasions (for your birthdays or for a particular event of your life).

4. To enable you to receive relevant information and tailored marketing content.

You will receive information and updates about us either at your request (with your prior consent where required by law) or when we are authorised by law to send you such information and updates directly, for instance after a purchase. Such communication can be global or local, and may include updates about our products and services, notifications, invitations to events, offers, surveys, etc.]

Our communications will be customised and specifically designed to be of interest to you and will be updated with any new personal information linked to your GINORI 1735 profile. We will thus use your personal information to send you tailored communications or other customised advertisements or marketing campaigns. This use of your information includes some profiling activity.

If you are a resident of the United States or Guam, please also see Appendix 3 - Specific information on text and instant messages for residents of the United States or Guam residentsfor more information about how and when we may use your phone number to send you messages.

When you share your contact information with us, we may use this personal information to contact you through related communication channels (such as text message, MMS, e-mail, post, internet means, social media or telephone), with your consent where required. You can of course request us not to use a particular channel of communication or opt-out (unsubscribe) from it by applying the opt-out option that will always be shared with you. If you want to stop receiving communication from us via all communication channels, please send an email to [email protected].

As part of the GINORI 1735 experience, we will always try to customise and personalise your experience with us. This is why we will use your personal information to send you tailored communications or personalise your journey with us, but only with your prior consent where it is required under applicable privacy legislation. Our communications could include tailored product recommendations we think you might like, personalised marketing content designed to suit your interests, personalised events invitations or, at your request and where available, personalised and customised products. For these purposes, we will use the information you provide to us (for example your date of birth, your country of residence, your preferred means of contact, etc.) and/or jointly or independently, certain patterns we may observe when interacting with you (for example where you prefer buying our products, what type of products you like, which occasions you are shopping for, etc.). With this information, we may create groups of similar customers (called “persona”) to whom we can decide to offer personalised content and experiences both in inbound or outbound interactions. In this context, we may make inferences about you, as derived from your personal information (profiling). For example, if you always purchase our products from the same store (specific location or online), we may consider this store as your preferred one. This will allow us to customise your experience with GINORI 1735 based on your interests and shopping habits (i.e. tailored communication).In order to provide you with such customised and personalised experience, in our stores or online, you may be required to log in or identify yourself.

To enrich your personal information, we may use cookies or other online advertising technologies. Via such technologies, we will collect personal information related to your activities on social media and your browsing activity across different websites and devices (for example: to know if you have visited our website after opening a newsletter you have received). Certain technologies may rely on services provided by other companies acting on their own account (such as social media WeChat, WhatsApp, Baidu, Kakao Talk, Facebook, Twitter, Instagram, or other online platforms). These companies have their own privacy and cookies policies and the way they use the personal information you share with them will be subject to their rules and not ours.

Personal information linked to your GINORI 1735 profile (your identification personal information such as your e-mail address, phone number, social network id, etc.) will enable us to reach you on third-party platforms or to create “ lookalike campaigns”, allowing us to find new people who are likely to be interested in our products because they may be similar to you. We may conduct such campaigns through our website, social media or other communication means such as search engine. When this kind of campaigns are conducted, before it is shared, your personal information is hashed and turned into short fingerprints that cannot be reversed.

Using cookies or other online advertising technologies may also enable us to show you online advertisements that are “contextual” (meaning they are shown according to the webpage you are browsing), or “behavioural” or “interest based” (where advertisements are shown to you based on your interests which we have inferred from your information including demographic, geographic and interest-based data). We may use such advertisements to display products or services that are most relevant to you.

If you no longer want to see customised online advertisements, you may request us to delete your GINORI 1735 profile or modify your cookie preferences – see “cookies or other online advertising technologies”. In addition, some third-party sites allow you to stop seeing advertisements from specific advertisers, so you may also set your preferences on those websites.

5. To send you non-marketing communications.

Non-marketing communications may be sent upon your request, and/or may be important for your safety and the security of your personal information.

You may still receive such communications even when you opt-out from certain marketing communications. The information communicated may be necessaryfor the correct performance of our contract with you or be mandatory to comply with some of our legal obligations.

If you are a resident of the United States or Guam, please also see Appendix 3 - Specific information on text and instant messages for residents of the United States or Guam residentsfor more information about how and when we may use your phone number to send you messages.

Non-marketing communications can include, but are not limited to: emailing you to verify your identity when you sign up to our services; emailing you for password and/or username reset; notifying you that a particular service has been or will be suspended for maintenance or terminated; notifying you of an upgrade, a rectification or an incident affecting our services that may involve your personal information; notifying you of an update to our privacy policy or Terms of Use; or informing you about any products or services you have requested or purchased.

We will never contact you to ask for your password. Please be aware if you receive any request for this personal information.

6. To manage our social networks  

GINORI 1735 manages “Fan” pages available on several social networks. We may need to process the information made available by the different platforms or when you interact with our pages and publications.

When, as a user of a social media, you decide to interact with our social media pages (e.g. when you follow one of our pages, when you click "Like" on Facebook or "Follow" on Instagram or add a reaction to a post, when you "share" or add a "comment", etc.), we have access to public information in your profile. Your information is used for the purpose of interacting with you through the social network in question or to establish analyzes or statistics on the use of our pages or on the performance of our communications. Our services may remove your comments if they do not comply with our policies on the use of social networks (e.g. if your comments are insulting, illegal or malicious).

When you visit our “Fan” page, when you do not have an account or are not logged in to the relevant social network, we do not collect any personal information about you, except for the aggregated data provided to us by each social network.

7. To conduct our business securely and protect our activities and personnel.

To deliver our products and services safely to you, perform our contract properly or comply with some of our legal obligations, we will implement fraud prevention and detection measures. Such measures will allow us to adequately perform our contract with you and/or protect our legitimate interests in defending ourselves against fraud. We may notably implement measures to ensure that you are complying with our terms and conditions for sales, available in this website, offers and programs, and to prevent and detect non-compliance or fraud by you. This may include reviewing and assessing your dealings with us, your eligibility to participate in certain sales, offers and programs, your compliance with the terms and conditions of such sales, offers and programs, and undertaking enforcement action and/or disciplinary action where such non-compliance or fraud is suspected or identified.

We may use administrative and technical measures to protect, our website, our systems, our networks, transactions occurring on our website or in our stores, and any other necessary means to protect the personal information we may access or store. For this purpose, we may also be required to verify your identity or to take note of any suspicious or actual non-compliance with our terms and conditions or fraud we incurred with respect to your dealings with us. Such measures may also be implemented for compliance purposes or to avoid sharing your personal information with any untrusted third parties.

In addition, we may implement certain measures to protect and defend our rights and property, our employees and our business partners in compliance with applicable laws, regulations and international conventions. For example,we can monitor our inbound and outbound interaction with our customer service.

8. To assess and better understand our business.

To manage our activities, perform our obligations under our contract with you and comply with our legal obligations, we may need to access and use some of your personal information for finance, management or legal purposes, or business-related analytics & market research activities.

For example, this could occur when we use the invoices we have issued in relation to your purchases for compliance or accountability purposes, or when we analyse personal information to understand the characteristics of our customers (what is the gender proportion, the average age etc.).

In certain limited circumstances, such activity may be based on our legitimate interest when related to business analytics & market research activities

Certain activities which are required when conducting a business may involve the use of your personal information. This could include internal processes (such as finance control, accounting, stock management, production management, internal or external audit), certain legal obligations (for example, record-keeping or tax declaration), or analyses conducted in case of a merger or acquisition.

We may also conduct various business-related analytics & market research activities, which may require us to access or otherwise use some of your personal information, or to send you surveys or customer satisfaction questions in order to gather new or additional information. This notably enables us to analyse and learn how our customers use and interact with us in order to improve products, services and our business in general. It is also important for us to conduct operations that allow us to analyze and measure the performance of our marketing or communications campaigns. This may be the case, for example, when you click on one of our ads on our business partners website or when you make a purchase after viewing one of their ads. Please be aware that to do this, we may use cookies or other online advertising technologies.

1. To optimise and manage our website and other means of communication.

We may take certain measures involving the use of your personal information toadminister, optimise and improve our means of digital or physical communicationssuch as our website, our mobile application, or face-to-face interaction in our stores.

The use of your personal information will allow us to perform our contractual obligations or improve our services in accordance with our legitimate interest. Of course, when we use cookies or other online advertising technologies requiring us to do so, we will always ensure that we have duly obtained your prior consent.

We may use some of your personal information toadminister, optimise and improve our websites, our applications, our content and our other digital offerings, including the services and products offered through our websites, applications or any other digital means of communication to ensure the most user-friendly online navigation experience. We may use such personal information to fix operational problems such as pages crashing and software bugs. Please be aware that to do this, we may use cookies or other online advertising technologies.

5. WHAT PERSONAL INFORMATION DO WE COLLECT?

When you interact with us or our approved partners, you may provide us with the following categories of personal information (that may include sensitive information in accordance with applicable legislation).

If you are a resident of California or of certain other US states, please see the section “What personal information do we collect?” in Appendix 4 – Specific information for U.S. .

1. Identifiers & GINORI 1735 profile information

This set of personal information enables us to identify you, manage your GINORI 1735 profile, provide you with customer service and assistance and, in some cases, to contact you, including by sending you relevant information and tailored marketing content on the ground of the legal bases set out in this privacy policy.

The list below is provided to give you an overview of the type of information we may collect. However, the collection of this information is not systematic: only the information necessary to fulfill each purpose will be collected and used.

It could include, when your applicable privacy legislation allows us to collect such personal information, your first name, last name, pseudonym, signature, email address, postal address, date of birth, place of birth, login name, phone number, unique personal identifier, customer number, online identifier, social media accounts (and related information collected through social log-in), gender, country of residence, image (in case of videocall with our sale assistants), lifestyle/interests, Internet Protocol (IP) address, account name, social security number, state identification card, driver’s license number, passport number, nationality, or other similar identifiers, physical characteristics or description (for example characteristics such as your size where relevant to the products and services we would offer you), and certain personal financial information.

We will take steps to minimise information that is collected to what is necessary in relation to the purposes for which it is processed. In some cases, the creation of your GINORI 1735 profile will be mandatory in order to access to some specific services or to purchase from our website.

In some countries, some personal information could be considered sensitive, special or protected. We will collect and use such information only where no other option is available, and always comply with the applicable privacy legislation to collect, protect and use safely your personal information (in particular, by seeking your consent where required).

If you are an employee of a Kering entity, we may process certain information regarding your employment, and we invite you to refer to the employee privacy policy that has been made available to you.

2. Transaction information & commercial information (including audio)

This set of personal information enables us to provide you with the products and services you have requested, manage your GINORI 1735 profile, provide you with relevant customer service and assistance, secure our communications and to manage and better understand our business. 

The list below is provided to give you an overview of the type of information we may collect. However, the collection of this information is not systematic: only the information necessary to fulfill each purpose will be collected and used.

It could include personal information on the products and services you purchase, obtain or consider, their price, size, collection, when the product was bought, if it was returned, product defects, comments you made on the product or the service we have provided to you, purchasing and consumer histories or trends, etc. This could also include personal financial information relating to how you paid for your products or your bank details when you request a refund. We will take steps to minimise information that is collected to what is necessary in relation to the purposes for which it is processed.

Some personal information (including the reference number of the devices contained in the products you have purchased) will be linked to your GINORI 1735 profile when you identify yourself in the stores, through customer services or on our website. In addition, when contacting our customer service, we may record your conversation with prior notice to you.

Under certain applicable privacy legislation, particular transaction and commercial details are considered sensitive. We will collect, store and use such personal information with the highest level of care in accordance with the applicable legislation and with your consent where required.

3. Personal life information and inferences

This set of personal information enables us to always offer you the optimum service by understanding you better. We use it to manage your GINORI 1735 profile, provide you with relevant customer service and assistance and also, in certain circumstances, to contact you for example by sending you relevant information, updates and tailored marketing content.

The list below is provided to give you an overview of the type of information we may collect. However, the collection of this information is not systematic: only the information necessary to fulfill each purpose will be collected and used.

It could include your preferences regarding fashion events, how you have used certain products, food allergies when you explicitly choose to share this information with us, personal information regarding your relationships, including about your family members, your friends, or the people you send invitations to, for example if you indicate to us that you will offer them a gift or if you invite them to join a GINORI 1735 program (if you have obtained their consent to share such information with us, where this is required by applicable law), your life habits, how you use our website or third-party websites such as social media, your answers to our surveys or any other personal information we may collect when it is directly or indirectly linked to you. We may draw inferences from any of the information identified above to create a profile about you, reflecting your preferences, characteristics, trends, predispositions, aptitudes and attitudes.

Under certain applicable privacy legislation, some personal life information is considered sensitive. In this context, we will collect, store and use such personal information only where no other option is available and with the highest level of care in compliance with the applicable privacy legislation (including with your consent where required).

4. User-generated content

This set of personal information enables you to provide us with personal information relating to you or to third parties. In certain circumstances it enables us to contact you.

The list below is provided to give you an overview of the type of information we may collect. However, the collection of this information is not systematic: only the information necessary to fulfill each purpose will be collected and used.

It could include pictures of you (including the picture(s) taken with virtual try-on) or other individuals, or any other type of content such as texts, feedbacks, opinions, personal information regarding other individuals you may provide us with (for example when participating in a contest or sharing personal information with our sales associates or through social media), “tagging” or “liking” our social media page or any content published by us, or any personal information you may provide in the public domain. You may remove such content at any time if you no longer want us to use it.

You shall avoid sharing third-party personal information through such means or you should ensure that they have given prior authorisation to such sharing.

5. Technical, electronic & localisation information

This set of personal information enables better delivery of the service you expect from us.

It could include personal information related to your interactions with us and allows us to manage your GINORI 1735 profile, provide relevant customer service and tailored marketing content, establish communications and conduct our business securely, assess and better understand our business, and optimise and manage our website and other means of communication.

The list below is provided to give you an overview of the type of information we may collect. However, the collection of this information is not systematic: only the information necessary to fulfill each purpose will be collected and used.

This could happen in a store (e.g.  when a purchase is made in a specific store and then linked to a GINORI 1735 profile), or when contacting our customer services (why do you contact us? what means have you used?) or when using our website (do you use tablets, phones, computers? what use are you making of our website?).

Some personal information will be shared with us automatically from the device or the service provider you are using (e.g. social media). We can collect personal information shared by your device such as your IP address, device type, unique device identification numbers (device identifier), browser type, time zone settings, broad geographic location (e.g. country or city-level location); online activity (such as your internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements) and other technical personal information or personal information shared by the service provider. Such service providers have their own privacy and cookies policies, so remember that the personal information you give them will be subject to their rules and not ours.

In addition, we may be able to collect personal information on how you have interacted with us, including certain personal navigation information (including the pages accessed and links clicked, bugs and errors, browsing patterns) and your preferences (such as your language preference).

Some of this personal information may be collected using  cookies or other online advertising technologies.

Want to know more? You may be interested in the following sections of our Privacy Policy:

Why do we collect your personal information?

What are your rights regarding your personal information?

6. WHEN DO WE COLLECT YOUR PERSONAL INFORMATION?

When you interact with us, either online or in person, you may share with us your personal information when:

1. You buy a product or subscribe to a service;
2. You create a GINORI 1735 profile, join our loyalty scheme, participate in a contest, join a reward program or link your social media account to your GINORI 1735 profile;
3. You subscribe to our newsletter;
4. You interact with us or seek advice and share personal information through our websites, our social media pages, our sales associates in a store or via chat, phone or video calls, at a trade show, at events or through our customer services also through phone calls, or you book an appointment via our website;
5. You use your device to browse activity across different websites;
6. A personal shopper, or any other agent acting on your behalf interacts with us in particular to buy a product or subscribe to a service for you;
7. Your information is shared with us by our approved partners, with your prior consent where required.

Want to know more? You may be interested in the following sections of our Privacy Policy:

Why do we collect your personal information?

What personal information do we collect?

What personal information do we collect from third-party sources?

How do we collect your personal information?

What are your rights regarding your personal information?

7. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

We mainly obtain information directly from you and process them by automated means when you interact with us. When you interact with us, either online or in person, we collect your personal information through:

1. Our sales associates (in stores or via chat, phone or video call) or our customer services (for example by phone or chat) when you share personal information with us;
2. Our websites or our applications, whether you are registered or not, by completing surveys, registration processes or forms. We may also use cookies or other online advertising technologies for this purpose;
3. Any means we make available to you - for example, when you buy a product, we may collect certain personal information relating to your payment such as the purchase price and date and product reference (we do not keep any of your personal banking information for longer than necessary to complete the transaction);
4. From third-party sources such as social media.

More broadly, we collect your personal information through any means you may use to interact with our sales associates, whether in our stores or through our customer services via phone, email, chat or text message. Our sales associates or customer services may use various means to collect your personal information during or after the interaction.

In addition, we may obtain personal information from services provided by other companies to update or supplement your personal information, for example when you link your social media profile with your GINORI 1735 profile. These companies have their own privacy and cookies policies in place, so remember that the personal information you give them will be subject to their rules and not ours.

Want to know more? You may be interested in the following sections of our Privacy Policy:

Why do we collect your personal information?

What personal information do we collect?

What personal information do we collect from third-party sources?

What are your rights regarding your personal information?

Who are our third-party sources?

8. WHO ARE OUR THIRD-PARTY SOURCES?

We mainly obtain information directly from you. From time to time, we may also obtain information on you from third-party sources.

We will only gather such information when the third parties either have obtained your consent or are otherwise legally allowed to share such information. In certain limited circumstances, some third parties may be required to disclose your personal information to us.

For more information on our sharing of information with these third-party sources, please refer to the section With whom do we share your personal information?

Our third-party source categories could include:

1. Our retailers and distributors, as they can collect your personal information when you interact with them;
2. Our affiliates and subsidiaries;
3. Our event partners, as you can share certain personal information when you interact with them;
4. Social media in accordance with their own privacy policies;
5. Our technology partners and market research organisations;
6. Our business and approved partners;
7. Vendors who provide services on our behalf;
8. From your devices, such as when you visit our websites;
1. Your family or friends, such as when they provide us with your contact information, so we can send information that may interest you;
10. Online advertising companies;
11. Consumer reporting agencies;
50. Consumer data resellers (for example, in connection with online advertising);
1000. Enforcement or judicial authorities or any other public authority; and
14. Government entities.

Want to know more? You may be interested in the following sections of our Privacy Policy:

Who collects & uses your personal information?

Why do we collect your personal information?

What personal information do we collect?

What personal information do we collect from third-party sources?

What are your rights regarding your personal information?

With whom do we share your personal information?

9. SHOULD YOU ALWAYS SHARE YOUR PERSONAL INFORMATION WITH US?

You may not always be required to provide us with the personal information that we are asking you for: any personal information that is required is clearly marked as mandatory.

When you do not wish to share certain personal information with us, you may simply not provide it to us, or opt-out of the processing of your personal information when this option is offered to you.

However, if you choose not to provide certain personal information, you may not be able to benefit from some of our services or to purchase certain products for which the provision of such personal information is necessary.

We may ask you to provide us with personal information to meet certain legal requirements. In such cases, we will notify you in due time and advise you as to whether your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

Want to know more? You may be interested in the following sections of our Privacy Policy:

Why do we collect your personal information?

What personal information do we collect?

How do we collect your personal information?

What are your rights regarding your personal information?

10. FOR HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

We retain your personal information only for as long as it is needed to fulfill the purposes for which it was collected. Please see additional explanations below.

• • When you create a GINORI 1735 profile, we are retaining your personal information connected to such profile (as listed in the section WHAT PERSONAL INFORMATION DO WE COLLECT?) for 5 years from the last interaction you initiated with GINORI 1735; 
  • When you sign up exclusively to receive updates about GINORI 1735’s new activities, exclusive products, tailored services, we retain your personal information for 3 years from the last interaction you initiated with us;
  • When you interact with our customer services, we retain the recordings of the calls for 30 days (unless a longer retention period is permitted by law). When we are unable to link your interaction to your GINORI 1735 profile, we will retain the other personal information you share with us by e-mail, chat, text or instant message for 3 years after this interaction with GINORI 1735.

Please note the above retention rules will not apply in the following circumstances: (i) where we are legally required to retain your personal information for a shorter or longer period (in such a case, we will retain your personal information as long as this legal requirement is applicable); or (ii) in case of an actual or reasonably potential dispute (in such a case, we will retain your personal information until said dispute concludes).

 

Last interaction shall be defined as the last contact you initiated which is traceable by our systems or by one of our employee. Last contact could be the last time a call, sales email, short message, in-app message or meeting was proposed to you and to which you responded favorably. For instance, clicking on a link included in an email (except for a link to unsubscribe from receiving marketing content), having a chat on our website or attending an appointment in one of our stores are considered a last contact. Conversely, opening an email or visiting our website without logging in would not qualify as last contact. 

Before deleting your personal information from your GINORI 1735 or customer profile, we will contact you to inform you of such deletion and you may ask us to keep your personal information. By not answering you agree to the deletion of any personal information that we are not legally obliged to keep for longer in accordance with legal, tax and accounting requirements.

We will destroy your personal information without delay once it is no longer necessary (e.g., if the purposes of collection/use of the personal information have been accomplished, if the statutory retention period expires) in a way that prevents such personal information from being restored or recovered. If printed on paper, the personal information will be destroyed by shredding, incinerating, or some other similar methods and, if saved in electronic form, the personal information will be destroyed by technical methods which ensure that the personal information cannot be restored or recovered thereafter.

In case of an actual or reasonably potential dispute, we may also retain your personal information for longer according to the applicable statute of limitations so that we have an accurate record of your dealings with us in the event of any complaints or challenges.

It is also possible that certain information which we consider to be important for GINORI 1735 history or patrimony may be retained by us for longer periods exclusively for archival purposes, for historical purposes or for statistical purposes. This may be the case when some of our notable customers have benefited from our services or bought our products.

Additional information for South Korean residents:

We may retain certain personal information in accordance with the following legal requirements:

• Records on contracts and withdrawal of subscriptions: 5 years (as required under the Act on Consumer Protection in Electronic Commerce Transactions)
• Records on consumer complaints and processing of disputes: 3 years (as required under the Act on Consumer Protection in Electronic Commerce Transactions)
• Records of log-ins: 3 months (as required under the Protection of Communications Secrets Act)

Want to know more? You may be interested in the following sections of our Privacy Policy

Why do we collect your personal information?

What personal information do we collect?

What are your rights regarding your personal information?

11. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

We, GINORI 1735, are strongly committed to keeping your personal information safe.

To do so, we design our services with your safety in mind. Within our group, we have dedicated teams managing and ensuring the security and privacy of your personal information. We have adopted specific technical and organisational security measures, in accordance with applicable laws and regulations, to protect personal information against accidental or unlawful destruction, accidental loss, alteration, unauthorised disclosure or access.

For example, whenever personal information is passed between your device and our servers, we ensure that it is encrypted using Secure Sockets Layer (“SSL”) and/or other security methods. We implement Hyper Text Transfer Protocol over Secure Socket Layer (“HTTPS”) in order to protect your connection to our website. All your personal information is stored on secured servers.

We have also established a specialised personal information security management system. For example, we strictly control the scope of authorisation of our employees who have access to the personal information that we collect and process. We thus disclose or provide access to your personal information only on a strict need to know basis to our employees or to the third parties listed in the section With whom do we share your personal information?, and onlythrough secured systems. We regularly review our information collection, storage and processing practices, including physical security measures, to guard against any unauthorised access and use.

We conduct security and privacy protection training courses and tests on a regular basis to enhance our employees’ awareness of the importance of protecting personal information. We take commercially reasonable steps to make sure that our business partners and third-party service providers are able to protect your personal information. Our employees and those of our business partners and third-party service providers who have access to your personal information are subject to enforceable contractual obligations of confidentiality and specific contractual privacy provisions.

In the event of a security incident resulting in any breach of personal information, as qualified by law, we have an emergency response plan in place to prevent the expansion of such security incidents. In addition, we will report such personal information breach to the relevant supervisory authority as required by applicable law, and inform you via an appropriate channel as and where required by applicable law.

Please also note that in order to keep your personal information secure, we may from time to time, have to reset your password.

However, you should be aware that no service can be completely secure, and you play a key role in keeping your personal information safe. For the best possible protection of your personal information outside the limits of our control, your devices should be protected (e.g. by updated antivirus software) and your internet service providers should take appropriate measures for the security of personal information transmission over the network (e.g. with firewalls and anti-spam filtering). You accept the inherent security implications of interacting over the Internet and will not hold us or our partners responsible for any security incident or breach of personal information unless it is due to our negligence.

If you have any concerns that your personal information has been put at risk, for example if someone could have found out your password, please contact us as soon as possible.

Want to know more? You may be interested in the following sections of our Privacy Policy:

Where do we store your personal information?

What are your rights regarding your personal information?

12. WHERE DO WE TRANSFER & STORE YOUR PERSONAL INFORMATION?

We operate globally and may transfer your personal information to other companies within Kering or to approved partners in locations around the world. We want you to have the best service and customer experience, whether online or in person all over the world. For this purpose, we may have to share your personal information outside the country where you have first shared it with us. When we do so, it will always be for the purposes described in this privacy policy and where we are satisfied with the levels of protection and security implemented in compliance with applicable privacy legislation. This sharing of your personal information is necessary to enable us to perform the contracts we have with you or take steps at your request, prior to entering into a contract, in order to offer you a global customer experience.

The personal information we collect from you will be mainly stored in servers located in the European Union, United States and Switzerland, where it will be afforded the level of protection required by applicable privacy legislation. However, this may vary depending on the country in which the information is collected or applicable legislation. For more information about the location where your personal information is stored, you can contact us at [email protected] (or see How can you contact us?)

You should be aware that personal information stored outside the country where it was collected may be available to government authorities of the countries where it is stored, under applicable data disclosure laws of those countries.

We want to ensure that your personal information is always safely used and available to you, wherever you want to access it and for whatever reason you wish to use it.

When we share, use, or transfer personal information outside the country in which the information is collected, we will put in place appropriate measures to legitimize such transfer under applicable privacy legislation, which may include, as applicable, obtaining your consent or implementing adequate contractual safeguards. In particular, if we transfer your personal information from the European Union or Switzerland to a country for which no adequation decision has been adopted by the relevant authorities, we use standard contractual clauses approved by the relevant authorities (such as European Commission). You can contact us at [email protected]  (or see How can you contact us?) for more information about thesesafeguards including how to obtain copies of this information.

Want to know more? You may be interested in the following sections of our Privacy Policy:

What personal information do we collect?

How do we protect your personal information?

What are your rights regarding your personal information?

13. WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

Wemay share and disclose your personal information for business purposes with the categories of recipients listed below. We may also receive personal information about you from some of them as our third-party sources. The processing of personal information by such third parties relies on the legal bases listed for the relevant purposes in the section Why do we collect your personal information?(or the relevant appendix for your jurisdiction). If you would like more information about the sharing of your personal information, including the list of recipients, please contact our privacy team and Data Protection Officer at [email protected](or see How can you contact us?)

1. Approved partners acting as service providers   

To use your personal information, we rely on approved partners. All approved partners are bound by an obligation to implement appropriate security measures to protect personal information in their possession, and bound by a strict confidentiality agreement and specific contractual provisions on “how” and “when” they are allowed to collect and use your personal information. Your personal information may be accessible to the following authorised personnel on a need-to-know basis:

• Kering and other affiliates of our group   

Our parent company Kering and its affiliates are our main approved partners. They will have access to your personal information but will never use it in contradiction to this privacy policy.

Kering and its affiliates enable us to: offer you our products and services (e.g. via wholesale management and sales processes); provide you with our customer service (e.g. responding when you contact us by phone, mail, text message, chat or social media); manage your GINORI 1735 profile (e.g. by keeping your information safe and performing IT-related functions attached to your GINORI 1735 profile); and, through shared services, to manage and better understand our business.

• Retailers (including online), resellers, franchisees, licensees, delivery providers, fulfilment companies and transaction partners

These partners mainly enable us to provide you with the products and services you have requested (e.g. ensuring your bank can proceed with payment, or delivering a product you have purchased on our website).

For sake of clarity, please note that such partners also carry out processing activities in parallel for their own purposes, acting then as data controllers (see Approved partners acting also on their own account below). In this respect, our privacy policy does not extend to the processing activities carried out by these partners where the latter are acting on their own account, as data controller for the performance of their services.

This can be the case when payment services provider carries out fraud detection processes. These other companies have their own privacy policies in place, so remember that the way they use any personal information you give them will be subject to their rules and not ours.

They can also be involved in creating and/or managing your GINORI 1735 profile (e.g. collecting your personal information and consent on our behalf so that we can set up your profile, linking your purchase to your GINORI 1735 profile so you can easily find it again, or providing your personal information when you access your GINORI 1735 profile).

• Marketing services, advertising providers, communication (email, SMS, MMS) providers

They help us manage your GINORI 1735 profile, provide you with relevant information, updates, and tailored marketing content (e.g. by sending you emails based on your previous purchases or on sweepstakes, contests and advertisements you have browsed), and send you non-marketing communications. We may also use postal delivery providers. They enable us to send you any communication and marketing content (e.g. letters and event invitations).

• IT service providers

These partners enable us to:

• Provide you with the products and services you have requested (e.g. by managing our e-commerce website and our applications, etc.) and manage your GINORI 1735 profile (e.g. by making sure it is available at any time when you interact with us, and linking your purchases to it);
• Provide you with relevant customer service (e.g. by allowing you to use chat services);
• Send you relevant information, updates and marketing content (e.g. by sending you tailored emails, SMS, MMS, chat messages etc.);
• Send you non-marketing communications (e.g. by emailing you to verify your identity when you sign up);
• Undertake transactions securely (e.g. by identifying potential behaviour that could be a threat to your personal information or guarding against third-party misuse of your payment details to purchase products);
• Assess and better understand our business (e.g. by providing personal information visualisation tools); and
• Optimise and manage our website and other means of communication (e.g. by ensuring that our website is always available based on your browsing habits).

• Audit, law firms and similar corporate professional service providers, data analysis providers

These partners enable us to better understand and conduct our business (they include accountants, lawyers and auditors who may need to use your personal information). In addition, data analysis providers may enable us to provide you with relevant information, updates and marketing content (e.g. by analysing your answers to a survey, providing insights and helping us to analyse trends and improve our products and services).

2. Approved partners acting also on their own account  

To use some of your personal information (see “Why do we collect your personal information”), we rely on approved partners. Certain approved partners may be able to determine “why” and “how” your personal information is used.

• • • Social networks

We manage our fan pages on the social networks listed below, a social network operated by our services. We use our fan pages to inform our community about our company, our products, our services and our offerings, as well as about current developments and to communicate with our users. You can send us messages, as well as share, comment or "like" our messages. We process the profiles of users of our products and services (in particular the user's name) and our interactions with them (for example the content of messages or comments) to process the information requests they submit and respond to their questions. The legal basis for such data processing is the provision of the services requested by the user concerned on social network, or if your country of residency doesn’t acknowledge the performance of a contract as a valid legal basis, then please consider that the actual legal basis is your consent when interacting with us via our social networks.

We may also use statistical functions provided by social networks on how our users use our fan page. These data statistics are based on personal data collected during a user's visit, or on the user's interaction with our content. Our legitimate interest in this regard is the improvement and optimization of our fan page, which is also in the interest of our users, or if your country of residency doesn’t acknowledge legitimate interest as a valid legal basis, then please consider that the actual legal basis is your consent when interacting with us via our fan page.

Lastly, social networks enable us to provide you with relevant information and updates, marketing content (e.g. advertisements based on look-alike profiles) and relevant customer service (e.g. when you use social media to contact us). Please be aware that they have their own privacy and cookies policies in place, so the personal information you give them will be subject to their rules and not ours.

• Retailers (including online), resellers, franchisees and licensees

Certain points of sale, carrying out their business under the GINORI 1735 name, may act as independent data controllers and are able to determine “why” and “how” they use the personal information you share with them. Please be aware that our privacy policy does not extend to services provided by other companies on their own account. They have their own privacy policies in place, so remember that any personal information you give them will be subject to their rules and not ours.

3. Actual or potential buyers as part of a business transfer

We may disclose your personal information to an actual or a potential buyer (and its agents and advisers) in relation to any actual or proposed divestiture, merger, acquisition, joint venture, bankruptcy, dissolution, reorganisation, or any other similar transaction or proceeding in compliance with applicable laws and regulations. Where this is required, we will take steps to minimise any data that is shared.

4. Law enforcement body, regulatory body, government agency, court, lawyers to comply with laws and defend our rights and interests

We may disclose your personal information to any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is (i) required as a matter of applicable law or regulation, (ii) necessary to exercise, establish or defend our legal rights, or (iii) necessary to protect your interests or those of any other person, and on the legal basis set out in this privacy policy.Where this is required, we will take steps to minimise any data that is shared.

5. At your request or for our legitimate interest or compliance with laws and regulations 

We may disclose your personal information to any other person: with your consent; where we have an overriding legitimate interest (on balance with your interests) to do so; or where we have a legal or regulatory obligation to do so.

Want to know more? You may be interested in the following sections of our Privacy Policy:

Why do we collect your personal information?

What personal information do we collect?

What are your rights regarding your personal information?

Can the privacy policy change?

Do we use cookies or other online advertising technologies?

14. HOW DO WE ADDRESS THE PRIVACY OF CHILDREN?

Protecting the safety and privacy of children is very important to us.

By creating your GINORI 1735 profile, or by registering through any means, or by placing an order, you confirm that youhave reached the age of consent in your country of residence (or, if you are under the age of consent, that your parent(s) or legal guardian(s) also agree(s) to such registration or order when they can give you such authorization under the law of your country of residence). 

If we become aware (including through a request from your parent(s) or legal guardian(s)) that we have inadvertently received personal information in contradiction to the above, we will delete such personal information from our records.

If you are a minor, and have created a GINORI 1735 profile, we may collect the categories of personal information mentioned in the section What personal information do we collect?, and use your personal information for the purposes listed in the section Why do we collect your personal information?, unless prohibited by applicable laws. You, or your parent(s) or legal guardian(s), when permitted or required under the laws of your country of residence, may exercise over your personal information the rights listed in the section What are your rights regarding your personal information?

Want to know more? You may be interested in the following sections of our Privacy Policy:

Should you always share your personal information with us?

For how long do we keep your personal information?

How do we protect your personal information?

Where do we store your personal information?

What are your rights regarding your personal information?

15. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION?

Subject to your applicable privacy legislation, you may be entitled to one or more of the following rights and exercise them on your own or via a legal representative acting on your behalf. We,GINORI 1735, are committed to protecting your rights and allowing you to exercise them. You will never be discriminated against when you exercise your right in good faith under any applicable privacy law.

If you need any further information regarding your rights, how to exercise any of your rights, or if you have any complaints or questions regarding our privacy practices, please contact our privacy team and Data Protection Officer at [email protected] or by completing the form available here (or see How can you contact us?).

If you are a resident of California or of certain other US states, please see the section “What personal information do we collect?” in Appendix 4 – Specific information for U.S. .

1. Right of access, rectification and erasure

Under certain circumstances you may have the right to request access to and obtain a copy of any of your personal information that we may hold. Such right of access also includes the right to receive information in particular about the purposes of the processing, the categories of personal information concerned, the categories of recipients to whom your information may be disclosed, and the envisaged period for the retention of your information.

You may also request correction of any inaccurate personal information relating to you and to request the deletion of your personal information. You can see and update most of this personal information yourself online, or by contacting our customer services, or by emailing our privacy team at [email protected] or by completing the form available here(or see How can you contact us?).

Specifically, subject to your applicable privacy legislation, your right of access may include:

1. • the right to request whether and how your personal information is processed and whether it has been shared with a third party in the preceding 12 months, in particular if you are an Aruban resident.
   • the right to obtain information about the existence of your personal information in our information system, the owner or operator of your personal information, the sources from which your personal information has been obtained (and proof of the legality of the method of collection of such information), the purposes, timing and methods of processing of your personal information, including the persons who may have access to such information and the information systems with which your personal information may be exchanged, the legal justification for and legal consequences resulting from the collection, processing and transfer to third parties of your personal information, and where applicable the existence of a compliance certificate and completion of the state examination of the information system in which your personal information is recorded, in particular if you are a resident of Azerbaijan.
   • the right to obtain confirmation that we process personal information about you, to request information about the public and private entities with whom we have shared your personal information, and to request information about the possibility of denying consent and the consequences of such denial, in particular if you are a Brazilian resident.
   • if we cannot satisfy your request for correction, the right to request that a statement of correction be attached to your information noting that a correction has been sought but not made, in particular if you are a resident of New Zealand.
   • the right to be informed of any disclosure of inaccurate personal information about you, in particular if you are a resident of Qatar.
2. Right to withdraw consent

Where processing of your personal information is based on your consent, you have the right to withdraw it at any time. For example, if you no longer wish to receive electronic marketing communications, you can change the settings in your GINORI 1735 profile, use the ‘unsubscribe’ link provided in our emails, text the STOP number in our text messages, or contact us directly and we will stop sending you communications. Please note that the withdrawal of your consent will not affect the lawfulness of processing based on your consent as carried out before such withdrawal.

If you are a resident of the United States or Guam, please also see Appendix 3 - Specific information on text and instant messages for residents of the United States or Guam residents.

3. Right to personal information portability

Under certain conditions, you may have the right to receive personal information you have provided to us within a structured, commonly used and machine-readable format, and also to require us to transmit it to another data controller where this is technically feasible.

4. Right to restriction of processing

Subject to privacy legislation applicable to you, you may have the right to restrict our processing of your personal information in particular where: 

• • you contest the accuracy of the personal information (until we have taken sufficient steps to correct or verify its accuracy); 
  • the processing is unlawful, but you do not want us to erase the personal information;
  • we no longer need your personal information for the purposes of the processing, but you require such personal information to establish, exercise or defend legal claims; or 
  • you have objected to processing that has been justified on legitimate interest grounds, pending verification as to whether we have compelling legitimate grounds to continue processing.

Where personal information is subject to restriction in this way, we will only process it with your consent or to establish, exercise or defend legal claims, in accordance with local legislation.

Specifically, subject to your applicable privacy legislation, your right to restriction of processing may include:

4. • the right to apply for the transfer of your personal information to an archive, and the right to demand a ban on the collection and processing of your personal information, in particular if you are a resident of Azerbaijan.
   • the right to request the anonymization, blocking or deletion of any unnecessary or excessive personal information or personal information processed unlawfully, in particular if you are a Brazilian resident.
   • the right to request us to stop transferring your personal information to a third party, in particular if you are a Vietnamese resident. 
5. Right to object to processing

Where we rely on legitimate interest to process personal information, you may have the right to object to that processing. In this case, we must stop using your personal information for that purpose unless we can either demonstrate compelling legitimate grounds for processing that override your interests, rights and freedoms or where we need to process the personal information in order to establish, exercise or defend legal claims. Where we rely on legitimate interest as a justification for processing, we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.

Where your personal information is processed for direct marketing purposes, you may also have the right to object to this at any time. This includes profiling to the extent that it is related to such direct marketing. For example, if you wish to object to receiving electronic marketing communications, you can change the settings in your GINORI 1735 profile, or use the ‘unsubscribe’ link provided in our emails, or text the STOP number in our text messages, or contact us directly and we will stop sending you communications.

If you are a resident of the United States or Guam, please also see Appendix 3 - Specific information on text and instant messages for residents of the United States or Guam residents.

6. Deceased person rights to privacy

To exercise rights on behalf of a deceased individual, you may be required to provide us with proof that you are an immediate family member or executor of the deceased person. Subject to applicable privacy laws, we may not be able to support your request. Please be informed that under certain laws (for example in France), you can define directives relating to the storage, erasure and communication of your personal information after your death.

7. Right to lodge a complaint

You also have the right to lodge a complaint with your local supervisory authority if you consider that the processing of your personal information infringes applicable law.

If you are a resident of a Member State of the European Economic Area, you may refer to the list of data protection authorities in the European Economic Area available here. If you are a resident of Qatar, you may contact your data protection authority, the Compliance and Data Protection (CDP) department, through the channels listed here.

Under applicable legislation, you may have the right to bring complaints relating to the processing of your personal information before civil courts..

8. Modalities of response to your requests, additional information or assistance

If you need any further information regarding your rights or how to exercise any of your rights, or if you have any complaints or questions regarding our privacy practices, please contact our privacy team and Data Protection Officer at [email protected] or by completing the form available here(or see How can you contact us?).

To help protect your privacy and maintain security, we will take steps and may require you to provide certain information to verify your identity before granting you access to your personal information or complying with your request.

Where permissible under applicable law, we reserve the right to charge a fee for instance if your request is manifestly unfounded or excessive, to cover the administrative costs incurred by your request. We will endeavour to respond to your request as soon as possible and in any case within the applicable timeframe.

In certain countries (such as if you are a Californian resident), if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the person whose personal information is the subject of the request. 

If you designate an authorised agent to make an access, deletion or opt-out of sale request on your behalf (a) we may require you to provide the authorised agent written permission to do so, and (b) for access and deletion requests, we may require you to verify your own identity directly with us.

Want to know more? You may be interested in the following sections of our Customer Privacy Policy:

Who collects & uses your personal information?

How do we protect your personal information?

Where do we store your personal information?

With whom do we share your personal information?

16. CAN THE PRIVACY POLICY CHANGE? 

We may occasionally make changes to this privacy policy, for example to comply with new requirements imposed by applicable laws or technical requirements. We will post the updated privacy policy on our website. We therefore encourage you to review this page every so often.

We may also notify you in case of material changes and, where required by applicable law, we will seek your consent to those changes.

If we wish to process your personal information for a new purpose not described in this privacy policy, where necessary we will inform you and where required we will seek your consent.

Want to know more? You may be interested in the following sections of our Privacy Policy:

What is covered by this privacy policy?

Who collects & uses your personal information?

What are your rights regarding your personal information?

17. DO WE USE COOKIES OR OTHER ONLINE ADVERTISING TECHNOLOGIES?

We use cookies to personalize content and ads, to provide social media features and to analyze our traffic data. We also share information on your use of our site with our social media, advertising and analytics partners. You can read more about any of our purposes or the vendors that we use by clicking on ‘Cookie Settings.’ This preference center is accessible at any time through the ‘Cookie Settings’ button located on every page.

When you visit any website or use an application, it may store or retrieve information using your browser, mostly in the form of cookies. This information might be personal information about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience. Because we respect your right to privacy, you can choose not to allow some types of cookies.

At any time, you have the option to accept or decline the use of cookies using the on/off settings of the preference center, by clicking on the button below:

Cookies Settings

1. What is a cookie?

A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to place on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and are called first party cookies. We also use third-party cookies – which are cookies from a domain other than that of the website you are visiting – for our advertising and marketing initiatives.

2. Why do we use cookie?

Cookies are usedfor various purposes, such as allowing the user to navigate between pages seamlessly, implementing the user’s preferences and improving their overall browsing experience, by customising the content according to their navigation and user profile as a GINORI 1735 customer. They can also help ensure that the adverts seen online by the user are more relevant to them and their interests. 

3. What types of cookies do we use?

We use several types of cookies which have different durations. In particular we use: 

• • Session cookies, which only last for the duration of a browsing session and facilitate your experience on our website; and
  • Persistent cookies, which last for more than one visit and memorise your preferred settings regarding our website.

These cookies can also be categorised as follows, depending on who sets them:

3. • First party cookies, which are supplied by the publisher of the website you are visiting, so that it functions properly.
   • Third party cookies, which are set on the website by third parties, and are intended to collect data in different ways and for several purposes, for example: collection of analytics data and information on social interactions and behaviours, and also for promotional activities.
4. What categories of cookie are on our website? 

The types of cookies used on our website serve different purposes and can fall into one of the categories below. Please to the Preference center to see what type of cookies is relevant.

Strictly necessary cookies

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you that amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. This allows us to authenticate and record your sessions, to secure traffic or to detect certain malicious activities. For the website, you can set your browser to block or alert you about these cookies, but some parts of the website will then not work. These cookies do not store any personally identifiable information.

Performance & analytics cookies

These cookies allow us to collect behavioral data and determine traffic sources, so we can

• Measure the traffic on the website. They help us to find out which pages are the most and least popular and see how visitors move around the website by distinguishing users and sessions, determining new sessions/visits and counting the number of pages viewed in the current session and the recording type. We will also track the traffic source or campaign that explains how you reach our website, via which partners for example, to measure the impact and the effectiveness of our partnership with other merchants or our advertising campaign.
• Understand by who and how our site is used. Performance and analytics cookies are also used to rationalize traffic counting and user behavior across several platform integrations. They allow us to store visitor custom variable information, test different versions of our website or our content, and allow third-party providers helping us analyze and optimize our content.

In order to obtain accurate analytics while enabling you to make your choice regarding the use of cookies and other tracking tools, we've implemented a dedicated solution allowing us to record and counting your preferences. If you prefer not to be tracked, this system will help us complete our analysis and reports by looking at other users similar to you. This information doesn't let us know who you are or keep tracking your browsing on our website.

Functionality cookies

These cookies enable the personalization of website content by recognizing you and remembering your preferences. 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, some or all of these services may not function properly.     

Profiling and targeting cookies

These cookies may be set through our website by us or our advertising partners. They may be used to build a persona based on your navigation and your interests to personalize your experience by providing adapted content, features and products or show you relevant advertisements on other sites. We may also use the information collected through these trackers to push advertisements, on partners' websites or social networks, to people who can share the same interests as you.

They do not directly store personal information but are based on uniquely identifying your browser and devices.

 If you do not allow these cookies, you will experience less targeted advertising.

Social cookies

These cookies are set by a range of social media services that we have added to the site and which enable you to share our content with your friends and networks. They can track your browser across other sites and build a profile based on your interests. This may influence the content and messages you see on other websites you visit. If you do not allow these cookies, you may not be able to use or see these sharing tools.

Chat feature cookies

These cookies are necessary for the activation of the chat functionality allowing us to locate you, to put you in contact with our teams and to give you the possibility of exchanging with us (via chat or video calls). This use will be associated with a monitoring of your experience on the site (including a live monitoring of your navigation on our site or mobile application) allowing us to assist you as best as possible and to recommend the products that best meet your expectations and preferences. If you do not accept these cookies, the chat functionality will not be accessible.

5. How to customize your cookie settings

When you first visit our website, you are required to accept or decline the use of cookies before proceeding. At any time, you have the option to accept or decline the use of cookies using the on/off settings of the preference center, by clicking on the ‘Cookie Settings’ button located on every page:

Because we respect your right to privacy, you can choose not to allow some types of cookies by using our Cookie Settings. Click on the different category headings to find out more and to change our default settings. Please note that blocking some types of cookies may affect your experience of the site and the services we are able to offer.

If you prefer, you can set your browser to reject cookies.  If you use multiple browsers (e.g. Internet Explorer, Microsoft Edge, Google Chrome, Firefox, etc.), you must repeat this procedure for each one, and if you connect to the web from multiple devices (e.g. from work and at home), then you will need to set your preferences on each browser on each device.

Please note that if you completely disable cookies from the browser, some of the functionalities might be lost, for example, normal browsing of the site and purchasing activity, while any personalised activity such as the advertising you receive when you visit this website will not be tailored to your interests.

For more information on third-party cookies (e.g. advertising or targeting cookies) and how to disable them directly from the browser instead of through Cookie Settings , we invite you to read the relevant privacy policy and opt-out guidelines which can be found here: https://www.youronlinechoices.com/

6. Do we share data collected through cookies?

We may collect information on our website through cookies and share it with third parties such as social networks or advertising platforms, as well as other companies within Kering, advertising agencies/providers and IT providers (e.g. hosting providers), with your consent where required.

7. Do we sell your personal information?

Sale of your personal information

If you choose to enable third party cookies via Cookie Settings, third parties (such as approved analytics and advertising partners) will collect your personal information via automated technologies on our websites, primarily in an effort to provide you with content and advertisements that may be of interest to you and on the legal bases set out in this privacy policy. The choice is yours. You may elect not to send your personal information to them at any time.

Please note that deciding not to share your information via third party cookies does not mean you will stop seeing ads, but these ads will not be tailored to you based on information derived from your activities on our websites.

Please also note that depending on your selection, we may still share your information in ways that are not a “sale” or “sharing” under California law, such as with our service providers, for our own online advertising purposes. 

If you are a Californian resident you also have the right to submit a Shine the Light Request, which means you may request that we provide you with a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, as well as the identity of those third parties.  Any such disclosures will be made consistent with your choices in Cookie Settings. You may contact us at the information below for a listing.

8. How to contact us

If you have any questions regarding our privacy practices or how we handle your data, please contact our privacy team and Data Protection Officer by sending an email to [email protected]  or by completing the form available here(or see How can you contact us?). ]

18. HOW CAN YOU CONTACT US?

If you have any questions regarding our privacy practices or how we handle your information, please contact our privacy team and Data Protection Officer by sending an email to [email protected]. or by using the form available here.

GINORI 1735 DPO: [email protected].

APPENDIX 1 - Specific information for Australian residents ABOUT THE USE OF YOUR PERSONAL INFORMATION

GINORI 1735 will collect, hold, use and disclose your personal information for the following primary purposes.

If you would like more information, you can contact us at [email protected](or see How can you contact us?)

1. To provide you with the products and services you have purchased or otherwise requested

We will use your personal information to manage our relationship with you and to perform our obligations under the contract you conclude with us when you purchase or otherwise request products or services from us. This can cover various activities such as internal accounting, processing your payment or delivery.

To provide you with the products and services you have requested, we will access, collect, store and use your personal information for invoicing, payment management and internal accounting.

Some of the operations mentioned above can be implemented by partners of ours as identified in section “With whom do we share your personal information?”, in particular the registration, payment and delivery of your order. Your information may be communicated, used or collected directly via the information system of our partner.

Certain specific information may be required to provide you with gift cards, customization services, or when you reserve a product or a service, request the repair of a product, or purchase products or services by phone, or on our website or a marketplace. In such cases, we could access, collect, store and use your personal information for delivery, warehouse and return management.]

During your visit to our store, we may need to collect your information in order to allow you to access our premises or when you wish to obtain a particular service: request for tax on products or in connection with our after-sales service, etc.

2. To manage your GINORI 1735 profile.

Once you have requested us to create your GINORI 1735 profile, via GINORI 1735 websites or any other means, including our customer service, your personal information will be linked to this profile, where we will keep all the information we have on you. This could include personal information we obtain directly from you as well as from other sources in accordance with applicable legislation. This could also include information about the purchases made when checking out as a guest or when checking out using a profile. The information in your GINORI 1735 profile is crucial to provide you with the GINORI 1735 personalized and tailored experience, and in some cases is necessary in order to access to some specific services or to purchase from our website, and thus it needs to be kept up to date for the best experience.

Once you have asked us to create your GINORI 1735 profile, we will supplement it with personal information such as your purchases, preferences and contact details. In this context, please be aware that we use personal identification information, such as your email address or phone number, to link an interaction or a purchase with your GINORI 1735 profile. This also applies when checking-out as a guest on our website when making a purchase, as mentioned above, or in case you bind your social media open ID account with your GINORI 1735 profile (by using dedicated QR Codes for example). In addition, we may use your date of birth to determine that you are old enough to use our services.

In order to keep your personal information accurate, we will take every reasonable step to ensure that personal information we hold is properly updated. Subject to your applicable privacy legislation you may have the right to have your information rectified at any time, and in event please let us know if any of your information needs updating or correcting, and we will make our best efforts to detect and correct inaccurate personal information (data cleansing) and delete any duplicated dataset. This may require us to correct typographical errors or inconsistent personal information.

3. To provide you with tailored customer service and assistance.

You should have the same unified experience no matter how we communicate. Whether this happens in our stores, on our website, by chat, by phone or by video, and whether you contact us or we contact you, we want to provide you with relevant and tailored customer service. 

For this purpose of providing you the GINORI 1735 experience, we will collect, store and use your personal information to be able to identify you. This will allow us to provide you with the tailored assistance you are asking for or to share relevant information with you. In addition, when you contact us, we may retain the personal information you share with us to always provide you with such a customised and personalised experience. This could happen if you are an existing or potential customer. Your personal information will be linked to your GINORI 1735 profile, if you have requested us to create one, or to a temporary record.

To provide you with a smooth and enjoyable customer experience, know you better to provide you with tailored answers, and to improve the quality and security of our services, we may rely on your consent, proceed in accordance with our contract with you, or take all reasonable steps to enter into a contract with you, or rely on our legitimate interest to improve our services.  

We will use the information we have about you to try to identify you when you contact us (whether by phone, video chat, text message, chat, social media, etc.). When we can identify you, we will be able to access personal information available in your GINORI 1735 profile or in your temporary record, to know when you have previously interacted with us and to provide you with the tailored assistance you are asking for. This could include real-time or subsequent monitoring of your interaction with us (for example on our website or in a store) to identify the products you are looking at or what could be your specific need.

To provide you with adequate customer service, you may be asked if you need further assistance when you are on our website or in a store. On our website, if you do not want to be contacted, kindly close the chat navigation window. This service was implemented for you to enjoy the same service as in one of our physical stores.

If we are not able to identify you, we may create a temporary record to allow you to have a unified purchase experience. Indeed, however you interact with us, we will do our best to avoid asking you again for information you have already shared with us.

Your personal information, in particular your GINORI 1735 profile if you have created one or the temporary record we may create about you, could enable our sales associates to contact you directly in relation to the products and services you have purchased or otherwise requested, such as when a product becomes available again or when an order you have placed has been received in store, or to share with you any other information you have requested from us. In addition, the monitoring of our interaction  enables us to improve the quality and safety of our services and to provide you with tailored answers.

All our customers are important to us. However, some of our customers and potential customers benefit from a more personalized experience due to the important relationship they keep with GINORI 1735. Our teams may need to collect and gather information on such customers or potential customers in order to identify personalities who correspond to the image and values of GINORI 1735 to offer them unique support. This may be the case when you participate in one of our selective projects or when our Sales Associates offers you to participate in events or contacts you for certain special occasions (for your birthdays or for a particular event of your life).

4. To enable you to receive relevant information and tailored marketing content.

You will receive information and updates about us either at your request (with your prior consent where required by law) or when we are authorised by law to send you such information and updates directly, for instance after a purchase. Such communication can be global or local, and may include updates about our products and services, notifications, invitations to events, offers, surveys, etc.]

Our communications will be customised and specifically designed to be of interest to you, and will be updated with any new personal information linked to your GINORI 1735 profile. We will thus use your personal information to send you tailored communications or other customised advertisements or marketing campaigns. This use of your data includes some profiling activity.

When you share your contact information with us, we may use this personal information to contact you through related communication channels (such as text message, MMS, e-mail, post, internet means, social media or telephone), with your consent where required. You can of course request us not to use a particular channel of communication or opt-out (unsubscribe) from it by applying the opt-out option that will always be shared with you. If you want to stop receiving communication from us via all communication channels, please send an email to [email protected] .

As part of the GINORI 1735 experience, we will always try to customise and personalise your experience with us. This is why we will use your personal information to send you tailored communications or personalise your journey with us, but only with your prior consent where it is required under applicable privacy legislation. Our communications could include tailored product recommendations we think you might like, personalised marketing content designed to suit your interests, personalised events invitations or, at your request and where available, personalised and customised products. For these purposes, we will use the information you provide to us (for example your date of birth, your country of residence, your preferred means of contact, etc.) and/or jointly or independently, certain patterns we may observe when interacting with you (for example where you prefer buying our products, what type of products you like, which occasions you are shopping for, etc.). With this information, we may create groups of similar customers (called “persona”) to whom we can decide to offer personalised content and experiences both in inbound or outbound interactions. In this context, we may make inferences about you, as derived from your personal information (profiling). For example, if you always purchase our products from the same store (specific location or online), we may consider this store as your preferred one. This will allow us to customise your experience with GINORI 1735 based on your interests and shopping habits (i.e. tailored communication).In order to provide you with such customised and personalised experience, in our stores or online, you may be required to log in or identify yourself.

To enrich your personal information, we may use cookies or other online advertising technologies. Via such technologies, we will collect personal information related to your activities on social media and your browsing activity across different websites and devices (for example: to know if you have visited our website after opening a newsletter you have received). Certain technologies may rely on services provided by other companies acting on their own account (such as social media WeChat, WhatsApp, Baidu, Kakao Talk, Facebook, Twitter, Instagram, or other online platforms). These companies have their own privacy and cookies policies and the way they use the personal information you share with them will be subject to their rules and not ours.

Personal information linked to your GINORI 1735 profile (your identification personal information such as your e-mail address, phone number, social network id, etc.) will enable us to reach you on third-party platforms or to create “ lookalike campaigns”, allowing us to find new people who are likely to be interested in our products because they may be similar to you. We may conduct such campaigns through our website, social media or other communication means such as search engine. When this kind of campaigns are conducted, before it is shared, your personal information is hashed and turned into short fingerprints that cannot be reversed.

Using cookies or other online advertising technologies may also enable us to show you online advertisements that are “contextual” (meaning they are shown according to the webpage you are browsing), or “behavioural” or “interest based” (where advertisements are shown to you based on your interests which we have inferred from your information including demographic, geographic and interest-based data). We may use such advertisements to display products or services that are most relevant to you.

If you no longer want to see customised online advertisements, you may request us to delete your GINORI 1735 profile or modify your cookie preferences – see “cookies or other online advertising technologies”. In addition, some third-party sites allow you to stop seeing advertisements from specific advertisers, so you may also set your preferences on those websites.

5. To send you non-marketing communications.

Non-marketing communications may be sent upon your request, and/or may be important for your safety and the security of your personal information.

You may still receive such communications even when you opt-out from certain marketing communications. The information communicated may be necessaryfor the correct performance of our contract with you or be mandatory to comply with some of our legal obligations.

Non-marketing communications can include, but are not limited to: emailing you to verify your identity when you sign up to our services; emailing you for password and/or username reset; notifying you that a particular service has been or will be suspended for maintenance or terminated; notifying you of an upgrade, a rectification or an incident affecting our services that may involve your personal information; notifying you of an update to our privacy policy or Terms of Use; or informing you about any products or services you have requested or purchased.

We will never contact you to ask for your password. Please be aware if you receive any request for this personal information.

6. To manage our social networks  

GINORI 1735 manages “Fan” pages available on several social networks. We may need to process the information made available by the different platforms or when you interact with our pages and publications.

When, as a user, you decide to interact with our social media pages (e.g. when you follow one of our pages, when you click "Like" on Facebook or "Follow" on Instagram or add a reaction to a post, when you "share" or add a "comment", etc.), we have access to public information in your profile. Your information is used for the purpose of interacting with you through the social network in question or to establish analyzes or statistics on the use of our pages or on the performance of our communications. Our services may remove your comments if they do not comply with our policies on the use of social networks (e.g. if your comments are insulting, illegal or malicious).

When you visit our “Fan” page, when you do not have an account or are not logged in to the relevant social network, we do not collect any personal information about you, except for the aggregated data provided to us by each social network.

7. To conduct our business securely and protect our activities and personnel.

To deliver our products and services safely to you, perform our contract properly or comply with some of our legal obligations, we will implement fraud prevention and detection measures. Such measures will allow us to adequately perform our contract with you and/or protect our legitimate interests in defending ourselves against fraud. We may notably implement measures to ensure that you are complying with our terms and conditions for sales, available on this website, offers and programs, and to prevent and detect non-compliance or fraud by you. This may include reviewing and assessing your dealings with us, your eligibility to participate in certain sales, offers and programs, your compliance with the terms and conditions of such sales, offers and programs, and undertaking enforcement action and/or disciplinary action where such non-compliance or fraud is suspected or identified.

We may use administrative and technical measures to protect, our website, our systems, our networks, transactions occurring on our website or in our stores, and any other necessary means to protect the personal information we may access or store. For this purpose, we may also be required to verify your identity or to take note of any suspicious or actual non-compliance with our terms and conditions or fraud we incurred with respect to your dealings with us. Such measures may also be implemented for compliance purposes or to avoid sharing your personal information with any untrusted third parties.

In addition, we may implement certain measures to protect and defend our rights and property, our employees and our business partners in compliance with applicable laws, regulations and international conventions. For example,we can monitor our inbound and outbound interaction with our customer service (including via voice or video recording or listening in real time, with prior notice to you).

8. To assess and better understand our business.

To manage our activities, perform our obligations under our contract with you and comply with our legal obligations, we may need to access and use some of your personal information for finance, management or legal purposes, or business-related analytics & market research activities.

For example, this could occur when we use the invoices we have issued in relation to your purchases for compliance or accountability purposes, or when we analyse personal information to understand the characteristics of our customers (what is the gender proportion, the average age etc.).

In certain limited circumstances, such activity may be based on our legitimate interest when related to business analytics & market research activities

Certain activities which are required when conducting a business may involve the use of your personal information. This could include internal processes (such as finance control, accounting, stock management, production management, internal or external audit), certain legal obligations (for example, record-keeping or tax declaration), or analyses conducted in case of a merger or acquisition.

We may also conduct various business-related analytics & market research activities, which may require us to access or otherwise use some of your personal information, or to send you surveys or customer satisfaction questions in order to gather new or additional information. This notably enables us to analyse and learn how our customers use and interact with us in order to improve products, services and our business in general. It is also important for us to conduct operations that allow us to analyze and measure the performance of our marketing or communications campaigns. This may be the case, for example, when you click on one of our ads on our business partners website or when you make a purchase after viewing one of their ads. Please be aware that to do this, we may use cookies or other online advertising technologies.

1. To optimise and manage our website and other means of communication.

We may take certain measures involving the use of your personal information toadminister, optimise and improve our means of digital or physical communicationssuch as our website, our mobile application, or face-to-face interaction in our stores.

The use of your personal information will allow us to perform our contractual obligations or improve our services in accordance with our legitimate interest. Of course, when we use cookies or other online advertising technologies requiring us to do so, we will always ensure that we have duly obtained your prior consent.

We may use some of your personal information toadminister, optimise and improve our websites, our applications, our content and our other digital offerings, including the services and products offered through our websites, applications or any other digital means of communication to ensure the most user-friendly online navigation experience. We may use such personal information to fix operational problems such as pages crashing and software bugs. Please be aware that to do this, we may use cookies or other online advertising technologies.

Your personal information may be collected, used, held or disclosed for other purposes with your consent or where otherwise permitted by applicable legislation. 

APPENDIX 2 - Specific information for residents of Qatar, Vietnam, China, Kuwait, SAUDI ARABIA, Mexico, Chile, South Korea OR AZERBAIJAN about the use of your personal information

GINORI 1735 will collect, record, hold, organize, structure, store, update, adapt, combine, consult, use, transfer and disclose your personal information for the following purposes. Your personal information will not be further used for purposes incompatible or inconsistent with the purposes for which it was collected, unless permitted by the applicable legislation.

The processing of your personal information is justified on the legal bases set out in this section. The legal bases listed in this section will also apply when we share your data with third parties (as listed in the section With whom do we share your personal information?) for one of the purposes mentioned below.

When we require information from you for the below mentioned purposes, we generally request you to submit this to us voluntarily, i.e. you have the right to consent or not to consent to the collection and processing of your personal data. If you choose not to provide certain personal information, you may not be able to benefit from some of our services for which the provision of such personal information is necessary.

If you would like more information, you can contact us at [email protected]  (or see How can you contact us?)

1. To provide you with the products and services you have purchased or otherwise requested

We will use your personal information to manage our relationship with you and to perform our obligations under the contract you conclude with us when you purchase or otherwise request products or services from us. This can cover various activities such as internal accounting, processing your payment or delivery.

To provide you with the products and services you have requested, we will access, collect, store, process, use, disclose and transfer your personal information for invoicing, payment management and internal accounting.

Some of the operations mentioned above can be implemented by partners of ours as identified in section “With whom do we share your personal information?”, in particular the registration, payment and delivery of your order. Your information may be communicated, used or collected directly via the information system of our partner.

Certain specific information may be required to provide you with gift cards, customization services, or when you reserve a product or a service, request the repair of a product, or purchase products or services by phone, or on our website or a marketplace. In such cases, we could access, collect, store and use your personal information for delivery, warehouse and return management.]

During your visit to our store, we may need to collect your information in order to allow you to access our premises or when you wish to obtain a particular service: request for tax on products or in connection with our after-sales service, etc.

2. To manage your GINORI 1735 profile.

Once you have requested us to create your GINORI 1735 profile, via GINORI 1735 websites or any other means, including our customer service, your personal information will be linked to this profile, where we will keep all the information we have on you. This could include personal information we obtain directly from you as well as from other sources in accordance with applicable legislation. This could also include information about the purchases made when checking out as a guest or when checking out using a profile. The information in your GINORI 1735 profile is crucial to provide you with the GINORI 1735 personalized and tailored experience, and in some cases is necessary in order to access to some specific services or to purchase from our website, and thus it needs to be kept up to date for the best experience.

Once you have asked us to create your GINORI 1735 profile, we will supplement it with personal information such as your purchases, preferences and contact details. In this context, please be aware that we use personal identification information, such as your email address or phone number, to link an interaction or a purchase with your GINORI 1735 profile. This also applies when checking-out as a guest on our website when making a purchase, as mentioned above, or in case you bind your social media open ID account with your GINORI 1735 profile (by using dedicated QR Codes for example). In addition, we may use your date of birth to determine that you are old enough to use our services.

In order to keep your personal information accurate, we will take every reasonable step to ensure that personal information we hold is properly updated. Subject to your applicable privacy legislation you may have the right to have your information rectified at any time, and in event please let us know if any of your information needs updating or correcting, and we will make our best efforts to detect and correct inaccurate personal information (data cleansing) and delete any duplicated dataset. This may require us to correct typographical errors or inconsistent personal information.

3. To provide you with tailored customer service and assistance.

You should have the same unified experience no matter how we communicate. Whether this happens in our stores, on our website, by chat, by phone or by video, and whether you contact us or we contact you, we want to provide you with relevant and tailored customer service. 

For this purpose of providing you the GINORI 1735 experience, we will collect, store, process, use, disclose and transfer your personal information to be able to identify you. This will allow us to provide you with the tailored assistance you are asking for or to share relevant information with you. In addition, when you contact us, we may retain the personal information you share with us to always provide you with such a customised and personalised experience. This could happen if you are an existing or potential customer. Your personal information will be linked to your GINORI 1735 profile, if you have requested us to create one, or to a temporary record.

To provide you with a smooth and enjoyable customer experience, know you better to provide you with tailored answers, and to improve the quality and security of our services, we may rely on your consent, proceed in accordance with our contract with you, or take all reasonable steps to enter into a contract with you, or rely on our legitimate interest to improve our services.

We will use the information we have about you to try to identify you when you contact us (whether by phone, video chat, text message, chat, social media, etc.). When we can identify you, we will be able to access personal information available in your GINORI 1735 profile or in your temporary record, to know when you have previously interacted with us and to provide you with the tailored assistance you are asking for. This could include real-time or subsequent monitoring of your interaction with us (for example on our website or in a store) to identify the products you are looking at or what could be your specific need.

To provide you with adequate customer service, you may be asked if you need further assistance when you are on our website or in a store. On our website, if you do not want to be contacted, kindly close the chat navigation window. This service was implemented for you to enjoy the same service as in one of our physical stores.

If we are not able to identify you, we may create a temporary record to allow you to have a unified purchase experience. Indeed, however you interact with us, we will do our best to avoid asking you again for information you have already shared with us.

Your personal information, in particular your GINORI 1735 profile if you have created one or the temporary record we may create about you, could enable our sales associates to contact you directly in relation to the products and services you have purchased or otherwise requested, such as when a product becomes available again or when an order you have placed has been received in store, or to share with you any other information you have requested from us. In addition, the monitoring of our interaction  enables us to improve the quality and safety of our services and to provide you with tailored answers.

All our customers are important to us. However, some of our customers and potential customers benefit from a more personalized experience due to the important relationship they keep with GINORI 1735. Our teams may need to collect and gather information on such customers or potential customers in order to identify personalities who correspond to the image and values of GINORI 1735 to offer them unique support. This may be the case when you participate in one of our selective projects or when our Sales Associates offers you to participate in events or contacts you for certain special occasions (for your birthdays or for a particular event of your life).

4. To enable you to receive relevant information and tailored marketing content.

You will receive information and updates about us either at your request (with your prior consent where required by law) or when we are authorised by law to send you such information and updates directly, for instance after a purchase. Such communication can be global or local, and may include updates about our products and services, notifications, invitations to events, offers, surveys, etc.]

Our communications will be customised and specifically designed to be of interest to you, and will be updated with any new personal information linked to your GINORI 1735 profile. We will thus use your personal information to send you tailored communications or other customised advertisements or marketing campaigns. This use of your information includes some profiling activity.

When you share your contact information with us, we may use this personal information to contact you through related communication channels (such as text message, MMS, e-mail, post, internet means, social media or telephone), with your consent where required. You can of course request us not to use a particular channel of communication or opt-out (unsubscribe) from it by applying the opt-out option that will always be shared with you. If you want to stop receiving communication from us via all communication channels, please send an email to [email protected] .

As part of the GINORI 1735 experience, we will always try to customise and personalise your experience with us. This is why we will use your personal information to send you tailored communications or personalise your journey with us, but only with your prior consent where it is required under applicable privacy legislation. Our communications could include tailored product recommendations we think you might like, personalised marketing content designed to suit your interests, personalised events invitations or, at your request and where available, personalised and customised products. For these purposes, we will use the information you provide to us (for example your date of birth, your country of residence, your preferred means of contact, etc.) and/or jointly or independently, certain patterns we may observe when interacting with you (for example where you prefer buying our products, what type of products you like, which occasions you are shopping for, etc.). With this information, we may create groups of similar customers (called “persona”) to whom we can decide to offer personalised content and experiences both in inbound or outbound interactions. In this context, we may make inferences about you, as derived from your personal information (profiling). For example, if you always purchase our products from the same store (specific location or online), we may consider this store as your preferred one. This will allow us to customise your experience with GINORI 1735 based on your interests and shopping habits (i.e. tailored communication).In order to provide you with such customised and personalised experience, in our stores or online, you may be required to log in or identify yourself.

To enrich your personal information, we may use cookies or other online advertising technologies. Via such technologies, we will collect personal information related to your activities on social media and your browsing activity across different websites and devices (for example: to know if you have visited our website after opening a newsletter you have received). Certain technologies may rely on services provided by other companies acting on their own account (such as social media WeChat, WhatsApp, Baidu, Kakao Talk, Facebook, Twitter, Instagram, or other online platforms). These companies have their own privacy and cookies policies and the way they use the personal information you share with them will be subject to their rules and not ours.

Personal information linked to your GINORI 1735 profile (your identification personal information such as your e-mail address, phone number, social network id, etc.) will enable us to reach you on third-party platforms or to create “ lookalike campaigns”, allowing us to find new people who are likely to be interested in our products because they may be similar to you. We may conduct such campaigns through our website, social media or other communication means such as search engine. When this kind of campaigns are conducted, before it is shared, your personal information is hashed and turned into short fingerprints that cannot be reversed.

Using cookies or other online advertising technologies may also enable us to show you online advertisements that are “contextual" (meaning they are shown according to the webpage you are browsing), or “behavioural" or “interest based" (where advertisements are shown to you based on your interests which we have inferred from your information including demographic, geographic and interest-based data). We may use such advertisements to display products or services that are most relevant to you.

If you no longer want to see customised online advertisements, you may request us to delete your GINORI 1735 profile or modify your cookie preferences – see "cookies or other online advertising technologies". In addition, some third-party sites allow you to stop seeing advertisements from specific advertisers, so you may also set your preferences on those websites.

5. To send you non-marketing communications.

Non-marketing communications may be sent upon your request, and/or may be important for your safety and the security of your personal information.

You may still receive such communications even when you opt-out from certain marketing communications. The information communicated may be necessaryfor the correct performance of our contract with you or be mandatory to comply with some of our legal obligations.

Non-marketing communications can include, but are not limited to: emailing you to verify your identity when you sign up to our services; emailing you for password and/or username reset; notifying you that a particular service has been or will be suspended for maintenance or terminated; notifying you of an upgrade, a rectification or an incident affecting our services that may involve your personal information; notifying you of an update to our privacy policy or Terms of Use; or informing you about any products or services you have requested or purchased.

We will never contact you to ask for your password. Please be aware if you receive any request for this personal information.

6. To manage our social networks 

GINORI 1735 manages “Fan” pages available on several social networks. We may need to process the information made available by the different platforms or when you interact with our pages and publications.

When, as a user, you decide to interact with our social media pages (e.g. when you follow one of our pages, when you click "Like" on Facebook or "Follow" on Instagram or add a reaction to a post, when you "share" or add a "comment", etc.), we have access to public information in your profile. Your information is used for the purpose of interacting with you through the social network in question or to establish analyzes or statistics on the use of our pages or on the performance of our communications. Our services may remove your comments if they do not comply with our policies on the use of social networks (e.g. if your comments are insulting, illegal or malicious).

When you visit our “Fan” page, when you do not have an account or are not logged in to the relevant social network, we do not collect any personal information about you, except for the aggregated data provided to us by each social network.

7. To conduct our business securely and protect our activities and personnel.

To deliver our products and services safely to you, perform our contract properly or comply with some of our legal obligations, we will implement fraud prevention and detection measures. Such measures will allow us to adequately perform our contract with you and/or protect our legitimate interests in defending ourselves against fraud. We may notably implement measures to ensure that you are complying with our terms and conditions for sales, available in this website, offers and programs, and to prevent and detect non-compliance or fraud by you. This may include reviewing and assessing your dealings with us, your eligibility to participate in certain sales, offers and programs, your compliance with the terms and conditions of such sales, offers and programs, and undertaking enforcement action and/or disciplinary action where such non-compliance or fraud is suspected or identified.

We may use administrative and technical measures to protect, our website, our systems, our networks, transactions occurring on our website or in our stores, and any other necessary means to protect the personal information we may access or store. For this purpose, we may also be required to verify your identity or to take note of any suspicious or actual non-compliance with our terms and conditions or fraud we incurred with respect to your dealings with us. Such measures may also be implemented for compliance purposes or to avoid sharing your personal information with any untrusted third parties.

In addition, we may implement certain measures to protect and defend our rights and property, our employees and our business partners in compliance with applicable laws, regulations and international conventions. For example,we can monitor our inbound and outbound interaction with our customer service (including via voice or video recording or listening in real time, with prior notice to you).

8. To assess and better understand our business.

To manage our activities, perform our obligations under our contract with you and comply with our legal obligations, we may need to access and use some of your personal information for finance, management or legal purposes, or business-related analytics & market research activities.

For example, this could occur when we use the invoices we have issued in relation to your purchases for compliance or accountability purposes, or when we analyse personal information to understand the characteristics of our customers (what is the gender proportion, the average age etc.).

In certain limited circumstances, such activity may be based on our legitimate interest when related to business analytics & market research activities

Certain activities which are required when conducting a business may involve the use of your personal information. This could include internal processes (such as finance control, accounting, stock management, production management, internal or external audit), certain legal obligations (for example, record-keeping or tax declaration), or analyses conducted in case of a merger or acquisition.

We may also conduct various business-related analytics & market research activities, which may require us to access or otherwise use some of your personal information, or to send you surveys or customer satisfaction questions in order to gather new or additional information. This notably enables us to analyse and learn how our customers use and interact with us in order to improve products, services and our business in general. It is also important for us to conduct operations that allow us to analyze and measure the performance of our marketing or communications campaigns. This may be the case, for example, when you click on one of our ads on our business partners website or when you make a purchase after viewing one of their ads. Please be aware that to do this, we may use cookies or other online advertising technologies.

1. To optimise and manage our website and other means of communication.

We may take certain measures involving the use of your personal information toadminister, optimise and improve our means of digital or physical communicationssuch as our website, our mobile application, or face-to-face interaction in our stores.

The use of your personal information will allow us to perform our contractual obligations or improve our services in accordance with our legitimate interest. Of course, when we use cookies or other online advertising technologies requiring us to do so, we will always ensure that we have duly obtained your prior consent.

We may use some of your personal information toadminister, optimise and improve our websites, our applications, our content and our other digital offerings, including the services and products offered through our websites, applications or any other digital means of communication to ensure the most user-friendly online navigation experience. We may use such personal information to fix operational problems such as pages crashing and software bugs. Please be aware that to do this, we may use  cookies or other online advertising technologies.

APPENDIX 3 - Specific information on text and instant messages for residents of the United States or Guam residents

This section applies when you provide prior express consent to receive text messages or instant messages from GINORI 1735. Messages that you may receive from us may include one time or recurring text or instant messages relating to our products, our services, our activities or including any other information that you have requested. At enrollment for recurring messaging programs, we will specify the approximate frequency of messages.

You may opt-out of receiving future messages by texting STOP to the number indicated in our message. For help or for more information, you may contact us at [email protected]  (or see How can you contact us?).

Messages are subject to the terms and conditions of your mobile carrier. Standard message and data rates may apply. Marketing and non-marketing text and instant messages may be sent to your mobile number using an automatic dialing system.

We cannot guarantee timing or receipt of the messages, as this may be affected by forces outside of our control. In the event that a message is delayed, or not received, we are not responsible for any related impacts.

You agree to provide us with a valid mobile number. If you change your mobile phone number, you agree to opt out of receipt of texts and instant messages prior to changing your mobile number.

APPENDIX 4 – SPECIFIC INFORMATION FOR US RESIDENTS 

1. What personal information do we collect 

This section is meant to provide supplemental or specific information for residents of California and certain other US states. We encourage you to read the full privacy policy as well. 

The personal information we collect about you includes information within the below categories of data. Note that the “Category” column listed below refers to the category of personal data as defined under California law and represents the categories of personal information that we have collected, and how it has been shared over the past 12 months. Inclusion of a category in the list below indicates only that we may collect some information within that category. We do not necessarily collect all information listed in a particular category, nor do we collect all categories of information for all individuals. We have collected and shared personal information in each of the below categories with our affiliates and service providers, as well as with government entities as necessary, for our business purposes within the last 12 months. We have not necessarily shared all information listed in a category.