Fondazione Ferragamo S.p.A. with registered offices at Via de’ Tornabuoni 2, 50123, Firenze (hereinafter, “Fondazione Ferragamo” or “Fondazione”) is committed to protecting the online privacy of the users of its websites and social network pages. As such, this Privacy Policy has been written in order to allow you to understand the Fondazione Ferragamo’s policy regarding your privacy, and how your personal information will be handled when using our website https://fondazione.ferragamo.com ("Website”), also pursuant to the Website’s terms and conditions, and when interacting with Ferragamo’s social network pages (on Facebook, Instagram e Youtube “Social Pages”). This Privacy Policy will also provide you with information so that you are able to consent to the processing of your Personal Data in an explicit and informed manner, where appropriate.

The information and data which you may provide, or which may otherwise be collected in the context of your use of Fondazione Ferragamo’s services – e.g., browsing the Social Pages, contacting the Fondazione Ferragamo through the “contacts” section of the Website (hereinafter, the "Services") – will be used by Fondazione Ferragamo in compliance with the internationally recognized data protection principles. This means, in particular, that any Personal Data processing carried out by Fondazione Ferragamo will respect the principles of lawfulness, fairness, transparency, purpose limitation, storage limitation, data minimization, accuracy, integrity and confidentiality.

CONTENTS
1. Data Controller
2. Personal Data processed
a. Browsing data
b. Special categories of Personal Data
c. Data provided voluntarily by the data subject
d. Cookies
3. Purpose of the processing
4. Legal bases, data controllership and mandatory / discretionary nature of the processing
5. Recipients of Personal Data
6. Transfers of Personal Data
7. Retention of Personal Data
8. Data subjects’ rights
9. Amendments

1. Data Controller

1.1. Fondazione Ferragamo is the Data Controller in reference to all the personal data processed for the purpose of the performance of the Services.

2. Personal Data processed

2.1. As you use the Website or interact with Fondazione’s Social Pages (in particular, when you proactively contact Fondazione by means of the Social Page chat service), we inform you that Fondazione may collect and process information related to you as an individual and which allows you to be identified (either directly or together with additional information), or which is related to other individuals (“Personal Data”), such as your name, an identification number, an online ID or one or more characteristic elements of your physical, physiological, mental, economic, cultural or social identity.
2.2. Personal Data which may be processed by Fondazione through the Website and/or Social Pages are as follows:

A. Browsing Data

2.A.1. The Website’s operation, as is standard with any website on the Internet, involves the use of computer systems and software procedures, which collect information about the Website’s users as part of their routine operation. While Fondazione does not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information, or by using other information collected – as such, this information is also considered Personal Data.

2.A.2. This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the Website, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on.

2.A.3. These data are used exclusively to compile anonymous, statistical information on the use of the Website, as well as to ensure its correct operation and identify any faults and/or abuse of the Website – the data is deleted immediately after processing, unless it must be used to identify responsible parties in the event of cybercrime committed which harms the Website or third parties, in which case information on web contacts may be kept for a period of 7 (seven) days.

B. Special Categories of Personal Data

2.B.1. Where using the “Contact” Section of the Website, you are allowed to submit Personal Data which may fall under special categories of Personal Data – i.e. data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.
2.B.2. In any case, Fondazione stresses the importance of providing your explicit consent to process special categories of Personal Data if you decide, nonetheless, to share it.

C. Data provided voluntarily by the data subject

2.C.1. When using some of the Website’s Services (e.g., when using the “Contact” to ask for information related to the services rendered by Fondazione), you are allowed to submit Personal Data related to other persons.
2.C.2. In any situation where you decide to share Personal Data related to other persons through the Website, you will be considered as an independent data controller regarding that Personal Data, and must assume all inherent legal obligations and responsibilities. This means that you must also make sure that you have these third parties’ consent to their Personal Data being used in this manner before providing them to Fondazione, or another appropriate legal basis which may allow for lawful processing of this information.
2.C.3. To this end, you must fully indemnify Fondazione against any complaints, claims or demands for compensation for damages which may arise from the processing of this Personal Data, initiated by the third parties whose information is processed via the Website by your initiative.

D. Cookies

2.D.1. Information regarding the use of cookies is available in the Cookie Policy at the following link: Cookie-Policy .

3. Purpose of the processing

3.F.1. Fondazione intends to use your Personal Data, collected through the Website and/or, where relevant, the Social Pages, for the following purposes:

• to be able to follow up your requests, when you contact us, with your email, through the section “Contacts” of the Website (“Client Management”);
• to browse and interact with Fondazione’s Social Pages (e.g. Facebook and Youtube.) (“Social Management”);
• to observe the preferences you reveal through your use of the Website, to send you advertising messages in line with those preferences, through the use of Profiling Cookies, described more in detail in our Cookie Policy. These cookies, if used together with other information about you, such as for example how our products and/or services are used, allow us to recognize when access is made to the reserved area, and to send personalized marketing messages in line with your preferences. Social and profiling cookies, as better detailed in our Cookie Policy, which also enable users to interact with social networks (Facebook), enable you to share contents of the Website through social networks (“Retargeting”);
• to comply with laws which impose upon Fondazione, according to the specific cases, the collection and/or further processing of certain types of Personal Data (“Compliance”);
• to prevent and detect any misuse of the Website, or any fraudulent activities carried out through the Website, and enable Fondazione to defend its rights (“Misuse/Fraud”).

4. Legal basis, data controllership and mandatory / discretionary nature of the processing

4.1. The Fondazione’s legal bases pursuant to Regulation (UE) 2016/679 (“GDPR”) to process your Personal Data, according to the purposes identified in Section 3, are as follows:

▪ Client Management: the processing for this purpose is carried out by Fondazione as autonomous data controller for the Services. This processing is necessary to follow up your requests of support/information. It is not mandatory for you to give Fondazione Ferragamo your Personal Data for these purposes; however, if you do not, Fondazione Ferragamo will not be able to provide the relevant Services to you.
▪ Social Management: the processing for this purpose is carried out by Fondazione Ferragamo, in some instances as joint data controller with the Relevant Company and/or the social network provider for the processing carried out through cookies and is necessary to let you interact with Fondazione’s Social Pages. It is not mandatory for you to provide Fondazione your Personal Data for these purposes; however, if you do not, Fondazione will not be able provide you the relevant Services.
▪ Retargeting: the processing for this purpose is carried out by Fondazione Ferragamo as autonomous data controller. This processing is based on your consent, which is provided by you when browsing the Website, as stated in the Website cookie banner. It is not mandatory for you to give consent to Fondazione Ferragamo to use your Personal Data for this purpose, and you will suffer no consequence if you choose not to (aside from not being able to benefit from greater personalisation of your user experience regarding the Website). Any consent given may be withdrawn at a later stage by using the options provided in section 6 of the Cookie Policy.

▪ Compliance: the processing for this purpose is carried out by Fondazione Ferragamo, as autonomous data controller and it is necessary to comply with its legal obligations. When you provide any Personal Data to Fondazione, Personal Data must be processed in accordance with applicable laws , which may include retaining and reporting your Personal Data to official authorities for compliance with tax, customs or other legal obligations.

▪ Misuse/Fraud: information collected for this purpose are used exclusively to prevent and detect fraudulent activities or misuse of the Website (for potentially criminal purposes) and allow Fondazione, as autonomous data controller, to defend themselves in subsequent legal proceedings that may arise.

5. Recipients of Personal Data

5.1. Your Personal Data may be shared, for the purposes listed in Section 3, with different persons / entities (hereinafter and collectively, “Recipients”):

a. entities acting as data processors on Fondazione Ferragamo’s behalf, in particular:
i. persons, companies or professional firms providing Fondazione with advice and consultancy regarding accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services;
ii. entities engaged in order to provide the Services;
iii. hosting providers or e-mail platform providers;
iv. companies and persons authorised to perform technical maintenance (including maintenance of network equipment and electronic communications networks);
b. public entities, bodies or authorities acting as autonomous data controllers to which your Personal Data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities;
c. legal entities which provide Fondazione Ferragamo anti Misuse/Fraud services;
d. persons authorised by Fondazione to process Personal Data needed to carry out activities strictly related to the provision of the Services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees of Fondazione Ferragamo).

6. Transfers of Personal Data

6.1. Apart from the transfer referred to in the previous paragraphs, some of your Personal Data are shared with Recipients who may be located outside the European Economic Area. Fondazione Ferragamo ensures that your Personal Data are processed by these Recipients in accordance with applicable data protection legislation. These transfers can be based on an adequacy decision or on the Standard Contractual Clauses approved by the European Commission.

7. Retention of Personal Data

7.1. Personal Data processed for Client Management will be kept for the to follow up your request. As Personal Data for this purpose are processed in order to provide the Services, Fondazione may retain the data for a longer period as may be necessary to protect Fondazione’s interests to defend against potential liability related to the provision of the Services and, in any case, for 10 years from the performance of the service.
7.2. Personal Data processed for Social Management will be kept for the period necessary to interact with you. When the platform is jointly managed with the platform provider, please refer to Personal Data retention policy available in the relevant social network privacy notice.
7.3. Personal Data processed for Retargeting will be retained until you withdraw your consent.
7.4. Personal Data processed for Compliance will be kept for the period required by the specific legal obligation set forth by the applicable law.
7.5. Personal Data processed for Measure/fraud reasons will be kept, as long as it is deemed necessary and as long Fondazione has the obligation to keep them to defend its interests in judicial proceedings.
7.6. More information on the data retention periods are available by writing to Fondazione at: info@fondazioneferragamo.it. You may always object to the further retention of your Personal Data by writing to the same e-mail address.

8. Data subject rights

8.1. As a data subject, are entitled to request from Fondazione at any time, access to your Personal Data, the correction and erasure of your Personal Data, as well as to object to its processing, based on grounds relating to your situation. You are also entitled to request the restriction of the processing of your Personal Data, as well as to obtain the Personal Data you have provided to Ferragamo in a structured, commonly used and machine-readable format.
8.2. Please note that most of the Personal Data you provide Fondazione can be changed at any time, including your e-mail preferences, by accessing, where applicable, your user profile created on the Website.
8.3. For Retargeting, you may always withdraw your consent at a later stage by using the options provided in section 6 of the Cookie Policy, without prejudice for the processing lawfully carried out before such withdrawal.
8.4. In any case, please note that, as a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of Personal Data, if you believe that the processing of your Personal Data carried out through this Website violates applicable law.

9. Amendments and effective date

9.1. Fondazione reserves the right to partly or fully amend this Privacy Policy, or simply to update its content, e.g., as a result of changes in applicable law. Where they are of a substantive nature, Fondazione will inform you of such changes as soon as they are introduced, and they will be binding as soon as they are published on the Website. In any case, Fondazione invites you to regularly visit this Privacy Policy in order to acquaint yourself with the latest, updated version of the Privacy Policy, so that you may remain constantly informed on how Fondazione processes and protects your Personal Data.