Privacy Policies

SG Privacy Policy

 

A. Who We Are?

  1. We are Fendi Srl with registered office in Palazzo della Civiltà, Quadrato della Concordia n.3, 00144, Rome (RM), Italy, Tax Code, VAT number and Rome Company Register no. 00466430584, tel. +39 06 334501; and Fendi Hong Kong Limited with registered office in 1601, 16/F, Dorset House , 979 King’s Road, Quarry Bay, HK. Company Registered no. 31547782. Tel. (852) 2968 8600 (individually or collectively referred to as “Fendi” or “we” or “our” or “us”).

B. What Is The Purpose Of This Policy?

  1. The purpose of this Privacy Policy is to inform you and provide you with an understanding of how we handle, collect, use, disclose and deal with personal data about you that you provide us, that we receive through/from third parties, that is in our possession or that comes into our possession, whether now or in the future. Please read this Privacy Policy carefully. In this Policy, “you” or “your” refers to the individual whose personal data we are receiving, collecting, using, disclosing or processing, which would be you.

  2. We take our responsibilities under Singapore’s Personal Data Protection Act (the “PDPA”) seriously. We also recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.

  3. The contents of this Privacy Policy may change over time so please check back frequently. Any changes to this Privacy Policy will be posted on and can be viewed at our Website (as defined below).

  4. We own and/or operate website(s) such as www.fendi.com/hk and/or any mobile apps that may be published by us (the said website and mobile apps may be collectively or individually referred to as the Website”).
     

C. What Information Do We Receive/Collect?

  1. Personal data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Fendi receives or collects information about you, such as but not limited to when you provide your information to us, when you use our Website, when you interact with us, when you interact with or enter into (or attempt to enter into) a transaction with us. Personal data which we may receive or collect include but may not be limited to :

  • Name

  • Home address

  • Contact information such as mobile number, email address

  • Transactional information

  • Credit card and/or other financial related information that is used for a transaction

  • Location information of yourself and/or your computer or device
     

You may refer to the EU Policies (as defined at section H) described at section H of this document for further information about the personal data we may collect or process.

Additionally, we may already possess personal data about you that we had lawfully received from other Fendi Group entities, whether for any of the purposes stated herein or other purposes, which we processed and/or process in accordance with applicable data protection law. “Fendi Group” refers to our affiliates, related corporations and associated companies, around the world.

We will receive or collect your personal data in accordance with the PDPA or with applicable data protection law.

  1. We may collect and store certain information automatically when you visit the Website. Examples include the internet protocol (IP) address used to connect your computer or device to the internet, connection information such as browser type and version, your operating system and platform, a unique reference number linked to the data you enter on our system, login details, the full URL clickstream to, through and from the Website (including date and time), cookie number and/or your activity on our Website, including the pages you visited, the searches you made.

  2. We may receive information about you from third parties if you use any websites or social media platforms operated by third parties (for example, Facebook, Instagram, Twitter etc.) and, if such functionality is available, you have chosen to link your profile on our Website with your profile on those other websites or social media platforms.
     

D. Cookies

  1. We may use cookies to identify you from other users on the Website.

  2. Please refer to our Cookie Policy mentioned at section H of this Privacy Policy for information about the cookies we use on the Website.

  3. By continuing to use the Website, you are agreeing to the use of cookies on the Website, as described above and in our Cookie Policy. However, please note that we have no control over the cookies used by third parties.
     

E. Geo-location Services

  1. Our Website and mobile or web-based applications may offer location-enabled services. We may receive information about your actual location (such as GPS signals sent by a mobile device) or information that can be used to approximate a location. You may be asked if the geo-location service can be activated and you can also object to this geo-location service within the respective mobile or web-based application.

  2. Further details can be found at our separate privacy policy dealing with our geo-location services or our use of geo-location tools entitled “EXTENDED PRIVACY POLICY LOCATE ME” (“Localize Privacy Policy), the contents of which you consent/agree to once you have consented/agreed to this SG Privacy Policy. The rights and obligations as described in the Localize Privacy Policy, will apply to you and us to the extent that the data protection law that is applicable to you is the European Union’s General Data Protection Obligation.
     

F. The Purposes For Which We Collect, Use Or Disclose Your Personal Data

  1. Fendi will/may collect, use, disclose and/or process your personal data for one or more of the following purposes :

 

  1. processing, facilitating and/or dealing with your interest in our products and/or services;

  2. considering, processing, facilitating, dealing with and/or managing, your request/application for or your purchase of, intended purchase of or your subscription for, our products and/or services (the “Transaction”);

  3. dealing with, facilitating, processing and/or administering the account that you may open with us;

  4. facilitating, processing, dealing with, administering and/or managing Transaction(s) or intended Transaction(s);

  5. providing products or services to you;

  6. administering, facilitating, managing, processing and/or dealing with your relationship with us, your transaction(s) with us, your being our loyalty card member or rewards member, any transactions or activities carried out by you on the Website or at our premises/establishments or with us, your requests, including but not limited to dealing with your adhoc queries, requests or bookings, dealing with your preferences, dealing with your membership needs, dealing with your delivery needs, processing orders and payment transactions, implementing transactions and the supply of products and/or services to you that you have requested. Without limiting the generality of the foregoing, should you make a reservation or transaction that includes third party individual(s) or on behalf of third party individual(s) or for third party individual(s), you consent to us disclosing personal data that identifies you, to the said third party individual(s) (such as but not limited to your name);

  7. administering, facilitating, processing and/or dealing in any matters relating to your use or access of the Website or including identifying you for login to the Website, our portals and other online services provided by us. Without limiting the generality of the foregoing, :

  8. this may include our collection and subsequent processing of your location data or data that identifies your location;

  9. if you :

  • gain access to or sign in to the Website, using your login credentials of a Social Networking Site, or

  • use any features of a Social Networking Site such as its widgets, plug-ins and browser push notifications, made available to you on our Website,

it may result in information or your personal data being collected or shared between us and the third party. For example, if you use Facebook’s “Like” feature, Facebook may register the fact that you “liked” a product and may post that information on Facebook. (“Social Networking Site” refers to an online or digital platform owned or operated by a third party, that is used by people to build social networks or social relations, or to interact, with other people, such as but not limited to Facebook, Instagram, Twitter). By your proceeding pursuant to (1) or (2) above, you consent to such collection, use or disclosure of your personal data;

  1. monitoring, processing and/or tracking your use of the Website in order to provide you with a seamless experience, facilitating or administering your use of the Website, and/or to assist us in improving your experience in using the Website;

  2. administering, facilitating, processing and/or dealing in any transactions or activities carried out by you on the Website;

  3. providing services to you as our customer, as a member of our loyalty programme(s)/card programme(s)/rewards programme(s) or when requested by you; dealing with or administering your participation in contests, gamification, social events organized by us;

  4. carrying out and/or facilitating your instructions or responding to any enquiry given by (or purported to be given by) you or on your behalf;

  5. contacting you or communicating with you via phone/voice call, text message and/or fax message, email and/or postal mail for one or more of the Purposes stated herein. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;

  6. understanding and/or managing your interests, concerns and preferences;

  7. the conduct of training or training purpose, so as to develop or improve our products or services and/or our staff’s and agents’ services and/or service quality. Without limiting the generality of the foregoing, such training may involve collection, use, disclosure or processing of your personal data including your feedback or comments or reviews;

  8. carrying out due diligence or other screening activities (including background checks, anti-money laundering checks, know your client checks) in accordance with legal or regulatory obligations (whether of Singapore or other countries) applicable to us or any Fendi Group entity, the requirements or guidelines of governmental authorities (whether of Singapore or other countries) which we determine are applicable to us or any Fendi Group entity, and/or our or any Fendi Group entities’ risk management procedures that may be required by law (whether of Singapore or other countries) or that may have been put in place by us or any Fendi Group entities;

  9. to prevent or investigate any fraud, unlawful activity or omission or misconduct, whether or not there is any suspicion of the aforementioned, regardless that such prevention or investigation involves us and/or is done by us or any Fendi Group entities; dealing with conflict of interests; or dealing with and/or investigating complaints; carrying out fraud detection and/or credit risk control in relation to your online transactions or attempted online transactions;

  10. complying with or as required by any applicable law, governmental or regulatory requirements of any jurisdiction applicable to us or any Fendi Group entity, including meeting the requirements to make disclosure under the requirements of any law binding on us or any Fendi Group entity, and/or for the purposes of any guidelines issued by regulatory or other authorities (whether of Singapore or other countries), with which we or any Fendi Group entity is/are expected to comply;

  11. complying with or as required by any request or direction of any governmental authority (whether of Singapore or other countries) which we or any Fendi Group entity is/are expected to comply with; or responding to requests for information from public agencies, ministries, statutory boards or other similar authorities (whether of Singapore or other countries). For the avoidance of doubt, this means that we may/will disclose your personal data to the aforementioned parties upon their request or direction;

  12. conducting research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve our or a Fendi Group entity’s products, services and/or facilities in order to enhance any continued interaction between yourself and us or a Fendi Group entity connected or in relation to the Website, or your Transaction(s); or to improve any of our or a Fendi Group entity’s products or services or, whether now or in the future. Without limiting the generality of the foregoing, we may/will in this regard send you surveys or request a face to face interview survey or request your feedback, by way of email or postal mail;

  13. where you have provided us with separate consent to send you marketing information or materials, we will collect, use, disclose and/or process your personal data for marketing purpose and in this regard, we may/would be providing you with marketing, advertising and promotional information, materials and/or documents relating to products, services and/or events (including products, services and/or events of third party organisations with which we may collaborate with) that we (including a Fendi Group entity) or such third party organisations may be selling, marketing, offering, organizing, involved in or promoting, whether such products, services and/or events exist now or are created in the future, :

  • by way of postal mail, electronic transmission to your email address(es), push notifications, other forms of in-app notifications or harnessing other technologies (such as geo-location technology) for our mobile application(s) on your mobile device(s) or other technologies on your computers, and/or through other modes of communication in compliance with the PDPA;

  • if you have separately expressly consented to one or more of the following 3 DNC Modes, by way of the 3 modes of communications of voice calls, text messages or faxes (the “3 DNC Modes”) to your Singapore telephone number, in compliance with the requirements of the PDPA; and/or

  • Notwithstanding (ii) above, regardless that you have not separately provided express consent as aforementioned in (ii) above, Fendi reserves its right to send a specified fax message (as defined in Singapore’s Personal Data Protection (Exemption from Section 43) Order 2013) (the “Exemption Order”) and/or a specified text message (as defined in the Exemption Order) (i.e. a marketing fax message or marketing text message) to your Singapore telephone number, if :

    • there is an ongoing relationship between Fendi and you and the purpose of the message is related to the subject of the ongoing relationship, pursuant to the requirements and conditions of the Exemption Order; or

    • the law permits.

 

  1. storing, hosting, backing up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Singapore;

  2. to facilitate and/or ensure the safety and security of our premises, our customers, our staff and/or visitors to our premises; to deal with, handle and/or conduct disciplinary, security, crime prevention and/or quality assurance processes, matters and/or arrangements. Without prejudice to the generality of the aforesaid, we wish to bring to your attention that if there are surveillance cameras installed at our premises and/or offices, whether now or in future, such surveillance cameras are for security, crime prevention, safety and training reasons and you acknowledge that your personal data will be collected by such cameras and processed by us consequently, should you visit our premises or offices;

  3. maintaining and/or developing our IT or business systems and infrastructure including testing and upgrading of these systems;

  4. creating reports with respect to your Transaction(s) and/or transactions that we have with our customers;

  5. facilitating, dealing with and/or administering external audit(s) or internal audit(s) of the business of Fendi and/or of any Fendi Group entities, Transaction(s), and/or our or a Fendi Group entity’s transactions with our/its customers;

  6. dealing with and/or facilitating a business asset transaction or a potential business asset transaction, where such transaction involves Fendi as a participant or involves only a Fendi Group entity as a participant or involves Fendi and/or any Fendi Group entities as participant(s), and there may be other third party organisations who are participants in such transaction. “business asset transaction” means the purchase, sale, lease, merger or amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation;

  7. record-keeping purposes and producing statistics and research for internal and/or statutory reporting and/or record-keeping requirements, of Fendi or of any Fendi Group entities;

  8. Fendi, Fendi Group’s or a Fendi Group entity’s reporting purposes including but not limited to reporting on Fendi’s business performance;

  9. anonymization of your personal data. In this regard, you acknowledge that personal data that has been anonymized is no longer personal data and the requirements of applicable local data protection law (i.e. the PDPA) would no longer apply to such anonymized data; and

  10. to deal with the or as part of a bankruptcy, winding up, reorganization, restructuring, insolvency, receivership or an assignment for the benefit of creditors, of Fendi.

(the purposes set out in this paragraph 14 above shall be collectively referred to as the “Purposes”)

  1. Fendi may/will need to disclose your personal data to third parties, whether located within or outside Singapore, for one or more of the above Purposes, as such third parties, would be processing your personal data for one or more of the above Purposes. In this regard, you hereby acknowledge, agree and consent that we may/are permitted to disclose your personal data to such third parties (whether located within or outside Singapore) for one or more of the above Purposes and for the said third parties to subsequently collect, use, disclose and/or process your personal data for one or more of the above Purposes. Without limiting the generality of the foregoing or of paragraph 14, such third parties include :

 

  1. any Fendi Group entities;

  2. any of our agents, contractors or third party service providers that process or will be processing your personal data on our behalf including but not limited to those which provide administrative or other services to us such as mailing houses, telecommunication companies, information technology companies and data centres, hosting and maintenance service providers, analysis services service providers, e-mail messaging services service providers, delivery service providers, payment transactions service providers, marketing service providers;

  3. third parties with whom we enter into or may enter into any contractual or other arrangement in relation to the products or services to be provided to you, or in relation to the Transaction; and

  4. third parties to whom disclosure by Fendi is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes.

 

  1. We may share your information with any Fendi Group entities, which may be based in countries other than Singapore, from time to time for one or more of the Purposes.

  2. You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by emailing us at customerprivacy@fendi.com. We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request, unless an exception under the law or a provision in the law permits us to. However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal, including us being unable to perform the transactions requested by you or the termination of your relationship with us (depending on the extent of your withdrawal), as the case may be.

  3. We may collect, use, disclose or process your personal data for other purposes that do not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by applicable data protection law or permitted by law.

  4. To the extent permitted by law, we may/will be receiving or collecting from sources other than yourself, personal data about you, for one or more of the above Purposes, and thereafter using, disclosing and/or processing such personal data for one or more of the above Purposes. We may combine information we receive from other sources with information you give to us and/or with information we have about you. We may use this information and the combined information for the Purposes set out above (depending on the types of information we receive).

  5. We take reasonable steps to ensure that any personal data we collect, disclose and use is accurate and complete, if your personal data is likely to be used by us to make a decision that affects you, or disclosed to another organisation. However, it is important that you advise us of any changes to your personal data or if there are any errors in the personal data we hold about you. We will not be responsible for relying on inaccurate or incomplete personal data arising from your not updating us of any changes in your personal data that you had initially provided us with.

 

G. Provision of third party personal data by you

  1. Should you provide us with personal data of any individual other than yourself, you represent, undertake and warrant to us that :

  2. for any personal data of individuals that you disclose to us, you would have prior to disclosing such personal data to us obtained consent from the individuals whose personal data are being disclosed, to :

  3. permit you to disclose the individuals’ personal data to Fendi for the Purposes; and

  4. permit Fendi and the Fendi Group to collect, use, disclose and/or process the individuals’ personal data for the Purposes;

  5. at our request, you will use such form(s) or document(s) provided by us in obtaining such consents from the individuals in question (for the avoidance of doubt, we are under no obligation to you to create any such form(s) or document(s));

  6. any personal data of individuals that you disclose to us are accurate; and

  7. for any personal data of individuals that you disclose to us, that you are validly acting on behalf of such individuals and that you have the authority of such individuals to provide their personal data to Fendi and for the Fendi Group to collect, use, disclose and process such personal data for the Purposes.
     

H. EU Fendi Policies That May Be Applicable To You (“EU Policies”)

  1. To the extent that, the data protection law that is applicable to you is the European Union’s General Data Protection Regulation (“GDPR”), or the GDPR is applicable to your personal data and/or to the activities which we are carrying out in relation to your personal data, the EU Policies described in this section H would apply to you :

  2. The  ‘Privacy Policy Shop Online’, that deals in the main with your online purchase of FENDI branded products;

  3. The ‘FENDI & ME Privacy Policy’, that deals in the main with your participation in our loyalty programme;

  4. The 'Newsletter Privacy Policy’, that deals in the main with your subscription to our newsletter service;

  5. The ‘Localise Me Policy’ that deals in the main with our geo-location service;

  6. The ‘Information Contact Us Policy’, that deals in the main with your enquiries and our responding to the same;

  7. The 'Cookie Policy’, that provides you with information on the cookies we deploy on the Website; and

  8. The ‘Website Privacy Policy’ that deals in the main with your use of the Website and personal data processing by us.

(the above policies shall be collectively referred to as the EU Policies)


I. How Do We Store Data?

  1. Security of your personal data is important to us. We will put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.

  2. We will put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.

 

J. Rights

  1. You have the right to ask us not to use your personal data for marketing purposes. Please let us know if you want to withdraw your consent by emailing us at customerprivacy@fendi.com.

  2. You have the right to access and/or correct any personal data that we hold about you, subject to exceptions under the law. This right can be exercised at any time by emailing us at privacy@fendi.com. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. With respect to your access request, we may charge a fee in order to process it.

  3. For a request to access personal data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within 30 days. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested. Note that the PDPA exempts certain types of personal data from being subject to your access request.

  4. For a request to correct personal data, once we have sufficient information from you to deal with the request, we will correct your personal data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest practicable time within which we can make the correction. Note that the PDPA exempts certain types of personal data from being subject to your correction request as well as provides for situation(s) when correction need not be made by us despite your request.

  5. We hold and deal with your personal data in accordance with the PDPA.


K. Complaint Process

  1. If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us with your complaint or grievance.

  2. Please contact us with your complaint or grievance by emailing us at privacy@fendi.com.

  3. Where you are sending an email in which you are submitting a complaint, your indication at the subject header that it is a PDPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organisation to handle. For example, you could insert the subject header as “PDPA Complaint”.

  4. We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.


L. General

  1. Your consent that is given pursuant to this Privacy Policy is additional to and does not supersede any other consents that you had provided to Fendi or any Fendi Group entities with regard to processing of your personal data.

  2. For the avoidance of doubt, in the event that Singapore personal data protection law permits an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the law shall continue to apply. Further, where Singapore personal data protection law permits us to handle, retain or process your personal data without having to comply with or as exceptions to, the data protection obligations in the PDPA, such rights given to us to do so will continue to prevail, notwithstanding anything stated in this Privacy Policy.

If you have any queries on this Privacy Policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officer at: privacy@fendi.com.

Last Updated on 10 December 2020