FENDI wishes to inform you as to the processing of personal data about you that is collected when you visit one of the stores (the ‘ Stores’), as well as when you browse the website www.fendi.com (the ‘ Website’), and in any case in which you decide to use our services, for example, by registering to our loyalty program, by making purchases, or making requests in Store or through any communication channel, such as the ‘Contact Us’ section, the email address and/or the phone number available on the Website as well as by using our instant messaging platforms and our Live Chat on the Website and on our social channels. If you are browsing the Website, please also read the ‘Website terms of use’, as they also contain important information on the security measures we have put in place.
This Privacy Notice does not address FENDI privacy practices relating to job applicants, employees, and other employment-related individuals, nor data that is not subject to applicable data protection laws (such as deidentified or publicly available information). This Information Notice is also not a contract and does not create any legal rights or obligations not otherwise provided by law.
This Privacy Notice is divided into several sections, which you can choose to read by simply clicking on the title of each section, so that you can also freely and consciously choose whether to provide your consent, where requested.
Your personal data shall be processed using paper, electronic or telematic means in order to pursue the purposes specified in this Privacy Notice, in compliance with EU Regulation 2016/679 (the ”GDPR”), any implementing or equivalent national laws (hereinafter collectively referred as the ”Privacy Regulation”) and US privacy laws.
If you reside in the United States, please refer to section ”U.S. Privacy Supplementary Provisions” section below for additional information on the privacy rights available to residents of certain states and our personal data processing practices specific to those individuals.
The data controller of your personal data is:
(hereinafter jointly referred to as ”FENDI” or the ”Company”).
FENDI has also appointed a Data Protection Officer (”DPO”), who can be contacted at the dedicated e-mail dpo@fendi.com.
To the extent that they are necessary to achieve the purposes described in this Privacy Notice, FENDI shall process your following personal data:
Where you provide personal data of third parties (e.g., to facilitate delivery of purchased products), please ensure that such third parties are aware of the processing carried out under this Privacy Notice.
The Companies disclose personal data to the following categories of recipients who are located – as applicable – in Italy, in the territory of the European Economic Area (“EEA”) and in territories outside the EEA where the Companies operate:
To obtain the full and named list of data recipients, you may contact us at customerprivacy@fendi.com.
In any event, your personal data will not be disseminated.
Your personal data is transferred to countries outside the EEA and US and, in particular, to those in where FENDI Group companies are operational and active including: Australia, Bahrain, Brazil, Canada, China, South Korea, the Philippines, Japan, Hong Kong, India, Kuwait, Macau, Malaysia, Mexico, Qatar, the United Kingdom, Singapore, Switzerland, and Thailand.
The transfer to non-EEA countries of your personal data for the purposes specified in this Privacy Notice shall take place on the basis of appropriate safeguards, namely through the signing of standard contractual clauses adopted by the European Commission, as well as through the adoption of technical and organisational measures necessary to ensure, from time to time, adequate protection of your data, as required by the applicable Privacy Regulation, with the exception of countries that have obtained an adequacy decision from the European Commission.
The personal data transfer agreement is available at the registered office of each of the Companies, of which you may request an excerpt should you wish to do so.
Personal data shall be retained for the time periods specified below, which are necessary for carrying out the data processing in connection with the purposes from time to time pursued by FENDI as set forth in this Privacy Notice.
Once the time limits below have passed, personal data will be deleted or anonymised.
1. Retention periods and deletion of data processed for Contractual Purposes
For Contractual Purposes, data is retained for the term of the contract and/or service requested (e.g., in the case of accounts created on the Website or in connection with services provided by FENDI), as well as for up to 10 years thereafter.
2. Retention periods and deletion of data processed for Legal Purposes
For Legal Purposes, data is retained for a period equal to the duration prescribed for each type of data by law.
3. Retention periods and deletion of data processed for Marketing Purposes and Profiling Purposes
Purchase detail data processed for Marketing Purposes and Profiling Purposes is retained for 7 years following its collection.
You may at any time terminate the processing and storage of data regarding you by notifying the Companies of your withdrawal of consent or objection to processing.
4. Retention periods and deletion of data processed for Business Purposes
Personal data processed for Business Purposes is retained for a period equal to the relationship established with you from time to time and for 10 years thereafter, in the event that the personal data is necessary to assert and defend the Companies’ rights vis-à-vis you and/or third parties in any litigation proceedings. In the event that the processing is for the purpose of carrying out activities which are functional to transactions concerning the transfers of business and business units, acquisitions, mergers, spin-offs, or other transformations, and with respect to the performance of such transactions, the retention periods listed above will apply with respect to the main processing that takes place.
Pursuant to the Privacy Regulation, you may exercise the following rights:
Right of access to your personal data in order to obtain confirmation as to whether or not personal data concerning you is being processed and, if so, to know the origin of the data, the purposes and methods of processing, and the logic adopted.
Right to rectification and integration of inaccurate or incomplete personal data concerning you.
Right to erasure (and where there are no specific reasons that otherwise relieve FENDI of the obligation to erase) if (i) personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (ii) you revoke consent and there is no other legal basis for processing; (iii) you object to processing for marketing or profiling purposes; (iv) the personal data has been processed unlawfully.
Right to restriction of processing in cases where (i) you contest the accuracy of personal data, for the period necessary to verify the accuracy of such personal data; (ii) the processing is unlawful and you object to the erase of the personal data and instead request that its use be restricted; (iii) although the Company no longer needs it for processing purposes, the personal data is necessary for you to establish, exercise or defend a right in court; (iv) you object to the processing pursuant to Article 21(1) of the GDPR pending verification as to whether FENDI’s legitimate reasons prevail over yours.
Right to object to the processing of personal data regarding you based on FENDI’s legitimate interest and/or for Marketing Purposes and Profiling Purposes.
Right to portability i.e. to receive your personal data in a structured, commonly used and readable format, so that such data may be retained for further use for personal purposes, and to ask us to arrange for the transmission of such data to another data controller.
Right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent
You may exercise your rights as provided for by the GDPR by sending an e-mail to customerprivacy@fendi.com.
The exercise of rights is not subject to any formal requirements and is free of charge. A response will be given without undue delay and, at the latest, within one month from receipt of the request.
You also have the right to file a complaint with the Italian Data Protection Authority (www.garanteprivacy.it) or with the supervisory authority of the country where you habitually reside, work, or where the alleged violation occurred, if the conditions are met.
This Privacy Notice is effective from the time of its publication. FENDI may amend and/or supplement this Privacy Notice, including as a result of any subsequent regulatory amendments and/or additions to the Privacy Regulation. Amendments will be notified in advance and you can view the updated Privacy Notice at the Privacy Policy link.
The following disclosures supplement the information contained above in this Privacy Policy by providing additional in-formation about the privacy rights available to individual residents of certain states in the United States and personal data processing practices relating to those individuals performed by FENDI. For a detailed description of how the Company collects, uses, discloses, and otherwise processes personal data, please read the sections above of this Privacy Policy.
1. Nevada Residents
If you are a resident of the state of Nevada in the United States, you have the right to opt out or withdraw your consent for this use of your personal data. To this end, you may submit a request by customerprivacy@fendi.com.
2. California, Colorado, Connecticut, Delaware, Iowa, Maryland, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia Residents
If you are a resident of the states of California, Colorado, Connecticut, Delaware, Iowa, Maryland, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, or Virginia in the United States, the following supplementary disclosures apply to you.
a) Personal Data Disclosures, “Sale,” “Sharing” and Targeted Advertising
FENDI does not sell or share your personal information in exchange for monetary consideration for use of your data for marketing and/or profiling purposes. FENDI discloses categories of personal data that collects to the categories of recipients set forth below. Different state privacy laws in the United States provide consumers the right to opt-out of certain data processing. This includes the display advertisements that are based on personal data obtained or inferred over time from an individual’s activities across businesses or distinctively branded sites, applications or services (“Targeted Advertising”, also referred to in California as “cross-context behavioral advertising”). Some states also provide the right to opt-out of “Sharing”, which includes providing or making available personal information to third parties for such Targeted Advertising activity. FENDI may use certain personal data that you provide to advertise to you. This may include making available your personal data to certain third parties in a way that may constitute a Sale and/or Sharing, as well as using your personal data for purposes of Targeted Advertising. If you are in one of those jurisdictions, in order to exercise your right to opt out of targeted advertising or “sales” of your personal data, or withdraw your consent for this use, please click on “Your Privacy Choices” in the footer of the Website or contact us at customerprivacy@fendi.com. To adjust your preferences about the cookies FENDI uses, please visit the “Cookie Settings” manager linked in the footer of the website.
Category of Third Parties
FENDI is a member of the LVMH Group, consisting of LVMH Moët Hennessy Louis Vuitton SE (“LVMH”) and its affiliated Maisons. A full list of the Maisons affiliated with the LVMH Group is available here. FENDI may disclose personal information to the parent entity, LVMH, and affiliated Maisons when they are acting as processors according to our instructions and on our behalf, to provide you with the same level of service worldwide or in other circumstances as permitted or required by law.
Service Providers. FENDI may disclose certain information to third parties, agencies and vendors that perform services to support Company’s business functions and internal operations, including: hosting of FENDI websites; processing payment information for the orders that you request; delivering emails and text message communications; providing marketing assistance; providing website ratings and other user content sharing services; supporting website analytics, including pixels, tags and cookies; analyzing purchases and the use of FENDI website, its features, products; chat features and customer support services.
Payment Providers. Payments for purchases may be completed using third party vendor payment systems. FENDI does not store or disclose your credit card information as part of your purchase through these third-party systems. The personal or financial information you provide through payment processors is subject to the third-party privacy policy.
Legal Process. FENDI may disclose your information to companies or affiliates who help protect the Company’s rights and property or when required by law, the legal process in response to subpoenas, warrants, court orders, investigations, government authorities, investigations or as reasonably necessary to protect the rights or interests of the Company, its employees, affiliates or others.
Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit, opt-out of the sale of personal data or withdraw the consent for the processing of personal data for purposes of targeted advertising (as described in the Your Additional U.S. Privacy Choices paragraph below).
Please note FENDI does not sell personal data of individuals FENDI knows to be less than 16 years of age or share such information for targeted advertising purposes.
b) Sensitive Personal Data
The following personal data elements FENDI may collect may be classified as “sensitive” under certain privacy laws:
FENDI only uses or discloses sensitive personal data where reasonably necessary and proportionate for the purposes of providing products and performing services you have requested, verifying and improving the products and services FENDI provides, detecting security incidents, fraud, and other illegal actions, ensuring the physical safety of natural persons, performing services on behalf of the business, or short-term transient use. FENDI only collects and processes sensitive personal data without the purpose of inferring characteristics about the relevant individual, and FENDI does not sell sensitive personal data or process or otherwise share sensitive personal data for the purpose of targeted advertising.
c) Automated Decision-Making
FENDI does not conduct automated processing of personal data for the purposes of evaluating, analyzing, or predicting an individual’s personal aspects in furtherance of decisions that produce legal or similarly significant effects. As a result, FENDI does not provide a right to exercise control over such forms of automated decision-making.
d) Your Additional U.S. Privacy Choices
Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:
Depending on your state of residency, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on FENDI’s relationship or is otherwise permitted by law.
Submitting Privacy Rights Requests
Please submit a request specifying the right you wish to exercise by:
If you wish to manage your privacy preferences, including opting out of the use of your personal data, visit “Your Privacy Choices” via the footer of the Website. To exercise your right to opt-out as it relates to the use of cookies and related technologies that involve the sale of personal data or the use of personal data for targeted advertising purposes, you may also click the “Cookie Settings” link in the footer of the Website and adjust your preferences accordingly. If you are visiting FENDI website with the Global Privacy Control enabled, any cookies that constitute sales or are used for targeted advertising should already be turned off automatically in FENDI’s cookie preference manager. Please note this opt-out tool is website, device, and browser specific, so you will need to change your preferences on each device and browser you use to interact with the specific website you are visiting. In addition, you can also opt-out of cookie-based sales by businesses that participate in the Digital Advertising Alliance’s CCPA Opt-Out Tool by visiting www.privacyrights.info. Lastly, you may follow the other steps set forth in the Cookie Policy to further exercise control over cookies and related technologies.
Before processing your request to exercise certain rights (including the Right to Know, Access & Portability, Correction, and Deletion), FENDI will need to verify your identity and confirm you are a resident of a state that offers the requested right(s). In order to verify your identity, FENDI will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information FENDI maintain about you in our systems. As a result, FENDI requires requests submitted through our online form and toll-free number to include first and last name, email address, phone number, state of residency and/or the date and place of your last transaction with us.
In certain circumstances, FENDI may decline or limit your request, particularly where FENDI is unable to verify your identity or locate your information in its systems, or where you are not a resident of one of the eligible states.
Submitting Authorized Agent Requests
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where FENDI can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, FENDI generally requires evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, FENDI may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.
Appealing Privacy Rights Decisions
Depending on your state of residency, you may be able to appeal a decision FENDI has made in connection with your privacy rights request. All appeal requests should be submitted by replying to the communication resolving your original request.
e) Additional California-Specific Disclosures
The following disclosures only apply to residents of the State of California.
California Categories of Personal Data
California law requires FENDI provides disclosures to you about what personal data FENDI collects by reference to the enumerated categories of personal data set forth within California law. To address this obligation, please refer to “Which categories of personal data we process” Section of this Privacy Policy.
U.S. Privacy Policy
Last Revised: January 2021
This Privacy Policy describes how Fendi S.r.l. and Fendi retail companies (collectively, “Fendi,” “we,” “us,” or “our”) collects, uses, shares, and safeguards personal information. This Privacy Policy also tells you about your rights and choices with respect to your personal information, and how you can reach us to get answers to your questions. You can jump to particular topics by going to the headings below:
Types Of Information We Collect.
We collect information as described in the specific policies provided by the Website. For details, please refer to the following:
If you apply for a job posting we also collect information necessary to process your application or to retain you as an employee. This may include, among other things, contact information and information regarding your employment history. We use this information to respond to employment applications and in anticipation of your potential employment with us.
In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources. For example, if you submit a job application, or become an employee, we may conduct a background check.
Sharing Of Information.
We do not sell your personal information. In addition to the specific situations discussed elsewhere in our privacy policies, we disclose information in the following situations:
Your Choices.
You can make the following choices regarding your personal information:
Please address written requests and questions about your rights to Palazzo della Civiltà, Quadrato della Concordia No. 3, 00144, Rome (RM), Italy, Tax Code, VAT number and Rome Companies’ Register No. 03897971002, tel. +39 06 33 450 970, or by email through the Contact Form.
Note that, as required by law, we will require you to prove your identity. We may conduct an identity verification by phone call or email. Depending on your request, we will ask for information such as your name, the last item you purchased from us, or the date of your last purchase from us. We may also ask you to provide a signed declaration confirming your identity or to provide copy of your identity document. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.
In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us.
If you are an authorized agent submitting a request on behalf of an individual you must attach a copy of the following information to the request:
How We Protect Personal Information
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Some of our websites permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.
If we do not receive both pieces of information, the request will be denied.
Where We Process Personal Information
We may process your personal information in the United States or Italy, as well as other countries/regions. Please note that where your personal information is processed outside your country/region of residence, it may be subject to the laws of the country/region in which it is processed, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country/region, pursuant to the laws of such country/region. If you would like more information about our policies and practices regarding processing of personal information outside your country/region of residence, please make a request to the contact in point 11 below.
Miscellaneous
The following additional information relates to our privacy practices:
Contact Information
If you have any questions, comments, or complaints concerning our privacy practices please contact us at Palazzo della Civiltà, Quadrato della Concordia No. 3, 00144, Rome (RM), Italy, Tax Code, VAT number and Rome Companies’ Register No. 03897971002, tel. +39 06 33 450 970, email customerprivacy@fendi.com.
****************
California Personal Information Disclosure
California Civil Code 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicates that companies should disclose whether the following categories of information are collected, “sold,” or transferred for an organization’s “business purpose” as those terms are defined under California law. You can find details about the information that we collect from California residents in the chart below. Note that while a category may be marked that does not necessarily mean that we have information in that category about you. Please also note that nothing in this disclosure should be construed to concede that we or any of or affiliates are a “business” as that term is defined under the California Consumer Protection Act (the “CCPA”).
In addition, we may disclose information when requested to government entities, auditors, lawyers, consultants, and other parties as required by law concerning any category (e.g., in response to a subpoena).”
| Categories of Personal Information We Collect |
To Whom We Disclose Personal Information for a Business Purpose |
| Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, email address, account name |
|
| Additional categories of personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – this may include signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information |
|
| Characteristics of protected classifications – this may include age, sex, race, ethnicity, physical or mental handicap, etc. |
|
| Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
|
| Audio, visual, or similar information – this may include photographs, video feeds, audio recordings, and similar information. |
|
| Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement. |
|
| Geolocation data |
|
| Professional or employment-related information |
|
| Inferences drawn from any of the information listed above |
|