The personal data that you provide may be regarded as jointly controlled by Kering SA and by Gucci.
1. Personal Data We May Collect About You
We will collect various types of personal data about you for the purposes described in this Policy, including:
- Contact information (such as your name, birthday, email address, gender) that you provide by completing forms on the Website;
- Personal data that may be contained in communications you send to us, for example to report a problem or to submit queries, concerns or comments regarding the Website or its content;
- Information from surveys that we may, from time to time, conduct on the Website for research purposes, if you choose to respond to, or participate in, them;
- Information about your use and navigation of our Website, such as your IP address and other device identifiers, your operating system and browser type, and information about the Website pages you visit, collected by cookies or other tracking technologies;
- We may also collect information about how your Device has interacted with us, including the pages accessed and links clicked, how you navigate to and from the Gucci Sites and Gucci Content (such as how you scroll over the Gucci Sites and Gucci Content, which parts you click and how long you spend on each page), your preferences, the products and/or services that you have viewed or searched for, crashes and download errors and response times; and
- Personal information collected from third parties, such as data that you agree to share with us on publicly accessible social networks (e.g., Facebook, Instagram, etc.) and/or that we may collect from other publicly accessible databases.
You are under no obligation to provide any such information. Providing your personal data to us (in particular, your personal details, your email) is necessary for supplying services provided on the Website upon your request, or when your personal data is needed to fulfil obligations required by law or regulations. The refusal to provide us with any personal data necessary for performing the above purposes may consequently prevent us from provide you the reservation service or fulfilling obligations required by law and other regulations. Therefore, failure to provide personal data may constitute, in some cases, a legitimate and justified reason for not providing the Website’s services.
Disclosure of further personal data to us other than that required for fulfilling legal or contractual obligations and to properly browse our services with necessary traffic data is, on the contrary, optional and does not have any effect on the use of the Website and of its services. We will inform you at every step whether disclosing your personal data to us is required or optional by marking with an appropriate symbol (*) the information that is required or data needed for the purchase of products and/or for the provision of requested services on the Website.
2. Minimum Age
Protecting the safety and privacy of children is very important to us. We do not accept registrations submitted by, and will not knowingly collect or use personal data from anyone under the age of sixteen (16) years, or any other age limit set out by the law of his/her country of residence. By registering or making any purchase on the Website, you confirm that you have reached the age of majority in your country of residence.
4. Use Made of Your Personal Data
Whenever we process your personal data, we do so on the basis of a lawful "justification" (or legal basis) for processing. In the majority of cases, the processing of your personal data will be justified on one of the following bases:
- processing is necessary to perform a contract with you or take steps that you have requested in order to enter into a contract (e.g., sale contract);
- processing is necessary for us to comply with a legal obligation;
- processing is in our legitimate interests as a business, and our interests are not overridden by your interests, fundamental rights or freedoms. Our legitimate interests may include our interest in using customer and Website user personal data to conduct and develop our business activities (including by carrying out standard marketing activities), with current and potential customers and Website users; and in establishing, exercising or defending legal claims; or
- processing is based on your prior explicit consent, such as segmented and customized marketing activities.
|The purposes for which we process your personal data are the following:||The processing of your personal data is justified by the following legal basis:|
|To provide you with the services and information offered through the Website and which you request||Performance of a contract|
|Administer your account with us||Performance of a contract|
|Audit the downloading of data from the Website||Our legitimate interest to get to know our customers better and improve our services accordingly|
|Improve and customise our Website, and our products, services and our business in general, such as by tracking your product preferences, shopping history and interactions with the Website||Our legitimate interest to improve our products and services|
|Identify visitors to the Website||Our legitimate interest to get to know our customers better and improve our services accordingly|
|Data analytics, market research purposes (surveys, customer satisfaction, etc.) and data enrichment. This includes second party data matching (i.e., the activity of matching and sharing trusted partner data where two individual brands contract together to match their own data through users unique identifiers and reidentification, i.e., enriching our database with additional usersinsight gathered through activities on our digital media).||On the basis of our legitimate interests in analyzing and learning how usersuse and interact with Gucci in order to improve products, services and our business in general.|
|Correspond with you to resolve your queries or complaints||Your prior explicit consent|
|Global or local marketing purposes (to communicate with you on Gucci updates about our products and services, invitations and other marketing communications that may be of interest to you by one or several of the following channels: SMS, MMS, e-mail, paper mail, internet, social media or telephone), and (ii) for customizing your experience with us to your interests and shopping habits (e.g., tailored communications) and improving our services, notably via profiling, including conducting lookalike targeting campaigns by the selection of your advertising impressions across our websites||Your prior explicit consent|
5. Disclosure of Your Personal Data
We may disclose your personal data to any of our affiliate companies, or to our service providers who assist us in providing the services we offer, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in performing other tasks, from time to time.
For the avoidance of doubt, we will get your express opt-in consent before we share your personal data with any third party company other than Gucci and Kering for marketing purposes.
Your personal data will be accessible by authorized personnel of Kering, Gucci and affiliated companies, and service providers acting on our behalf on a need-to-know basis. Transfer of your personal data from your country of residence to third countries where we operate, including France, Italy, Switzerland and the United States of America, will be involved; some of these countries are subject to a data protection and privacy regulations similar to yours, whereas others are not. To ensure the protection of your personal data is consistent with applicable law, such transfers and processing outside your country of residence or the EEA will be made pursuant to the EU Model Clauses, or any similar legal mechanisms acceptable locally.
We may also share your personal data with third parties in connection with potential or actual sale or restructuring of our company or any of our assets, or those of any associated company, in which case personal data held by us about our users may be one of the transferred assets.
We will also respond to requests for personal data where required to do so by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator or any other legal process served on us.
We place great importance on the security of all personal data associated with our users. We have adopted security measures to protect personal data against accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure or access. For the best possible protection of your personal data outside the limits of our control, your device should be protected (such as by updated antivirus systems) and your internet service provider should take appropriate measures for the security of network data transmission (such as, for example, firewalls and anti-spam filtering).
While we take reasonable steps to protect your personal data, we cannot guarantee that the personal data you disclose to us will be 100% secure, nor that any data breach will not occur.
You accept the inherent security implications of dealing on-line over the Internet and will not hold Gucci, Kering or their processors responsible for any data breach unless it is due to our negligence.
7. Retention of Your Personal Data
Our general approach is to retain your personal data only for as long as required to fulfil the purposes for which it was collected. We generally retain your personal data for 5 years from the last contact you initiated with either Gucci or Kering. Last Contact shall be defined as the last contact initiated by the customer and traceable by our systems or a sales associate.
As examples of such contacts there could be the last time a call, sales email, or meeting was proposed to you to which you responded favorably by, for instance clicking on the link to our website included in the email or attending an appointment in one of our stores. Opening an email from Gucci or Kering would not qualify as Last Contact. Clicking on a link included in an email would.
However, in some circumstances we may retain personal data for longer periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements.
In specific circumstances we may also retain your personal data for longer periods of time corresponding 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.
8. Your Rights
With respect to your personal data you have the rights stated in the articles 15-21 GDPR.
You also have the right to lodge a complaint with your local supervisory authority if you consider that the processing of your personal data infringes applicable law or the CNIL, as Kering Lead Supervisory Authority under the GDPR: COMMISSION NATIONALE DE L'INFORMATIQUE ET DES LIBERTÉS, 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07, Tel: +331 53 73 22 22.
For further information regarding your rights, to exercise any of your rights, or if you have any complaints or questions regarding the processing of your personal data please contact firstname.lastname@example.org.
Please note that we may request proof of identity, and we reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. We will endeavour to respond to your request as soon as possible and in any case within the applicable timeframes.