PRIVACY POLICY

Prada S.p.A., with its registered office in Milan (Italy), the operating holding company of the Prada Group (define below) and site manager of www.church-footwear.com together with its subsidiary Church Italia S.r.l., with registered office in Milan (Italy), the company directly operates the selling of products offered on www.church-footwear.com/it/en.html (the “Website”) (Prada S.p.A. and Church Italia S.r.l. are referred together as the “Company”, “we” or “us”), recognize the importance of maintaining the confidentiality, integrity and security of your personal data (“Personal Data”), and hereby inform you that any Personal Data which you provide to the Company through our Website, as well as any Personal Data which you may provide to a Prada Group store, including through its subsidiaries and/or affiliates (collectively the “Prada Group”), will be processed in compliance with current applicable laws on privacy and with any specific local regulations applicable from time to time, including the European General Data Protection Regulation (Regulation (EU) 2016/679 – “GDPR”), together with the principles and general rules of conduct contained in the Code of Ethics adopted by the Prada Group.

1.    Type and source of data

Browsing data

During their normal operation, the computer systems and software procedures used to operate our Website collect certain personal data (log files). The transmission of such data is inherent to the use of internet communication protocols. This information is not collected in order to be associated with specific data subjects. However, due to its nature, this information can allow users to be identified by means of its processing and integration with data held by third parties. Such information includes the IP addresses or domain names of the computers you use to visit our Website, URIs (Uniform Resource Identifiers) of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, the numerical status code of the server reply (successful, error, etc.) and other parameters concerning the user's operating system and computer environment. This data is used with the sole purpose of obtaining anonymous statistical information on the use of our Website and to guarantee its correct operation.

Cookies

Our Website uses cookies to ensure its efficient functioning and to improve our services. Cookies are small text files that are sent to your computer (usually to your browser) by the websites you visit. Cookies are stored in your computer to be recognized by those websites on your subsequent visits. For more information on cookies, on the types of cookies used on our Website, on how to disable them and on how you can revoke your consent, see our cookie policy.

Personal Data voluntarily provided by the data subject

We collect and process the Personal Data that you directly and voluntarily provide through our Website when (i) you place online orders; (ii) register to our Website; and/or (iii) you use other functionalities available on the Website (for example: to subscribe to our newsletter, to send a request to our Client Service, to book an appointment in store, to connect or interact with us through social networks, etc). We may also collect and process the Personal Data that you provide by filling in and signing our customer card (“Customer Card”) at a Prada Group’s store.

If you decide to register to the Website through the social login function, please be informed that we will have access to the Personal Data of your social account (for example, your email address and your public profile) in accordance with the privacy settings of the applicable social media platform. For more information, please refer to the related privacy statements on the applicable social media platform; We do not oversee or control such social media services or user profiles on these platforms and do not establish privacy settings or rules regarding how Personal Data is used on such platforms.

The items of Personal Data collected may include personally identifiable information (title, first and last name, location and date of birth), contact and billing details (postal address, billing address, email, telephone), details of purchases and/or other information regarding you that you may decide to provide during the interactions with our Client Service or with sale staff.

Furthermore, when you voluntarily send an e-mail through our Website and/or to the addresses indicated in our Website, we collect your e-mail address so that we can reply to any request, as well as any additional Personal Data contained in your message.

Personal Data of minors

You must be at least 16 years old (or older depending on your country or state of residence) in order to provide us with Personal Data and at least 18 years old to purchase products from our Website.

If we have actual acknowledge that a minor has provided, through the Website or otherwise, their Personal Data without a verifiable parental consent, we will de-activate the minor’s account and take all reasonable measures to delete or make anonymous the minor’s Personal Data from our systems.

2.         Purposes and legal bases of the processing

Your Personal Data may be processed and used for the following purposes:

(a)    to respond to all your requests and to manage your relationship with the Prada Group;

(b)    to fulfil your online purchase orders and perform all management activities connected with it (including administrative management of the contract, delivery of goods, payment processing, management of any claims and litigation, and fraud prevention), and to comply with any applicable legal or regulatory obligations.

(c)     to send by email the newsletters and other marketing communication regarding the Prada Group’s products, services, initiatives and events as a result of your subscription to the service.

Furthermore, if you register to the Prada Group customers database (as a result of your registration to the Website, or your signing the Customer Card at a Prada Group store), your Personal Data will be managed by the holding company Prada S.p.A. and shared with all Prada Group stores globally, and may be processed together with the details of your purchases online and/or in stores, for the following purposes:

(d)    to confirm your identity as a registered Prada Group customer and, consequently, to provide a customized customer care service and post-sales assistance and allow you to access exclusive services and benefits reserved for registered members (e.g. preservation of your purchase order history, faster online checkout, simplified procedures for product repair and warranty, commercial discounts, pre-sale and other promotional events, etc.);

(e)    profiling: to perform individual or group studies, surveys, statistical analysis and/or market research with regards to your preferences for CHURCH’S and the other brands, products and services of the Prada Group, so that a personalised service can be offered and cultural and recreational activities may be promoted based on customer’s interests;

(f)      marketing: to contact you and/or send you (by post, telephone, e-mail and any other form of electronic communication or digital means including social network platforms and other instant messaging applications) information and promotions, including commercial information, newsletters, advertising, catalogues and invitations to events concerning CHURCH’S and the other brands, products and services of the Prada Group.

The Personal Data processing referred to in subsections (a), (c) and (d) is necessary to provide the service requested by the data subject. The processing referred to subsection (b) is necessary to execute the contract with the data subject or the related pre-contractual measures and to fulfill the connected legal obligations of an administrative and fiscal nature. Further, the data processing referred to in subsections (e) and (f) is based on the prior consent of the data subject.

3.         Nature of the provision of personal data

The provision of your Personal Data is optional.

However, if you wish to purchase products offered on our Website, register to the Prada Group customer database, receive information on Prada Group’s products and/or use any other services offered on the Website, you need to fill in all mandatory fields of the relevant forms, otherwise we cannot proceed with the contractual services requested.

The provision of your Personal Data for the purposes of profiling and marketing indicated in Section 2 letters (e) and (f) is subject to your express prior consent. If you withhold your consent, we may not be able to proceed with the indicated purposes, including the ability to offer you personalised services, inform you of any initiatives that may interest you and/or send you any other commercial information on products, initiatives and events of the Prada Group.

You may withdraw or modify your consent to the processing of your Personal Data by us at any time, by writing to the Data Controller at the contact addresses indicated in Section 7, or by using the “unsubscribe” link included in all of our commercial electronic communications, and/or by using any other appropriate procedures which we may make available to you.

4.         Processing Methods

Your Personal Data will be processed by suitable electronic or automated means and computerized tools, or manually and on hard copy, exclusively for the purposes for which the data have been collected and guaranteeing the security and confidentiality of any processed information through the adoption of appropriate measures to prevent the alteration, cancellation, destruction, unauthorized access or not allowed processing or not in accordance with the purpose of collection.

Your Personal Data will be processed by the Prada Group’s internal staff duly authorised to do so in accordance with their respective job duties.

5.         Transfer and disclosure of data

Whenever necessary and/or instrumental to the abovementioned purposes, your Personal Data may be processed on behalf of the Company by other entities (third parties) engaged by us in the correct and regular pursuit of the described purposes, including:

• Prada Group companies and franchisees that operate Prada Group stores;
• Third party service providers, consultants and firms providing advisory and/or consulting activities, or performing related data processing activities on behalf of the Company (e.g. service providers, carriers, IT technicians or any other suppliers that we may hire to carry out and/or manage any promotional campaigns for Prada Group’s products and services, etc.).

These third parties will act on behalf of the Company as data processor and are under a contractual obligation of confidentiality of the personal information.

As the Company is part of an international network your Personal Data may be transferred abroad, even temporarily, in accordance with applicable legislation, including to countries outside the European Union, by adopting all appropriate security measures and safeguards to ensure an adequate level of data protection and security.

Your Personal Data will not be used for third-party advertising purposes or for the promotion of products, services or initiatives by entities other than the Prada Group, nor shall they be disclosed to unknown persons under any circumstances.

Communication of data to the other Prada Group companies

Please also note that if you register on the Prada Group customers database for the purposes referred to in Sections 2, letters (d)-(f), your Personal Data will be automatically visible to, and shared with, all Prada Group stores globally to provide you with the same level of service around the world. We will take all appropriate and suitable security and confidentiality measures as required by applicable legislation to ensure an adequate standard of data protection, as well as in compliance with article 49, paragraph 1 letter b) of the GDPR, as the data transfer is necessary for the implementation of pre-contractual and contractual measures adopted at the data subject’s request.

6.         Retention period

Your Personal Data will be processed and stored for: (i) as long as required to carry out the purposes for which the data were collected, (ii) in accordance with the storage periods required by the applicable laws, or (iii) until you revoke your consent to the processing/storage of your Personal Data, if applicable.  After the conclusion of such period(s), and where there is no legal or business purposes for retaining your Personal Data, it will be automatically and permanently erased or made anonymous.

In particular, regarding the data processing of registered members into Prada Group customers database:

• Personal Data collected for the purposes of customer management to offer personalized services and advantages reserved for registered members, are kept for a period of 7 years from the date of your last interaction with the Prada Group; and
• Purchase details are kept for a period of 7 years from the date of purchase.

7.         Data controllers and contacts

For the purposes referred to in Section 2 letters (a) and (b) the Data Controller is:

Church Italia S.r.l.

Via Antonio Fogazzaro 28, Milan (Italy)

E-mail: privacy@church-footwear.com.

For the other purposes referred to in Section 2 letters (c) to (f) the Data Controller is:

Prada S.p.A.

Via Antonio Fogazzaro 28, Milan (Italy)

Group Data Protection Officer

E-mail: privacy@prada.com.

If you have any request regarding your Personal Data, have any enquiries regarding this Privacy Policy or you would like to exercise your rights, please contact (free on charge) the Data Controller or the Group Data Protection Officer by writing to the addresses/email addresses listed above.

8.         Your rights

Please note that you may exercise the rights under the applicable privacy laws (and in particular under the articles 15 to 21 of the GDPR), including the right to request information as to whether your Personal Data is being processed and as to the characteristics of the processing, the right to rectification and erasure of your Personal Data, to limitation of the data processing and/or the right to object to the processing and/or request the transmission of your Personal Data to another controller, and/or the right to lodge a complaint with the competent supervisory authority, including the Italian Garante per la protezione dei dati personali (www.garanteprivacy.it) or take legal action if you believe there is noncompliance with the provision of the applicable laws.

You also have the right to withdraw your consent for the processing of your Personal Data at any time, without charge. The withdrawal of your consent will not affect the lawfulness of processing based on your consent before its withdrawal.

We reserve the right to amend this Privacy Policy at any time. The Privacy Policy currently in force is the one published on the Website.

Last updated: March 2020