PRIVACY POLICY

Versace appointed a Data Protection Officer (hereinafter, “DPO”), which you can contact by writing to DPO@versace.it.

When browsing on Our Website or using Our services, we will collect the following Data:

• Navigation Data, such as the IP addresses or domain names of the computers you use to access the Website, and the Uniform Resource Identifier (URI) addresses of the requested resources, which transmission is inherent in the use of Internet communication protocols. This information is not collected in order to be associated to identified users, but could allow for user identification through processing and/or in combination with data held by third parties. These data will be used for the sole purposes of obtaining statistical anonymous information on Website use and to check that the Website runs properly, and are deleted immediately after processing. These Data may be used for the purpose of establishing liability in the event of hypothetical cybercrimes against the Website; therefore, data relating to your web interactions may be retained in accordance with and limited to such purpose. From the IP addresses and domain names of the computers used to access the Website, it may be possible, limited to the purpose of establishing liability mentioned above, to obtain additional user identification data (such as name, surname, e-mail address, telephone number, etc.);
• Identification data and contact details, including name, surname, e-mail address, phone number, Taxpayer ID, date of birth, customer ID, age, Country of residence, address, transaction ID, and gender, as provided by you when registering with the Website, making a purchase, or when subscribing to one of our services (such as Our Newsletter);
• Preference Data, including data relative to how often you make a purchase, your habits, and the purchases you have made;

Protecting the safety and privacy of minors is of paramount importance to us. By registering with the Website on the dedicated section, when filling-in any of the data-collection forms published on our Website, or when submitting a request to receive/subscribing to our Newsletter service, you confirm that you are at least 16 years of age, or, where the legislation of your Country of residence stipulates a different threshold, that you meet that minimum age. In addition, if you provide any information concerning third parties (including parents, tutors, or associates), you confirm that such information may be disclosed to Versace and used for the purposes and under the conditions detailed in this Privacy Policy.

The Data you provide on Versace’s Website are collected and processed for the following purposes and under the following legal bases:

A. Without prior consent:

1. performance of a contract and/or steps taken at the data subject’s request prior to entering into a contract:

• using the Website and any technical assistance;
• managing a contact request submitted by you, including through the live chat managed by a provider to receive assistance in purchasing products you are interested in, or obtain shipping information relative to the products you purchased, or for any other inquiries;
• managing your request to receive information on the availability of one of the products offered on our on-line store (“Notify Me” service);
• managing your request to book an appointment at one of our Versace boutiques;
• allowing you to register with and access your password-protected area;
• managing payments and/or processing and handling your product purchase orders;
• additional service purposes, including handing in-store returns, assistance/inquiries/issues relative to products, repairs, product authentication.

2. complying with our obligations under any laws, regulations, or national and EU legislation and/or obligations imposed by competent Authorities;

3. pursuit of our legitimate interests:

• we have an interest in managing and maintaining the Website for the purpose of ensuring business continuity, including through the operation of the Website, and making the services we offer more efficient;
• we have an interest in producing aggregate statistics aimed at optimising and improving navigation on our Website (without identifying users), based on the aggregate reporting generated downstream of the collection of data through the analytical cookies described in the Website’s Cookie Policy;
• we have an interest in producing aggregate statistical analyses based on individual events, aimed at measuring the number of conversions generated by a given advertising message, for the purpose of optimizing advertising campaigns. We will conduct such processing operation by using your e-mail address, phone number, your name and your surname, the city you are from, your nation, and post code; these data, where available, are the ones you provided when registering with and/or making a purchase on our Website or when subscribing to our Customer Card at one of our boutiques . The above Data shall only be used if, when accessing the Website, you also consented to the use of profiling cookies by clicking on “Accept”, or by enabling Google cookies in the “Profiling Cookies” section accessible by clicking on “Manage Preferences”.
  This processing is supported by Google, which acts as Versace’s processor and records your pseudonymised IP address for the exclusive purpose of measuring conversions on Versace’s behalf. Google will not transfer your data to third parties, nor will it carry out any further processing, or enrich, using the data collected by Versace in its capacity as Controller, the data that it processes as independent controller on the basis of its own consents for other purposes. Google will retain your Data for the above purposes exclusively for a period of 20 days. You may object at any time to processing operations, following the steps provided under paragraph 11.
• we have an interest in conducting aggregate statistical analyses based on individual events on your Data (e.g., date of birth, customer ID, age, Country of residence, address, transaction IDs, gender, etc.) and analyses concerning your Country of residence, store proximity, and/or spending habits. These Data, partly provided by you and partly generated by Versace, will be processed, in pseudonymised and aggregate form, by Versace, in order to optimise its business processes and sales strategies;
• we have an interest in carrying out aggregate statistical analyses based on email-open tracking, in order to assess the performance of the campaigns sent and to support Versace’s business optimisation;
• we have an interest in preventing or uncovering fraud or other misuse that is harmful to the Website and to Versace, and in exercising our rights in judicial proceedings ad for the management of disputes.

The legitimate interests of the Controller in carrying out the above processing operations have been assessed and assessed and balanced against the rights and freedoms of the data subjects through a dedicated assessment, and have been considered to prevail over said rights and freedoms. You may object at any time to said processing, following the steps provided under paragraph 11.

B. Subject to prior consent:

1. marketing purposes including through social media platforms:

• we will process the identification data and contact details you provided when registering with the Website, making a purchase, subscribing to one of our services (e.g. Newsletter), or when you fill out the registration forms present on Meta’s and TikTok’s social media platforms, to send you promotional messages, catalogues, and brochures, invites to events, and in general commercial communications regarding Versace and its initiatives, and to conduct market research and customer-satisfaction surveys relating to purchasing experiences (through the post, via e-mail, operator-assisted telephone calls, SMS, MMS, social media, and instant messaging services). As to the lead-generation service made available by Meta and TikTok, Versace and said providers will act as independent controllers in the collection of your Data, in accordance with Versace’s Privacy Policy, which is linked at the bottom of the form, and Meta’s and TikTok’s privacy policies, which are also linked at the bottom of the form, reported here for ease of reference: Meta's privacy policy, TikTok’s privacy policy;

• if you have provided your consent to the processing of your Data for marketing purposes, we may also share your Data (e.g., name, surname, e-mail address, phone number) with Meta’s social media platform, in order to allow you to view targeted advertising content through its platform (Meta’s “Custom Audience” targeting tool). With regard to this service, your Data will be hashed and encrypted within Versace’s systems before they are shared with Meta; Meta will then act in its capacity as external processor to create matches on Versace’s behalf, while it will act as an independent controller for the Data you provide directly on the platform, which are governed by Meta Privacy Policy

  You can revoke your consent at any time following the procedures detailed in paragraph 11; we will no longer send you any promotional messages, and remove your Data from our “Custom Audience” list.

2. Profiling purposes, namely:

• we will analyse the Data we collect, including through automated means, by also processing them on the basis of your interests, habits and purchasing preferences, including after creating homogeneous groups of profiles that show a degree of correlation with one another, to send communications relating to personalised offers and proposals, tailored to your interests, via post, e-mail, operator-assisted telephone calls, SMS, MMS, social media and instant messaging services.
• we will analyse the Data collected, including through automated means, such as customer ID, Country, address, gender, data relating to purchasing frequency and spending, in order to identify the relevant store or store assistant (the “Preferred Store” and “Preferred SA”) for an existing or potential Versace customer (“prospect”);
• if you have given your consent to the processing of your Data for profiling purposes, we may also
   i) share your Data (e.g., name, surname, e-mail address, phone number) with Meta's social media platform, in order to allow you to view targeted and personalised advertising messages based on your purchasing preferences and habits, through the social media platform (known as Meta's “Custom Audience” function). With regard to this service, your Data will be hashed and encrypted within Versace’s systems before they are shared with Meta; Meta will then act in its capacity as external processor to create matches on Versace’s behalf, while it will act as an independent controller for the Data you provide directly on the platform, which are governed by Meta’s Privacy Policy;
   ii) share your Data (name, surname, phone number, e-mail address) with Meta, including after Versace analysed your preferences, in order to create “Lookalike” audiences among social-network users who appear to have interests or demographic characteristics that are similar to those of our customers (known as “Lookalike” function). In this case, Versace will share your Data following hashing and encryption, and Meta will, in its capacity as Data processor, create matches on behalf of Versace, thereby creating “Lookalike” audiences from said matches, to then offer targeted advertising messages to said audiences. To offer targeted advertising messages on its social media platform, Meta will act as independent controller, as specified in Meta's Privacy Policy,
   iii) share some of your Data (such as user agent, e-mail address, gender, city you are from, post code), for the purpose of optimising the targeting of Versace’s advertising messages on Meta’s platforms, and to measure the results of advertising campaigns and optimise services (through Meta’s business tools such as “Conversion API”). This way, Meta will be able to create a match between your Data and additional data you have provided as a result of your interaction with the Website and Meta's systems, and may create matches for the purpose of conducting campaign measuring activities on behalf of Versace, acting in the capacity as Data controller. In addition, Meta will, as independent data controller, process your Data by enriching them with any additional data provided by you as a result of your interaction with the Website and Meta's systems, for the purpose of allowing you to view targeted advertising messages on Meta's platforms, as specified in Meta's Privacy Policy. This tracking activity is based on your consent to profiling and tracking using cookies, which you provided through your interaction with the cookie banner (you may revoke this consent at any time by accessing the banner on the Website and clicking on “Manage Preferences” or by clicking on the “Manage Cookies” link at the bottom of the Website’s home page), and based on your consent to profiling the data you provided, which gave when providing the data.
  

You can revoke your consent at any time by following the process indicated in paragraph 11; we will no longer analyse your preference Data, and will no longer share them with Meta for the above purposes.

3. purposes relating to the use of tools for measuring and analysing user interactions with the web pages they visit:

Versace and Meta will process, in their capacity as Joint Controllers as described in paragraph 1, the Data relating to your interactions with the websites you visit, by using Meta Business Tools (including, but not limited to, Meta's Pixel, Cookies, Plug-ins). The Website uses social plug-ins. Social Plug-ins are specific tools that allow the functionalities of a Social Network to be integrated directly into a website (e.g., Meta’s “Like” button).” All Social Plug-ins on the Website are marked by the relative logo property of the social media platform. When visiting one of our Website's pages, and interacting with a Plug-in (e.g., by clicking on “Like”), or deciding to leave a comment, the relevant information will be sent by your browser directly to the social media platform (Meta), and stored by the same. Additional information on how Meta processes your Data, including the legal bases used by Meta, and on how to exercise your privacy rights with respect to Meta, is available in Meta's Privacy Policy

Providing your data for the purposes under paragraph 5, letter A), paragraphs 1) and 2) is mandatory; should you decide not to provide these data in whole or in part, we will be unable to fulfil any contractual obligations undertaken, address your requests, or comply with legal obligations. You may object to the processing of your Data for the purposes under paragraph 5, letter A), paragraph 3, by following the process detailed in paragraph 11, except where Versace demonstrates to have an overriding legitimate interest.
As to the purposes under paragraph 5, letter B), providing your Data is optional because their use on our part is subject to your express consent. Should you choose not to provide your consent or to revoke your consent at a later time, this will not have any effects other than preventing us from informing you on any of our initiatives that may be of interest to you, from analysing your purchasing habits and preferences, and from using measurement and interaction tools with Meta. You may choose to no longer receive marketing e-mails and/or newsletters from us by clicking on the “Unsubscribe” button at the foot of each e-mail, or by exercising your rights as further described in paragraph 11. You may choose for your Data to not be processed for profiling purposes, by exercising your rights as further described in paragraph 11. Revoking your consent will not jeopardise the pursuit of the other purposes outlined under paragraph 5, letter A).

We process your Data using electronic methods, by conducting Data collection, recording, updating, organisation, storage, consultation, processing, alteration, selection, retrieval, comparison, use, interconnection, restriction, erasure, and destruction processing operations. The Data will be processed by Versace and by its authorised persons through electronic (and manual) systems, in accordance with the principles of fairness, loyalty, and transparency set out by Privacy Laws, and in such a way as to protect your confidentiality and your rights by adopting appropriate technical and organisational measures to ensure a level of security appropriate to the risk presented. Specific security measures are complied with to prevent the loss of Data, their illegal or improper use, and any unauthorised accesses to such Data.

With regard to the purposes under letter A) 1 and 2 of paragraph 5, the Data will be processed for the entire period of duration of the contractual relationship in order to attain the above purposes, and in any case within the limitation periods established by law. Data required to comply with legal obligations will continue to be retained including after the above time-limits, in order to fulfil said obligations and in accordance with data retention periods set out by applicable laws and regulations. With regard to the purpose of handing a contact request submitted by you, including through the live chat managed by a provider, in order to receive assistance in purchasing products you are interested in, obtain shipping information relative to the products you purchased, or for the inquiries under letter A) 1, paragraph 5, the Data will be processed for two years following collection, unless you exercise your right of erasure, in which case the Data will be erased two months after the case has been closed.

As to any Data provided for the purposes under letter B of paragraph 5, number 1) (marketing), and 2) (profiling), in consideration of the fact that the Data Versace intends to retain concern purchases for “high end” products, and that the average annual purchase frequency for each customer is spread out over time, your Data will be retained for a maximum period of 7 years, unless you exercise your right to revoke your consent; this 7-year period of retention is considered appropriate and proportionate to the purposes pursued and to the type of Data processed. Upon expiry of said 7-year period, the Data will be erased or anonymised; you may however renew your consent at any time to the processing of Data by Versace for said purposes.

As to any Data provided for the purposes under letter B No. 3) (use of Meta Business Tools) under paragraph 5 (Purposes of processing) the Data will be processed in accordance with Meta’s Privacy Policy

Data are processed by Versace’s internal members of staff appointed to such end as “persons in charge of processing”. The Data collected to pursue the above purposes will also be processed by third parties, appointed as processors, where required, or, as the case may be, disclosed to third parties who will act in the capacity of independent data controllers; said third parties are

RECIPIENT / PURPOSE OF THE COMMUNICATION OF DATA	WHAT WE MAY SHARE
Companies within Versace's corporate group for service and/or marketing/profiling purposes, subject to your prior consent	Name, e-mail address, address of residence, phone number, date of birth, demographic information, order history, IP address, payment information, preferences, information regarding transactions, information regarding Website use.
Individuals, companies, associations, or professional firms that provide assistance or consulting services to Versace, including with respect to bookkeeping, administration, legal, tax, and financial matters.	Name, e-mail address, address of residence, phone number, date of birth, demographic information, order history, IP address, payment information, preferences, information regarding transactions, information regarding Website use.
Companies, entities, and associations that provide services connected and instrumental to enabling your navigation on the Website; couriers who deliver catalogues and/or purchased products to you or deliver goods to our stores; customer-assistance services; market survey specialists and analysts; credit card payment providers; IT system maintenance service providers.	Name, email address, residence, phone number, date of birth, demographic information, order history, IP address, payment information, preferences, transaction information, Website usage information
For payments handled by Klarna, more information is available here. As to processing operations carried out by Klarna in its capacity as independent data controller, you can find more information by clicking on the following link.	Name, billing address, shipping address, e-mail address, phone number, date of birth, payment information, etc.
Meta, as social media platform carrying out services connected to marketing activities. With regard to the Custom Audience and Lookalike Audience tools, Meta acts as Versace’s data processor in carrying out operations consisting of matching the Data provided by Versace, subject to your prior consent for marketing purposes, with Meta users’ Data. Exclusively for audience generation activities through the “Lookalike” tool, Meta acts in the capacity of independent data controller based on Meta’s Privacy.	Name, surname, e-mail address, phone number.
Public administrations for the performance of institutional functions within the limitations established by laws and regulations.	Name, e-mail address, address of residence, phone number, date of birth, demographic information, order history, IP address, payment information, preferences, information regarding transactions, information regarding Website use.

The Data may also be made accessible, communicated, and transferred to Public Bodies, Judicial Authorities, and Law Enforcement authorities, who will process the Data for the purpose of acting on investigation requests or where expressly required under a legal obligation.

We may transfer the Data outside of the European Union. To this end, based on the Privacy Laws, Versace assesses the impact of Data transfer and where applicable adopts the most appropriate guarantees (such as adequacy decisions or standard contractual clauses).

For more information on the transfer of the Data collected through Cookies, including third-party cookies, please refer to Versace’s Cookie Policy […] and to the privacy policies adopted by each third party, available on said third parties’ respective websites, and linked to the tables included in Versace’s Cookie Policy.

You can exercise the following rights relative to your Data:

• receive confirmation of the existence of your Data, and access their content (Right of access);
• update, amend, and/or correct your personal Data (Right to rectification);
• request erasure or restriction of processing of Data processed in breach of the law, including data which retention is not necessary in relation to the purposes for which the Data were collected or otherwise processed (Right to be forgotten and Right to restriction);
• object to Data processing (Right to object);
• revoke consent, where granted, without affecting the lawfulness of the processing operations carried out based on consent prior to said revocation;
• lodge a complaint with the Supervisory Authority in case of breach of the Privacy Laws;
• receive the Data provided to Versace in a structured, commonly used and machine-readable format, and request to have the Data transmitted to a different controller (Right to data portability).

We remind you that you can access your Versace account to rectify or view some of the Data you provided to us and associated to your account.

The above requests must be sent to Versace via email to DPO@versace.it and/via regular mail to Società Gianni Versace S.r.l., Piazza Einaudi 4, 20124 Milan, Italy.

If you made your purchases through the website www.farfetch.com and any other of its domain names, please note that Farfetch UK Limited (hereinafter, “Farfetch”) sends to Gianni Versace S.r.l. (“Versace”) the Data you provided when making a purchase on Farfetch. With respect to said Data, Versace acts as data controller. In more detail,

• Data processed by Versace: Versace will process your name, surname, Country, shipping address, phone number, VAT number;
• Purposes of Processing: Versace will process the Data for contractual purposes and to comply with its tax obligations, and namely for the purpose of billing and shipping your orders to you.
• Legal basis: the legal basis for processing these Data is to comply with the contractual and legal obligations to which Versace is subject;
• Methods of processing: the above Data shall be processed by Versace using electronic methods, by conducting Data collection, recording, updating, organisation, storage, consultation, processing, alteration, selection, retrieval, comparison, use, interconnection, restriction, erasure, and destruction processing operations. The Data shall be processed by Versace and its authorised persons through electronic (and manual) systems, in accordance with the principles of fairness, loyalty, and transparency set out under the applicable privacy laws, and in such a way as to protect your confidentiality and your rights, by adopting appropriate technical and organisational measures to ensure a level of security appropriate to the risk presented. Specific security measures are complied with to prevent the loss of Data, their unlawful or improper use, and any unauthorised accesses to such Data;
• Data retention: Versace shall retain your Data for a period of 10 years after your purchase. Furthermore, any Data required to comply with legal obligations will continue to be retained including after the above time-limit in order to fulfil said obligations and in accordance with data retention periods set out by applicable laws and regulations.
• Categories of data recipients: couriers, who will handle your Data exclusively for the purpose of shipping your orders, as independent controllers.
• Data transfers outside of the European Union: for more information on Versace's transfers of Data, please refer to paragraph 10 of Versace’s Website Privacy Policy;
• Your rights: you can exercise your rights, including access, rectification, erasure, objection, data portability, and data restriction rights, and lodge a complaint with the competent authority by following the process detailed in paragraph 11 of Versace’s Website Privacy Policy. If you are a resident of the United States or Canada, please refer to paragraph 13.

In accordance with applicable laws, and in keeping with our commitment to honour the trust you have placed in us, we wish to inform you of your rights in relation to the processing of your personal information (hereinafter, “Personal Information”) by Versace, and the applicable procedures to exercise your rights. Exercising your privacy rights will not lead to any form of disadvantage or discrimination.

For a description of the additional rights afforded to residents of specific Countries, provinces, States, or local communities (and the procedures you should follow to exercise them), please refer to the “Additional Rights” section below.

Right to Access, Rectify, and Erase Personal Information

• Access to Personal Information: you have the right to check whether we collected or otherwise processed Personal Information concerning you, and to request a copy of the Personal Information we collected, which you will be given in electronic format.
• Rectification of Personal Information: you have the right to obtain the rectification of your Personal Information processed by us, when incomplete or inaccurate. You can also make a few corrections to your Personal Information directly by accessing your online account.
• Erasure of Personal Information: you have the right to request the erasure of your Personal Information processed by us, with the exception of particular cases (for instance, when we are required to keep said Personal Information to comply with a request or a contract, to fulfil a legal obligation, or to establish, exercise, or defend our rights in judicial proceedings).
• Procedure to submit a request to access, erase, or rectify Personal Information: You can submit a request to access, erase, or rectify your Personal Information personally or through an Authorised Agent, as follows:
  • Request submitted personally:
    • send your request to dpo@versace.it, or
    • call +1 8887217219, and follow the prompts to share the required information.
• Request through an Authorised Agent: if you have appointed an Authorised Agent to submit a request on your behalf, using the above channels, you need to (1) fill-in and sign a power of attorney or written authorisation, and (2) as the Authorised Agent to attach the signed document when submitting the request on your behalf.

In order to protect your security and your privacy, at our sole discretion we may ask you to verify your identity verified before providing any copies, or before erasing or rectifying the Personal Information as requested. In addition, we will only provide one single copy of the Personal Information, even when the request is submitted through an Authorised Agent.

Managing Marketing Communications

• Direct Mail Opt-Out: if you wish to stop receiving direct mail from us, please contact us at dpo@versace.it (for US and Canadian customers) and include "Direct Mail Opt-Out" in the subject line.

Please note that we may still contact you by postal mail in connection with your accounts, contracts, activities, transactions, and communications in place with us.

• Unsubscribe from receiving emails: if you wish to stop receiving promotional e-mails from us, please follow the "unsubscribe" instructions contained in each promotional e-mail you have received from Versace.

Please note that we may still contact you in connection with your accounts, contracts, activities, transactions, and communications in place with us.

• Direct Messaging Opt-Out (SMS or MMS): Versace does not send SMS or MMS messages in the US or Canada in connection to any promotional and/or marketing activities.

 

Additional Rights

Browser Do-Not-Track signals

Some web browsers and devices allow you to send a “Do Not Track” preference. At this time, we do not alter the user experience in response to such signal. To know more about browser tracking signals and “Do Not Track” signals, see http://allaboutdnt.org.

Canadian Residents

• Revoking consent to processing operations: Canadian residents have the right to revoke their consent to processing, in a manner similar to the right of erasure. To revoke your consent to processing, we ask you to submit a request to erase your Data, following the procedure detailed above (Procedure to submit a request to access, erase, or rectify Personal Information).

Colorado, Connecticut, Virginia, and Utah Residents

• Right to Opt-Out of Targeted Advertising: In addition to the rights listed above, the residents of Colorado, Connecticut, Virginia, and Utah have the right to revoke their consent to receiving our targeted advertising. To opt out from targeted advertising, we ask you or your Authorised Agent to send a request using the procedure detailed above (Procedure to submit a request to access, erase, or rectify Personal Information).

California Residents

• California Shine the Light: California residents may request that we stop sharing their Personal Information with third parties for direct marketing purposes. This request will take effect as of the date it is submitted, and we are not responsible for any communications you may receive from third parties who obtained your Personal Information before that date. In these cases, it is recommended to exercise your right to opt-out with the relevant third party, or contact said third party directly.
  • Procedure to submit a request under California’s Shine the Light law:
    • Submit a request by writing to dpo@versace.it
    • Include the following:
    • The subject line of your email must contain the following language: Exercise of my rights under California’s Shine the Light law.
    • The body of the email must include your first name, last name, and the email address associated with your Versace account.

• California Privacy Rights (CCPA and CPRA) and Notice Rights The California Consumer Privacy Act of 2018 (CCPA) and the California Privacy Rights Act of 2020 (CPRA) require businesses to provide consumers with certain notices regarding their Personal Information practices. The information specified in said notice requirements are reported below:
  • a list of the categories of Personal Information we collect can be found in paragraph 3, “Types of Data Processed”;
  • details relative to the sources from which we collect Personal Information may be obtained by writing to dpo@versace.it, or by mail to Gianni Versace S.r.l., Piazza Luigi Einaudi 4, 20124, Milan, Italy;
  • details relative to the business or commercial purposes for which we collect or process Personal Information are reported in paragraph 5, “Purposes and Legal Grounds for Processing”, and
  • details relative to the Personal Information we share with third parties, and the purposes of such sharing are reported in paragraph 9, “Scope of Data Processing, Communication, Disclosure”

Right to object to the sale or sharing of Personal Information and to its use for targeted advertising: In addition to the rights listed above relative to access, rectification, and erasure of Personal Information, Californian consumers have the right to ask us at any time not to sell or share their Personal Information with third parties for targeted advertising purposes. To object to targeted advertising, the user or their Authorised Agent must submit a request following the procedure detailed above (Procedure to submit a request to access, erase, or rectify Personal Information).