Prada S.p.A. (hereinafter also “PRADA”) with its registered office in Milan, Italy, the operating holding company of the Prada Group and site operator of www.carshoe.com (hereinafter the “Website”), recognizes the importance of maintaining the confidentiality, integrity and security of your personal data (hereinafter the “Personal Data”), and pursuant to art. 13 of Regulation (EU) 2016/679 (hereinafter “GDPR”) informs you that any Personal Data which you provide to PRADA through the Website, as well as any Personal Data which you may provide to PRADA, including through its subsidiaries and/or affiliates (collectively the “Prada Group”), at a Prada Group’s store will be processed in compliance with current European laws on privacy and with any specific local regulations applicable from time to time, 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
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 to specific data subjects. However, due to its nature, this information can allow users to be identified by means of their 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.
Personal Data voluntarily provided by the data subject
PRADA will collect and process the Personal Data you directly and knowingly provide through our Website when: (i) you place online orders; (ii) register to our Website; (iii) and/or your use of 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 the store, to connect or interact with us through social networks, etc.). PRADA may also collect and process the Personal Data that you provide by filling in and signing our customer card (hereinafter the “Customer Card”) at a Prada Group’s store.
If you decide to register the Website through the social login function, please be informed that PRADA 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; PRADA does not oversee or control such social media services or user profiles on these platforms and does not establish privacy settings or rules regarding how Personal Data is used on such platforms.
The Personal Data processed may include personally identifiable information (title, name and surname, country, date of birth), contact details (postal address, email, telephone), shipping and billing information, details of your purchases online and in stores, and other information eventually provided in the course of your interactions with our Client Service or with our sales 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 your Personal Data, and at least 18 years old to purchase products from our Website.
If you are a minor, you should obtain prior written consent from your parent or legal guardian before providing your personal data. If PRADA discovers that it has collected Personal Data about a minor without the prior consent of a verifiable parent or legal guardian, it will de-activate the minor’s account and try to delete the data as soon as possible.
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 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 CAR SHOE and the other brands and initiatives of the Prada Group 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 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 analyses and market research with regards to your preferences for CAR SHOE and the other brands, products and services of the Prada Group, so that a personalized service can be offered and cultural and recreational activities may be promoted based on customers’ 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 of a commercial nature, newsletters, advertising, catalogues and invitations to events concerning CAR SHOE and the other brands, products and service of the Prada Group.
The Personal Data processing referred to in letters (a), (c) and (d) is necessary to provide the service requested by the data subject. The processing referred to in letter (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. For the purposes of profiling and marketing referred to in letters (e) and (f) the data processing is based on the prior consent of the data subject.
3. Nature of the provision of personal data
The provision of Personal Data is optional.
However, if you wish to purchase products offered on our Website, to register in the Prada Group customer database to be provided with exclusive services and benefits reserved for registered customers, and/or use any other services offered on the Website, you will need to fill in all mandatory fields on the relevant data collection forms, otherwise PRADA cannot proceed with the contractual services requested.
The Personal Data processing for the purposes of profiling and marketing, referred to under section 2, letters (e) and (f) above, 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 personalized 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 Prada S.p.A., Via A. Fogazzaro 28, 20135 Milan (Italy), by sending an email to firstname.lastname@example.org or email@example.com, by using the “unsubscribe” link included in all of our commercial electronic communications, or by using any other appropriate procedures which may be made available to you by PRADA.
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 they 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 who are duly authorized to do so in accordance with their respective job duties.
5. Communication and disclosure of data
Whenever necessary and/or instrumental to the abovementioned purposes, your Personal Data may be processed on behalf of PRADA by other entities acting as data processor, pursuant to art. 28 of GDPR, and belonging to the following categories:
- Prada Group companies and franchisees that operate Prada Group stores;
- companies, consultants and professional firms that providing advisory and/or consultancy services, or performing, on behalf of PRADA, related services that are instrumental to the purposes of data processing (e.g. internet service providers, couriers, suppliers hired by PRADA to arrange and/or manage promotional campaigns of the Prada Group's products or services etc.).
As PRADA 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 to the Prada Group customers database for the purposes referred to in section 2 letters (c), (d) and (f), your Personal Data will be automatically visible to, and shared with, all Prada Group stores globally (also in countries not belonging to the European Union) to provide you with the same level of service around the world. PRADA 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 art. 49, paragraph 1 letter b) of the GDPR, when 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: (a) as long as required to carry out the purposes for which the Personal Data were collected; (b) in accordance with the storage periods required by applicable laws; or (c) 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 purpose 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:
- personally identifiable information and contact details collected for the purposes of customer management to offer personalized services and benefits 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 controller and contacts
The data controller is:
Via Antonio Fogazzaro 28 Milan (Italy)
Data Protection Office (“DPO”)
8. Your rights
Please note that you may exercise your rights under articles 15 to 21 of the GDPR at any time, and in particular 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 to request the transmission of your data Personal Data to another data controller.
You also have the right to withdraw your consent for the processing of your Personal Data by PRADA at any time, without charge. The withdrawal of your consent will not affect the lawfulness of processing based on your consent before its withdrawal.
Pursuant to articles 77 and 79 of GDPR if you consider that the processing of your Personal Data infringes the GDPR you have 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.
Last updated:22nd May, 2019