Privacy Policy

THOM BROWNE Inc. - Website Privacy and Cookies Policy

Introduction

This is the privacy policy for Thom Browne Group for e-commerce activities.

We are aware of the importance of your personal data. Therefore, before using your personal data, we will provide you with complete information about the processing of your data and ask for your necessary consent.

This is the privacy and cookies policy for [http://www.thombrowne.com], being the e-commerce website of Thom Browne Inc. (hereinafter also “Thom Browne”) for the sale and purchase of our products (Site). For the purposes of European data protection legislation (hereinafter also “Data Protection Law”), we are the data controller in relation to the personal data processed in accordance with this policy.

The data processing is held by Thom Browne Inc. 3484679, Tax-ID number 90-0009098 whose registered office is at 240 W. 35th St. Fl. 16th New York, New York 1000. For any information regarding the processing of your personal data, you can contact us by email at privacy@thombrowne.com.

By using the Site, you acknowledge that you have read the terms of this privacy and cookies policy.

Your personal data (hereinafter also "Data") will be processed for the following purposes:

(i) Contractual purposes - purposes closely related to the sale (payment, order, delivery), including pre- and after-sales services provided by Thom Browne (cutting, dispatch, repair, customisation) and purposes related to the contractual guarantee provided by Thom Browne (in the case of Thom Browne's own sales registration, the contractual guarantee is in fact recognised even without the appropriate tax documentation).

(ii) Legal purposes - for any legally relevant purposes arising from the contract of sale (e.g., accounting, taxation, and legal obligations, e.g., legal warranties)

(iii) Customer service purposes - for the specific needs of the customer, in relation to the assistance services to be provided to the customer during the product evaluation and selection process, as well as in relation to the relationship with the customer in the boutique, the reception of the customer, the image consultation, the Style Suggestions ("style wear advice") provided by the dressing consultant, and any other activities related to the Customer Experience ("Customer Experience") in the Boutique.

and, with your prior consent, for the following purposes.

(iv) Marketing purposes - for commercial and marketing purposes, such as sending promotional offers, commercial activities and advertising information relating to products and services offered by Thom Browne by automated electronic delivery (including via SMS, instant message, e-mail, etc.) as well as by traditional means (paper letters and telephone calls).

(v) Purpose of the analysis - for research and analysis of your consumption habits, preferences, and choices to provide products and services that better meet your personal style and needs.

Data will be processed mainly electronically and by traditional means; indeed, some processing may take place on paper. At the same time, specific security measures will be observed to prevent data loss, illegal or incorrect use, and unauthorized access.

Study of customers' consumption habits and choices

With your explicit consent, Thom Browne will be able to study your consumption habits and choices to offer products and activities that best meet your personal style and needs, as described in point (v) above.

With the help of automated tools, Thom Browne will be able to process data relating to the value and frequency of purchases (including purchases during the discount season) and the types of products purchased during a given time (e.g., accessories, clothes, etc.). Thom Browne will be able to obtain more data directly from you about your preferences, hobbies, habits, lifestyle, and favorite sports. Such data may also be obtained indirectly (and therefore not from you) through certain social media platforms or using cookies on the Thom Browne website. In any case, this will only happen if you accept in advance with use of third-party login registration functions, by which the transmission of certain data about you from that social platform can authorize the use of analytics and marketing cookies in the manner provided on the platform's website. In addition, Thom Browne may integrate, or correct and update your personal data of a public nature, subject to the relevant restrictions and to the extent that you have consented and for the purposes described above.

In any case, the sole purpose of this research is to provide products, services, and activities to customers according to their style and needs. The way it is carried out is non-intrusive. In any case, you may at any time request that your personal data be analyzed and updated or amended as necessary.

Legal basis for data processing and data retention period

The legal basis for the processing carried out in accordance with the purposes described above are the following:

Contractual purposes - performance of the contract and obligations before and after the contract, as well as specific legal obligations arising from the performance of the contract (contractual guarantees).
Legal purposes - the fulfilment of legal and tax obligations relating to the sale.
Customer service purposes - to guarantee to its customers a level of service and assistance consistent with the relevant industry and brand reputation, where it is in Thom Browne's legitimate interests to do so.
Marketing purposes - subject to your specific consent.
Analytical purposes - subject to your specific consent.

Data is kept for different periods of time depending on the specific purpose for which it was collected, for the following periods:

Contractual purposes - to comply with civil law provisions and to be kept for a period not exceeding 10 years.
Legal purposes - to comply with tax regulations and to be kept for a period not exceeding 10 years.
Customer Service purposes - to be kept for a period appropriate to the needs of the service, the needs of the customer relationship and the needs related to the expression of the customer.
Marketing purposes - for a period not exceeding 5 years from the date of data collection, except where consent for continued retention has been requested from the client prior to the cut-off date.
Analytical purposes - no more than 5 years from the date of data collection.

Mandatory or optional nature of the data

The provision of data for contractual and legal purposes is not compulsory, but failure to provide certain data may prevent Thom Browne from performing sales contracts and/or related services.

If certain data is not provided for "service purposes", it may not be possible to obtain help and advice from Thom Browne, but this will not affect the sales contract.

Regarding marketing and analysis, failure to provide data will not in any case affect the sales contract and its related services, but may prevent you from receiving invitations, information, and business proposals, or even from responding to your needs, as well as from participating in questionnaires and satisfaction surveys.

Categories of recipients of personal data

Thom Browne may disclose your personal data to the following parties:

Thom Browne group companies.
Third party service providers engaged in processing activities that provide services or assistance and advice to Thom Browne, with particular - but not exclusive - reference to technological, accounting, administrative, legal, insurance, information technology, and marketing.
Persons and authorities whose right of access to personal data is recognized by laws, regulations or provisions issued by legally legitimized authorities.
Competent authorities

The above recipients will process your Personal Data as data controllers, data processors or persons in charge of processing, as appropriate.

In addition, your personal data will be made known to Thom Browne's employees and consultants, who will act as authorized parties and process your personal data on behalf of the Data Controller in accordance with the instructions of the controller.

Transfer of data outside the EU

Thom Browne may transfer your Data to the recipients listed above, including outside the European Union and to the United States. For transfers from the European Union to countries not deemed appropriate by the European Commission, the Company has put in place adequate and appropriate safeguards to protect your Data. Accordingly, Personal Data is transferred in accordance with the requirements and obligations under applicable data protection laws under Articles 44 et seq. of the GDPR. For further information regarding appropriate or adequate safeguards and the means to obtain a copy, you may contact Thom Browne at privacy@thombrowne.com in the manner set forth in this privacy notice.

Your rights

You have certain rights under the applicable data protection laws regarding your personal data. For example, you may request information from Thom Browne as to what personal data about you is held by Thom Browne and how it has been used or disclosed, and you may request access to such personal data in an understandable form. You may also request deletion, correction or updating of your personal data. You may also request to deregister your account (if any) or withdraw your consent to automated decision.

We remind you that you may also withdraw your consent at any time, as well as restrict specific contact details. It should be noted that the right to object to the processing of data for marketing purposes is also valid for traditional means if you do so electronically.

You can exercise this right by contacting us at privacy@thombrowne.com.

Contacts

To exercise your rights, withdraw your consent, to ask information or to make a complaint about our handling of your personal data, please send the relevant request to privacy@thombrowne.com or Avv. Valeria Finazzi at rappresentanteprivacyEU@thombrowne.com

Finally, please note that you may at any time lodge a complaint with the competent supervisory authority.