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Last updated: 01/11/2021

The Ermenegildo Zegna Group is aware that the personal data of its customers are important and it therefore intends to inform and provide them in this privacy policy (“Privacy Policy”) with as much control as possible on how their personal data (including sensitive personal data, if any, and reference to personal data in this Privacy Policy shall be deemed to include reference to sensitive personal data), collected through this website (the “Website”), are handled.

1) The Data Controller of the data collected and processed through the Website and the Data Protection Officer

The Data Controller of the data collected on the Website is

• EZ SERVICE Srl, Via Roma 99/100, 13835 TRIVERO (BI), ITALY (hereinafter referred to as, "Zegna", “we” or “us”).

To contact the data protection officer (“Data Protection Officer”) you may write to privacy@zegna.com for enquiries and complaints regarding the Privacy Policy and our processing of your personal data. You may also contact for information our local subsidiary at the following phone number: 400-626-8989.

2) What data will be collected through the Website, and purposes of their processing

The data collected and processed (with your consent, where required by applicable laws) through the Website are of a different type. Such data are processed for various purposes and with different methods. They include:

(a) Cookies - the data concerning your browsing of the Website are processed to ensure that the Website works properly, and for marketing purposes. Please see in this respect our specific Cookie Policy available here;

(b) Registration and Services - any data that you have voluntarily provided (email address, name, phone number, date of birth, password you gave filling-in the registration form of your Zegna personal account), or the data that were lawfully acquired in any other manner, are processed for acknowledging receipt of your requests and delivering the service, providing you with all necessary assistance and information in relation to the products and Zegna’s world. The data (you directly provided us personal information relating you and your working and study experience) for submitting you curriculum vitae to Zegna are processed to evaluate you possible career within Zegna.

(c) Social Log-In - Please note that using your social profile to log-in, some specific data will be communicated by the relevant social network (“Social Network”) you selected (such as name, surname, e-mail address and some other data about you that are on the same Social Network). Therefore, we will ask you your approval Social Network to proceed before logging you to your personal account using the social log-in. Please also note that Social Networks may ask for feedback and information about the social log-in use. Personal data you provide to these Social Network will be processed under the privacy policy and terms of service of those Social Networks and Zegna will not be liable for data processing by these Social Networks. We encourage you to read the privacy policies and terms of services of the relevant Social Networks.

(d) Marketing - by giving your express consent, you will allow Zegna to process your data for marketing purposes, namely, for marketing purposes, namely, for sending you, through newsletters, emails, sms and mms and through postal mails and telephone, information and updates on products, sales, promotional campaigns, events and other initiatives promoted by Zegna, also in collaboration with its business partners, and carrying out specific market researches.

(e) Study of preferences - By giving your express consent, you will allow Zegna to process your data for analysing your spending habits and preferences, and enabling it to adapt its products and initiatives to your tastes and meet best your requirements.

(f) Communication to third parties - By giving your express consent, you will allow Zegna to transfer your personal data to the other companies belonging to the Zegna Group: 

Ezi S.p.A.; Ermenegildo Zegna Giyim Sanayi ve Tic. A. S.; Ermenegildo Zegna H.m.b.H.: Société de Textiles Astrum France S.à.r.l.; Ermenegildo Zegna GmbH; Zegna Japan Co., LTD; Fantasia (London) Limited; Ermenegildo Zegna S.A. de C.V.; Ezeti Portugal. S.A.; Ermenegildo Zegna Madrid S.A.; Ezeti S.L.; Ermenegildo Zegna Czech s.r.o; Consitex S.A.; Ermenegildo Zegna Corporation; Ermenegildo Zegna (China) Co., LTD; Ermenegildo Zegna Far-East Pte LTD; Ermenegildo Zegna Hong Kong LTD; Ermenegildo Zegna Canada Inc.; Ermenegildo Zegna Australia PTY LTD; E. Z. New Zealand LTD; Ezesa Argentina S.A.; E. Z. Thai Holding Ltd; Zegna South Asia Private LTD, Ezesa Brasil Participacoes LTDA; Ermenegildo Zegna (Macau) LTD: Ermenegildo Zegna Malaysia Sdn. Bhd.; Ermenegildo Zegna Maroc S.A.R.L.A.U.; Ermenegildo Zegna Vietnam LLC; Zegna Gulf Trading LLC; E.Zegna Attica Single Member Societé Anonyme.

Where required by applicable laws and regulations, we will obtain your consent if we wish to use your personal information for purposes other than those stated in this Privacy Policy.

3) Source of personal data and relevant legal basis of the processing

Zegna collects personal data directly from the user, and from third party services, such as the data collected with the navigation as per Cookie Policy - section 2 (a) above - and data collected with the social log-in as per section 2 (c) above).

With the exception of the data related to your surfing activity, ruled by our Cookie Policy, the data processing is based on:

• For the registration and services activities - as per section 2 (b) - the legal basis in certain jurisdictions (including under the EU's General Data Protection Regulation) is the legitimate interest to provide the notes, general site services and the information requested by the users (and the contractual obligation in case Zegna offers the users specific services as “book an appointment” or “Made to Measure” services). The legal basis for the processing of working applications is the legitimate interest to evaluate the same for recruiting purposes. In other jurisdictions where legitimate interests do not apply, and/or where required under applicable laws, we will seek your consent for the processing of your personal data for the registration and services activities as set out in section 2(b) under this Privacy Policy.
• For social log-in, marketing, study of preferences, communication of data to third parties (as per sections 2 (c), (d), (e) and (f) above) the legal basis is the specific explicit consent given by the user.

4) Analysis of user's buying habits and selections

As indicated in Section 2 (e) above, with your express consent, Zegna may also process your personal data for the purposes of analysing your habits, buyings and selections, in order to make the Zegna products, services and initiatives more responsive to your tastes and needs.

Zegna will process, by automatic means, the lifestyle, the value purchased within a framework of time, the frequency of the purchases (even if the purchases are made during the sales period) and the kind of product purchased (accessories, clothes, haute couture, pret-a-porter). The study is only intended to propose to clients and users products, services and initiatives more responsive to their tastes and needs. Zegna will not proceed with an intrusive study of your behaviour.

Moreover, please note that as per Section 2 (a), with the your express consent, Zegna can process personal data through an automatic means to study cookies in order to verify the navigation through the Website and to propose products and services in line with the navigation.

5) How your personal data will be processed and storage period

The data collected through the Website will be mainly processed by electronic means, adopting all security measures as are reasonably necessary and appropriate to reduce to a minimum any risk of destruction or loss of the data, including accidental loss, unauthorized access, unlawful processing, or processing that are not compliant with the purposes for which the data were collected as specified in this Privacy Policy.

However, since the data will be transmitted via electronic networks, the above measures cannot limit or completely exclude the risk of unauthorized access or dissemination of the data. To this end, we recommend you check regularly that your PC is endowed with software capable of providing adequate protection (like updated antivirus systems) for the online transmission, inbound and outbound, of the data, and that your Internet Service Provider has adopted adequate security measures for a secure transmission online of your data (like, for instance, firewall and anti-spamming).

Personal data provided during the surfing activity and related to the surfing activity itself are kept for the period no longer than one year. Personal data processed to reply to the user or provide a service are kept as long as necessary for replying or providing the service. Personal data provided for the application activity are kept for the period necessary to evaluate the application. Personal data provided for profiling activities are kept for a limited period of time, in order to allow Zegna to understand user’s preferences within the luxury sector, respecting his privacy and consent. Personal data provided for marketing activities are kept as long as necessary for the particular processing also with reference to the specific sector of activity (luxury products) and considering the interest demonstrated by the clients to be updated on the products, events and runaways of Zegna. Notwithstanding the above, your personal data may be retained to comply with the applicable legal and regulatory requirements under the applicable laws. For more information, please contact the Data Protection Officer.

6) Voluntary nature of providing the requested data

The provision on any data collected through the Website for answering your requests, providing information, as well as for marketing purposes and for analysing your spending habits and preferences is free, voluntary and optional. Any failure by you to provide the data shall not limit your use of the Website, such failure may however make it impossible for Zegna to respond to your queries and requests for information, or send materials, updates, newsletters, invitations to the events organized by the Zegna Group and/or its business partners.

 

7) How we share your personal data

With your consent, Zegna communicates your personal data only as permitted by the applicable laws and as indicated below. Further to what is indicated in section 2 (f). (namely the transmit of your personal data to the other companies belonging to the Zegna Group or to its commercial partners by giving your express consent) and in section 2 (c). (namely the Social log-in) your personal data will be processed and disclosed to-

(i)    Zegna’s employees and consultants;

(ii)   other companies of the Zegna Group, acting as data processors in order to carry out contractual activities and services; and

(iii) to companies which, acting in their capacity as data processors, provide to Zegna specific technical and organizational services in relation to the Website and to the management of marketing and communication activities.

We will put in place appropriate security measures and/or request these third parties to have in place security measures to protect your personal information.

Where permitted by the applicable laws and regulations, your data may also be disclosed to the regulatory authorities, including but not limited to police officers and judicial authorities, in compliance with the law and upon their request, or in case there are good reasons to believe that such disclosure is reasonably necessary to (1) investigate, prevent or take initiatives in relation to suspected unlawful activities, or assist national supervisory authorities; (2) prepare a defence against third party claims or charges, protect the security of its own website and of the company; (3) exercise or protect the rights, property or security of Zegna, the Zegna Group companies, its affiliates, customers, employees and third parties.

If you are resident in the EEA: Your data will not be disseminated and will be transferred abroad, also to non-UE countries - only and if adequate levels of protection and sufficient safeguards, as provided for by the law, are guaranteed, such as “Standard Model Clauses” approved by the European Commission.

If you are resident in the People’s Republic of China (for the avoidance of doubt, for the purposes of this policy this excludes Hong Kong Special Administrative Region, Macau Special Administrative Region and Taiwan): with your separate consent we may share, transfer or store your personal information outside of the People's Republic of China where we are satisfied that adequate levels of protection are in place to protect the integrity and security of your personal information or adequate security measures are adopted and in compliance with the applicable laws. Where required by applicable laws, we will put in place appropriate measures to ensure that all processing of your personal data in jurisdictions outside of your home jurisdiction is safeguarded by the equivalent level of data protection in your home jurisdiction.

For more information about the location of data, please contact the Data Protection Officer.

8) Data subject’s rights under the privacy law

You, as the data subjects, may be entitled to the below data subject rights where permitted by the applicable laws.

The data subject shall be entitled to obtain at any time access to and a copy of personal data concerning him/her, confirmation from Zegna as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form. The data subject shall also be entitled to be informed of the source of the personal data; of the purposes and methods of the processing; of the logic applied to the processing, if the latter is carried out with the help of electronic means; of the identification data concerning the data controller and the data processors; of the entities or categories of entities to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as data processors or persons in charge of the processing.

The data subject shall also have the right to obtain the updating, rectification or, where interested therein, integration of the data, restriction of processing (including denying marketing on the basis of automated decision making, or object to important decisions based solely on automated decision making), erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed; certification to the effect that the above operations have been notified, as also related to their contents, to the entities to whom or which the data were communicated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected. The user can ask for the portability of his/her data; the user also has the right to be forgotten, to lodge a complaint with a supervisory authority as well as the right to withdraw the consent previously given.

The data subject shall have in any case the right to object, in whole or in part, on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys. The right to object may be exercised also in relation to how the marketing messages are being sent.

The data subjects shall have the right to withdraw consent for processing of personal data, or cancel the account registered on the Website. Processing conducted before such withdrawal of consent will not be affected.

The above rights may be exercised by sending the relevant request to Zegna, to the attention of the Data Protection Officer, at the following address: privacy@zegna.com.

9) Marketing

You have the right to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes, and where required by applicable laws we will obtain your prior consent to the direct marketing activities. You can also exercise the right to unsubscribe at any time by contacting us at privacy@zegna.com.

10) Changes to our Privacy Policy

Any changes or updates made to this Privacy Policy will be effective immediately upon posting to the Website. We will notify you of the updates of the Privacy Policy through emails, SMS, notifications, etc. We suggest that you periodically check the Privacy Policy for amendments. We may also seek your consent to those changes where required by applicable laws. If you do not agree with the changes, then you should stop using the Website.

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PRIVACY POLICY FOR ONLINE SALES

Last updated: 1/11/2021

The Ermenegildo Zegna Group is aware that the personal data of its customers are important and it therefore intends to inform and provide them with as much control as possible on how their personal data (including sensitive personal data, if any, and reference to personal data in this Online Sales Privacy Policy shall be deemed to include reference to sensitive personal data)) in this privacy policy for online sales (“Online Sales Privacy Policy”) collected and processed during the purchases made on this website are handled (the “Website”).

1) Joint Data Controllers, Data Processors and Data Protection Officer

With reference to the data connected to the online sales carried out through the Website and to any activity related to such sales

• EZ Service srl, Via Roma 99/100, 13835 TRIVERO (BI), ITALY (hereinafter referred to as, "Zegna").
• Consitex SA., via Ligornetto 13, Stabio, Switzerland (hereinafter referred to as, "CONSITEX")

together hereinafter referred to as, the “Joint Data Controllers”.

To contact the data protection officer (“Data Protection Officer”) of Zegna and EZI, you may write to privacy@zegna.com for enquiries and complaints regarding the Privacy Policy and our processing of your personal data. You may also contact for information our local subsidiary at the following phone number: 400-626-8989.

The Joint Data Controller have also engaged, for reasons of an exclusively organizational and functional nature, a number of companies that will act as external data processors for purposes that are strictly related and connected to the sales of the products as well as to any activity that is incidental or conducive to such sales (like, without limitation, delivery). The external data processors were selected by taking into account their proven expertise, competence, reliability, and ability to give adequate guarantees on the fact that they will act in strict compliance with the legislation currently in force and applicable to personal data, including data security. The data processors shall process the data of the Website’s users in accordance with the instructions received from the Joint Data Controllers. On a regular basis, the Joint Data Controllers will verify that the data processors have punctually performed the assigned tasks, and are still in a position to guarantee their full compliance with any data protection law. A complete list of the data processors can be obtained by contacting the Joint Data Controllers, to the attention to the Data Protection Officer at the following email address: privacy@zegna.com.

2) Data collected by the Joint Data Controllers and purposes of the processing

Joint Data Controllers will (with your consent, where required by applicable laws) collect personal data directly from the users during their registration or when they place their orders for the products, complete their e-transactions, exchange correspondence in relation to activities that are incidental and conducive to the sales, as well as when receive pre-sale and post-sale support. Further specific purposes will be illustrated in greater details in specific privacy policies posted from time to time on the Website.

Where required by applicable laws and regulations, we will obtain your consent if we wish to use your personal information for purposes other than those stated in this Online Sales Privacy Policy.

3) Source of personal data and relevant legal basis

Join Data Controllers collect personal data directly from the user (during the purchase steps). The processing activity as per section 2 is for the fulfilment of contractual and pre/post contractual obligations.

Join Data Controllers also collect personal data from other sources if you use other services provided by the Joint Data Controllers. The Joint Data Controllers are also working closely with third parties as set out in section 1 and may receive information about you from them. If you provide your information on these third parties websites, the privacy policy and terms of service of those websites are applicable. We encourage you to read the privacy policies of websites that you visit before submitting personal information.

Where required by the applicable laws, we will obtain your consent to process your personal data for the purposes described in this Online Sales Privacy Policy, and we will obtain your consent if we wish to use your personal data for purposes other than those stated in this Online Sales Privacy Policy.

4) How data will be processed and storage period

The data collected through the Website during any activity that is incidental and conducive to the sales of the product and to any other related activity, will be mainly processed by electronic means, adopting all security measures as are reasonably necessary and appropriate to reduce to a minimum any risk of destruction or loss of the data, including accidental loss, unauthorized access, unlawful processing, or processing that are not compliant with the purposes for which the data were collected as specified in this Privacy Policy.

However, since the data will be transmitted via electronic networks, the above measures cannot limit or completely exclude the risk of unauthorized access or dissemination of the data. To this end, we recommend you check regularly that your PC is endowed with software capable of providing adequate protection (like updated antivirus systems) for the online transmission, inbound and outbound, of the data, and that your Internet Service Provider has adopted adequate security measures for a secure transmission online of your data (like, for instance, firewall and anti-spamming).

Personal data collected under the Online Sales Privacy Policy will be stored for as long as necessary for the fulfillment of the purpose for which it is used, unless applicable law permits or requires a longer retention period.

5) Obligatory or voluntary nature of providing the requested data

The provision of the data, especially personal details, email address, postal address, telephone number, and also bank details in case of credit card payments, is compulsory for executing, through the Website, the product purchase agreement.

Some of said data, however, may be necessary for providing to the user other services made available on the Website in connection with the sales, or for discharging the obligations deriving from the law or regulatory provisions.

Any failure to provide some of the data required for such purposes might result in us being unable to perform the agreement for the products purchased through the Website, or to provide the user with other services related to their purchase - such as, for instance, support services (Customer Care), use of the Wish List - or, also, to correctly perform the obligations provided for by the law and regulatory provisions. Any failure by the data subject to provide us with the data may therefore constitute, as the case may be, a lawful and justified reason for not performing the agreement of the products purchased on the Website and not providing the related services.

The provisions of data other than the data the provision of which is mandatory, for the purposes of complying with legal or contractual obligations or for providing, upon request, specific services, is instead voluntary and it does neither affect the purchase of the products nor any of the connected/related services.

The mandatory or voluntary nature of the data to be provided will be, if necessary, and as the case may be, indicated by means of a special character (*) placed next to the relevant information or to the data the provision of which is necessary for the purpose of providing the services and for purchasing the products on the Website. Any failure to furnish the data the provision of which is voluntary, does not entail obligations or disadvantages of whatever type.

6) How we share your personal data

Your personal data may, with your consent, where required by the applicable laws, be disclosed to third parties which, acting in their capacity as Data Processors, carry out on behalf of the Joint Data Controllers specific services (including, without limitation, logistics services and IT services), companies of the same group, and other recipients of the data collected by the Joint Data Controllers, which will process the data for the sole purpose of performing the agreement of the products purchased on the Website (including the financial institutions in charge of providing remote card payment services through credit/debit cards) and only if such purpose is not in conflict with the purposes for which the data were collected and subsequently processed and, in any case, in a manner that is consistent with the law.

Your data may also be disclosed to the regulatory authorities, including but not limited to police officers and judicial authorities, in compliance with the law and upon their request, or in case there are good reasons to believe that such disclosure is reasonably necessary to (1) investigate, prevent or take initiatives in relation to suspected unlawful activities, or assist national supervisory authorities; (2) prepare a defence against third party claims or charges, protect the security of its own website and of the company; (3) exercise or protect the rights, property or security of the Joint Data Controllers, the Zegna Group companies, its affiliates, customers, employees and third parties.

None of the data will be communicated, transferred or otherwise disclosed to third parties other than the parties mentioned above, unless the relevant data subject has been previously informed of and has consent (if his/her consent is required by the law) to any such communication, transfer or disclosure. We will put in place appropriate security measures and/or request these third parties to have in place security measures to protect your personal information.

The data will not be disseminated, and will be transferred abroad only and if adequate levels of protection and sufficient safeguards, as provided for by the law, have been guaranteed with the use of the Standard Contractual Clauses.

If you are resident in the People’s Republic of China (for the avoidance of doubt, for the purposes of this Online Sales Privacy Policy, this excludes Hong Kong Special Administrative Region, Macau Special Administrative Region and Taiwan): with your consent we may share, transfer or store your personal information outside of the People's Republic of China where we are satisfied that adequate levels of protection are in place to protect the integrity and security of your personal information or adequate security measures are adopted and in compliance with the applicable laws. Where required by applicable laws, we will put in place appropriate measures to ensure that all processing of your personal data in jurisdictions outside of your home jurisdiction is safeguarded by the equivalent level of data protection in your home jurisdiction.

7) Data subjects’ rights under the privacy law

You, as the data subjects, may be entitled to the below data subject rights where permitted by the applicable laws.

The data subject shall be entitled to obtain at any time access to and a copy of personal data concerning him/her, confirmation from Zegna as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form. The data subject shall also be entitled to be informed of the source of the personal data; of the purposes and methods of the processing; of the logic applied to the processing, if the latter is carried out with the help of electronic means; of the identification data concerning the data controller and the data processors; of the entities or categories of entities to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as data processors or persons in charge of the processing.

The data subject shall also have the right to obtain the updating, rectification or, where interested therein, integration of the data, restriction of processing (including denying marketing on the basis of automated decision making, or object to important decisions based solely on automated decision making), erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed; certification to the effect that the above operations have been notified, as also related to their contents, to the entities to whom or which the data were communicated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected. The user can ask for the portability of his/her data; the user also has the right to be forgotten, to lodge a complaint with a supervisory authority as well as the right to withdraw the consent previously given.

The data subject shall have in any case the right to object, in whole or in part, on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys. The right to object may be exercised also in relation to how the marketing messages are being sent.

The data subjects shall have the right to withdraw consent for processing of personal data, or cancel the account registered on the Website. Processing conducted before such withdrawal of consent will not be affected.

The above rights may be exercised by sending the relevant request to Zegna, to the attention of the Data Protection Officer, at the following address: privacy@zegna.com.

9) Marketing

You have the right to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes, and where required by applicable laws we will obtain your prior consent to the direct marketing activities. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right to unsubscribe at any time by or by contacting us at privacy@zegna.com.

10) Changes to the Online Sales Privacy Policy

Any changes or updates made to this Online Sales Privacy Policy will be effective immediately upon posting to the Website. We will notify you of the updates of the Online Sales Privacy Policy through emails, SMS, notifications, etc. We suggest that you periodically check the Online Sales Privacy Policy for amendments. We may also seek your consent to those changes where required by applicable laws. If you do not agree with the changes, then you should stop using the relevant services provided by the Website.