This is the privacy and cookies policy for www.pucci.com, being the e-commerce webWebsite of Pucci (“we”, “us” and “our”) for the sale and purchase of our products (“Website”). For the purposes of European data protection legislation and California Consumer Privacy Act (CCPA and, jointly, Data Protection Law), we are the data controller in relation to the personal data processed in accordance with this privacy and cookies policy.

We are committed to protecting your privacy on-line when visiting the Website or communicating electronically with us. We appreciate that you do not want the personal data you provide to us distributed indiscriminately and here we explain how and why we collect and process personal data, what we do with it and what controls you have.  

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

We will treat all your personal data as confidential (although we may disclose this information in the circumstances set out below).  We will keep it on secure servers (as further detailed below) and we will fully comply with all applicable Data Protection Law and consumer legislation.

We may process personal data relating to you if:

• You are a user of the Website;
• You are a customer of us;
• You use our products;
• You are someone to whom we want to advertise or market our products;
• You are a contact suggested by one of our users or customers;

1. INFORMATION WE MAY COLLECT FROM YOU

Through your use of the Website, we may collect and process the following information about you:

• information (i.e., your name, email address, billing address, delivery address, telephone number, product selections, payment type and card expiry number or log in and password details) that you provide by completing forms on the Website, including if you register as a user of the Website, purchase any products from the Website, upload or submit any material via the Website, request any information, or enter into any competition or promotion we may sponsor.
• Information relating to transactions with us involving details of products that we have supplied to you (i.e., the date of the transaction, the products purchased, the price and currency, any requests you made).
• Information provided to us when you communicate with us, for example by email or phone, namely the reason of your request, your contact details, the outcome, any feedback you may leave. This includes communications you send to us, for example to report a problem or to submit queries, concerns or comments regarding the Website or its content.
• information from surveys that we may, from time to time, run on the Website for research purposes, if you choose to respond to, or participate in, them. Such information includes your age, your country/region of residence, your preferences or habits.
• Internet pages you have viWebsite immediately before coming to the Website or pages you visit immediately after leaving the Website.
• Information on your preferences and habits, namely the products that you like or the payment methods that you prefer. This information is provided by you in connection to your use of our Website or of any features of the Website (i.e., the ability to share content on social networks) and may be used, also in anonymous form, to improve our users' experience on our Website or to better understand you as our customer.
• Your personal computer IP address (which is the identification number of each personal computer connected to web and expressed as follows: XXX.XXX.XXX.XXX) or your mobile phone UDID code (which is the identification number of each mobile phone connected to web and expressed in forty characters); such information is not collected to identify you and it is only used to ensure the correct functioning of the Website features.

You are under no obligation to provide any such information. However, if you should choose to withhold requested information (e.g. your address or payment details), we may not be able to provide you with certain services. We will mark with an asterisk (*) on the Website's pages and forms any data that may be necessary for us to perform the service requested.  

What are Cookies

A cookie is a simple text file that is issued to your computer when you visit a webWebsite and which stores and sometimes tracks information about your use of a webWebsite. Each cookie is unique to your browser. It will contain some anonymous information such as a unique identifier, the webWebsite name and some digits and numbers. It allows a webWebsite to remember things like your preferences or what's in your shopping basket.

Although they do identify a user's computer, cookies do not directly identify users, and passwords and credit card information are not stored in cookies.

Cookies are not programs and therefore cannot contain viruses or other malicious software.

Most webWebsites you visit will use cookies to improve your user experience by enabling that webWebsite to remember you, either for the duration of your visit (using a 'session cookie') or for future visits (using a 'persistent cookie').

 How We Use Cookies

You can find any information about the various types of cookies we use on the cookies banner displayed on our Website

Controlling or deleting cookies

You have the choice to accept the above mentioned cookies via the cookies banner displayed on our Website.

If you change your mind and want to delete any cookies that are already on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. You can use the links provided below:

• Internet Explorer:

https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies

• Chrome:

https://support.google.com/chrome/answer/95647?hl=en-GB&hlrm=en

• Safari:

https://support.apple.com/kb/index?page=search&locale=en_GB&q=cookies%20safari

• Firefox:

https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-webWebsite-preferences

• Opera:

http://help.opera.com/Windows/10.00/en/cookies.html

Additional information on deleting or controlling cookies is available at www.AboutCookies.org, which includes additional useful information on cookies and how to block cookies using different types of browser or mobile device.

Please note that by deleting or restricting cookies or by disabling future cookies you may not be able to access certain areas or features of our Website or take full advantage of the Website.

To opt out of being tracked by Google Analytics across all webWebsites visit Google Analytics Opt-out Browser Add-on.

If you'd like to opt out of other third-party cookies relating to behavioural advertising, please go to www.youronlinechoices.eu. Opting out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

We (and other third parties acting on our behalf) may automatically track and collect information about the IP address, domain service, country/region location, time zone, language, the type of computer and web browser you are using and the pages you visit by using web beacons and other similar technology. If you access our Website via your mobile device, we may also collect information about your mobile provider and your mobile device. We use this information so that we can administer and improve our system, analyse trends, track users' movements, gather broad demographic information for aggregate use and detect suspicious or fraudulent transactions. If these automated processes reject your transaction on the basis that it is a suspicious or fraudulent, you may contact us and ask us to reconsider the decision within 21 days of receiving such notification. We are likely to use very similar criteria to review your transaction in person so there is no guarantee that the decision will be different.

We will use the information you provide only for the following purposes:

Information you give to us

We will use this information:

• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us. For this purpose, providing your personal data is necessary and any refusal may prevent you from purchasing products or receiving the services requested;
• to provide you with promotional, advertising and commercial information about our products and services that we feel may interest you, if you have ticked the relevant box situated on the form on which we collect your personal data (the order form or registration form to create an account with the Website) indicating your consent to receiving marketing material from us. We will provide the marketing materials via traditional mail, e-mail, telephone, fax, text, WhatsApp, WeChat SMS and MMS messaging, including newsletters, information on products, services, promotions and invitations to events. You can, at any time, indicate the preferred method of contact among those listed above and you may object to receiving promotional communications through all or only some of the methods of contact mentioned above. Provision of your personal data is optional and failure will not have consequences on your ability to purchase from the Website.
• to collect information on your preferences and habits, interactions with our Website and details of the purchases made and to use them to create group and individual profiles ("profiling") to send personalized communications subject to your consent. Personalized communications can be sent via traditional mail, e-mail, telephone, fax, text, SMS and MMS messaging. You can, at any time, indicate the preferred method of contact among those listed above and you may object to receiving promotional communications through all or only some of the methods of contact. Provision of your personal data is optional and failure will not have consequences on your ability to purchase from the Website.
• subject to your consent, to gather geolocation data with the purpose to identify the closest store to your position. Provision of your personal data for this purpose is optional and failure of providing your personal data will not have consequences on your ability to purchase from the Website;
• to notify you about changes to our service provided by the Website to perform our contractual obligations. Provision of your personal data in connection to a service you requested may be compulsory, failure to provide your personal data may prevent us from performing the service you requested;
• to ensure, based on our legitimate interests, that content from our Website is presented in the most effective manner for you and for your computer. Provision of your personal data for this purpose is optional and failure will not have consequences on your ability to purchase from the Website.

 Information we collect about you

We will use this information:

• to administer our Website and your account to perform our contractual obligations;
• for internal operations, including identifying visitors to the Website, troubleshooting, auditing the downloading of data, data analysis (demographic and sales data), testing, research, statistical and survey purposes based on our legitimate interests;
• based on our legitimate interests or your consent, where applicable, to improve our Website to ensure that content is presented in the most effective manner for you and for your computer;
• to identify visitors to the Website by using cookies subject to your consent;
• to allow you to participate in interactive features of our Website, subject to your consent;
• based on  our legitimate interests, to keep our Website safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you, subject to your consent;
• to make suggestions and recommendations to you and other users of our Website about products or services that may interest you or them in our legitimate interests and subject to your consent where relevant;
• to send you information we think you may find useful or which you have requested from us, including information about our products and services,  to perform our contractual obligations;
• for profiling activities, to create individual and group profiles on the basis of your activities online and your interactions with our Website, provided that you have given us your prior consent;
• based on our legitimate interests, to establish, exercise or defend legal claims, including respond to requests from, and other communications with, competent public, governmental, judicial or other regulatory authorities, respond to valid legal process, investigate or participate in civil discovery, litigation, or other legal proceedings, or protect or defend your rights, property or security or ours.  

You can tell us not to contact you with information regarding our products and services, either at the point such information is collected on the Website (by checking - as directed - the relevant box) or, where you do not wish us to continue to use your information in this way, by following the unsubscribe instructions on any communications sent to you. You can also exercise your rights at any time by contacting us using the Contacting Us details at the end of this privacy and cookies policy.

The legal basis on which we process your personal data is as follows:

• Where it is necessary to obtain your prior consent to the processing concerned, in order for us to be allowed to do it, we will obtain and rely on your consent in relation to the processing concerned and comply with any subsequent modification of your choices.
• Otherwise, we will process your personal data only where the processing is necessary:

1. for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract;
2. for compliance with a legal obligation to which we are subject or with any order and measure issued by competent judicial or administrative authorities; or

• for the purposes of the legitimate interests pursued by us or another person, provided that this will only be in circumstances in which those legitimate interests are not overridden by your interests or fundamental rights and freedoms which require protection of personal data. When we rely on legitimate interest we may refer to our interest in the correct functioning of the webWebsite, our interest in performing, where applicable, direct marketing activities, our interest in improving the user experience on our Website and in understanding the effectiveness of our advertising, as well as direct marketing activities.

If you wish to obtain further details regarding our legitimate interests, please contact us by using the Contacting Us details at the end of this privacy and cookies policy.

The processing of your personal data is carried out at EMILIO PUCCI S.r.l. registered offices, located in in Milan, Via Fieno 3, 20123 (MI), Italy.

We may disclose your personal data to our employees authorized for processing in our CRM, Digital and E-commerce, Finance and Legal Departments, as well as, in case you choose to pick up your purchase at any store, to the appointed sales staff.

We may also disclose your personal data to any of our affiliates, including the EMILIO PUCCI group companies, acting as our data processors, or to our agents or contractors acting as our data processors (namely payment management companies; product shipping and delivery companies; legal, tax and auditing experts) who assist us in providing the services we offer you through the Website, processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks, from time to time.

We have designated GLOBAL-E NL B.V. a company incorporated in The Netherlands with registered number 72541466 whose registered office is at Krijn Taconiskade 430 1087 HW Amsterdam, The Netherlands (Global-e) as our sales facilitation and e-commerce partner for e-commerce.

Global-e and Pucci act as independent data controllers, Global-e having its own Privacy Policy and Cookies Policy (which is available on this link https://www.global-e.com/consumer-privacy-policy), which are separate from this privacy and cookies policy.

We may share your information with other companies and organizations for identity verification and fraud protection purposes to the extent permitted by applicable laws.

In the event that we undergo re-organization or are sold to a third party, the personal data we hold about you may be transferred to that re-organized entity or third party.

You should be aware that we may be under a duty to disclose or share your personal data and/or user information in order to comply with any applicable legal obligation. We may also disclose your personal data if we believe that such action is necessary to prevent fraud or cybercrime or to protect the Website or the rights, property or personal safety of any person.

Recipients of your personal data may act as independent data controllers, as our data processors or as persons authorized from us to process personal data. You can contact us at any time, using the contact details below, to receive an updated list or request further information on the recipients of your personal data.

When we share your personal data with the entities mentioned above, it may imply transfers of your personal data at a destination outside of the European Economic Area (EEA) and the United Kingdom, namely to the US and Canada. This may include transfers to third countries whose laws provide levels of protection for personal data that are not always equivalent to the level of protection that may be provided in your own country.  Where we transfer your information, we will take all reasonable steps to ensure that your personal data is subject to appropriate safeguards, such as the EU approved Standard Contractual Clauses (as amended by the UK Addendum issued by the UK Information Commissioner, where relevant) and that it is processed securely and in accordance with this privacy and cookies policy and with the Data Protection Law. We will provide you with details on the applicable safeguards and transfers upon request made by using the Contacting us details at the end of this privacy and cookies policy.

The Website may, from time to time, contain links to external Websites. If you follow a link to any of these webWebsites, please note that these webWebsites have their own privacy policies and processes and that we do not accept any responsibility or liability for these policies and processes. Please check these policies before you submit any personal data to these webWebsites.

Payment details you provide will be encrypted using secure sockets layer (SSL) technology before they are submitted to us over the internet. Payments made on the Website are made through our payment gateway provider from time to time, including Apple Pay, Google Pay, PayPal, Adyen, Klarna, iDEAL and Sofort. You will be providing credit or debit card information directly to such payment provider which acts as independent data controller and operates a secure server to process payment details, encrypting your credit/debit card information and authorising payment. Information which you supply to such payment providers is not within our control and will be subject to their own privacy policy and terms and conditions. For more information please contact us.

We place great importance on the security of all personal dataassociated with our users. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal data under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to personal data. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it. In this respect, we recommend using a strictly personal password when logging in and following the instructions provided by the Website to guarantee its confidentiality.  

You should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit via the Website whilst it is in transit over the internet and any such submission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

It is advisable to close your browser when you have finished your user session to help ensure others do not access your personal data if you use a shared computer or a computer in a public place.

We process personal data only for so long as it is necessary for the purpose(s) for which it was originally collected, after which it will be deleted or anonymized except to the extent that it is necessary for us to continue to process it for the purpose of compliance with legal obligations to which we are subject. In particular, data collected in connection to the sale of products and services, is stored, for accounting reasons, for a period of time of ten years from the transaction as required by law. Please note that the data retention period actually applied by us may vary, depending on the relevant purpose as described hereinafter.

With respect to the services and products provided to you, we will keep your personal data during the period of our contractual relationship, extended by the applicable statute limitation period.

With respect to thedata collected in connection to our marketing activities, including personalized marketing activities, is stored on our databases for a period of time of seven years, according to the Data Protection Impact Assessment that the Company performed.

With regard to cookies we may place as part of your use of our online services, please refer to the “Cookies” section above.

With respect to the processing carried out in order to protect or defend your rights, property or security or ours, we will keep your personal data for the time of the relevant dispute or statute limitation period.

To receive further information on data retention, please contact us as indicated below.

You have the following rights in relation to personal data relating to you that we process:

• You may request access to your personal data and to receive a copy of the personal data processed by us; You may request that any incorrect or incomplete personal data about you that we are processing be rectified or completed.
• In certain circumstances (normally where the personal data has been provided by you and it is no longer necessary for us to continue to process it), you may be entitled to request that we erase the personal data concerned. For example, this right does not apply if the processing is necessary for the establishment, exercise or defense of legal claims.
• You have the right to request restriction of processing of your personal data. In this case, we will process your personal data only for the purposes permitted by applicable laws (such as for the exercise of a right in court, to protect the rights of another person, for reasons of relevant public interest).
• You have the right to data portability, that is the right to receive the personal data concerning you, in a structured, commonly used and machine-readable format. Such data can, as such, be transmitted to another data controller.
• In certain circumstances, such as with regards to the processing of your personal data for direct marketing purposes, you have the right to object to the processing of your personal data.
• Where we are processing personal data relating to you on the basis of your prior consent to that processing, you may withdraw your consent at any time, after which we shall stop the processing concerned.
• If you consider that the processing of your personal data being conducted by us infringes the Data Protection Law, you can contact us or you have the right to lodge a formal complaint with the competent supervisory authority, in particular in the country of your habitual residence, place of work or place of an alleged infringement.

In order to exercise any of your rights, or if you have any other questions about our use of your personal data, please contact us by using the Contacting Us details at the end of this privacy and cookies policy. Please note that we may request you to provide us with additional information in order to confirm your identity.  

CCPA grants California residents certain rights and provides for restrictions on particular business practices as set forth below. This Paragraph 13 shall only apply to California residents, as defined under sections 1798.140 (c), (g), 1798.145(a)(6) of the CCPA.

Right to Opt-out of Sale of personal data

California residents have the right to opt-out of our sale of their personal data. We do not and will not sell any of your personal data.

Notice at Collection

At or before collection of personal data, notice must be provided to California residents concerning personal data categories collected and the purposes for which such information is used.

Verifiable Requests to Delete and Requests to Know

Subject to certain exceptions, California residents have the right to make the following requests, at no cost

• Request to Delete

California residents have the right to request deletion of their personal data that we have collected about them and to have such personal data deleted, except where an exemption applies. 

• Request to Know

California residents have the right to request and, subject to certain exemptions, receive a copy of each personal data that we collected in the preceding 12 months and to have this delivered either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format allowing the resident to transmit this information to another entity without hindrance. California residents also have the right to request to provide them certain information about how we have handled their personal data in the preceding 12 months, including the following:

1. categories of personal data collected;
2. categories of sources of personal data;
3. business and/or commercial purposes for collecting and selling their personal data;
4. categories of third parties/with whom we have disclosed or shared their personal data;
5. categories of personal data that we have disclosed or shared with a third party for a business purpose;
6. categories of personal data collected; and
7. categories of third parties to whom the residents’ personal data has been sold and the specific categories of personal data sold to each category of third party.

California residents may make Requests to Know up to twice every 12 months.

Right to Non-Discrimination

CCPA prohibits discrimination against California residents for exercising their rights under the CCPA. Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices, rates, or penalties on residents who exercise their rights under CCPA, unless doing so is reasonably related to the value provided to the business by the residents’ data. 

Financial Incentives

A business may offer financial incentives for the collection, sale or deletion of California residents’ personal data, provided the incentive is not unjust, unreasonable, coercive or usurious, and is made available in compliance with applicable transparency, informed consent, and opt-out requirements. California residents have the right to be notified of any financial incentive offers and their specific terms, and the right to opt-out of such incentives at any time; residents may not be included in such incentives without their prior informed opt-in consent. We do not offer any incentives at this time.

You can exercise your rights, at any time, by emailing us at client.experience@pucci.com or by emailing our Data Protection Officer at dpo@pucci.com.

Please note that we may be required to ask you for further information in order to confirm your identity before we provide the information requested.

EMILIO PUCCI S.r.l., with registered offices in Milan, Via Fieno 3, 20123 (MI), Italy, is the data controller. You can submit any questions, concerns or comments you have about this privacy and cookies policy or any requests concerning your personal data by email to client.experience@pucci.com.

You can also contact our Data Protection Officer, at Regulatory Law Firm, in Rome, Via di Villa Ricotti 26, 00161 (RM), at the following email address: dpo@pucci.com.

We reserve the right to review, amend or merely update, in whole or in part, at its sole discretion, in any way and/or at any time this Websiteprivacy and cookies policy, also in accordance with any statutory or regulatory amendments to personal data protection provisions. The amendments and updates of this Website privacy and cookies policy may be, as the case may require, notified to the users by means of (i) emails to users registered with the Website and/or (ii) published on this page, and they shall be binding as of their publication and/or notification. Therefore, please visit this section regularly in order to check the latest publication and update of this Website privacy and cookies policy or check your email inbox. If such change to the privacy and cookies policy requires your consent, you will have a choice to consent as to whether or not we may use your personal data in this different manner.

This policy was last updated in September 2023.