1 • Preamble
2 • Data controllers and Data protection officer
The Moncler Local Company and Industries act, respectively, as data processor and controller.
The Moncler Local Company, as data processor, might process your personal data on behalf of Industries in order to manage online sales activity (e.g. managing orders and payments), as well as for "pick-up in store", "return in store", "click from store" and "click and reserve" services as defined in section 3.3.
The Local Moncler company can be contacted by writing to Moncler Rus LLC, registered offices at Bolshoy Zlatoustinsky pereulok, building 1, construction 1, room I - 101000 Moscow - Russian Federation.
As data controller, Industries will process your personal data also in order to carry out marketing activities (e.g. newsletters) and building of group and individual profiles (profiling) as described in section 3.4. Industries can be contacted by writing to Industries S.p.A., via Stendhal n. 47, 20144 - Milan (MI), Italy or by email at email@example.com.
Industries will manage your personal data in the context of your navigation experience through our App and access to reserved services as defined in sec. 3.1 and 3.2 below.
Industries has appointed a Data Protection Officer (DPO), who is domiciled at the offices of Industries S.p.A. and it is available as follows: firstname.lastname@example.org.
3 • Sources of data and the purposes of data processing
3.1 Browsing data
During their normal operation, the IT systems used to operate the App acquire some of your personal data, the transmission of which is implicit in the use of Internet communication protocols. This information is not collected for the purpose of identifying you, but may lead to your identification if, for example, it is combined with information held by a third party. This category of data includes the IP address and domain name of your smartphone, the URI (Uniform Resource Identifier) addresses 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 code indicating the status of the reply given by the server and other parameters relating to your operating system. We use this data for the sole purpose of obtaining anonymous statistical information on the use of the App and to check it is working properly. The data collected is deleted immediately after processing. The data could be used to ascertain responsibility in the event of cybercrime committed to the detriment of the Services.
3.2 Registration information and further information provided by the user
Use of the App does not require the creation of a personal account. However, in order to access certain pages reserved for registered users and, for example, to send us a request for information or feedback on the Services, you must create a personal account and become a registered user. When you create your account, you will be asked to enter the following registration information:
In addition, personal data directly provided by you when you place an order to purchase an item will be collected and processed, this consists of data collected by sending electronic mail, interacting with the functionality of the App and requesting services offered by the App. The personal data we collect and process includes your first name, surname, gender, nationality, email address, shipping and payment methods, credit and/or debit card number and shopping habits.
Should you wish to avail of our online size recommendation service, we will collect your body sizes (e.g. height, weight, age).
3.3 Purpose of the processing
Providing the above information is necessary in order to create an account and also to respond to and manage requests for information and/or user feedback; to provide the services requested through the App, including registration and subsequent updates and to manage the activities organised through the App; to carry out statistical analysis and surveys; to manage sales activities and to provide sales and after-sales services, such as administration, accounting, returns and guarantee management, customer relationship management, including compliance with legal obligations, national and EU regulations (including anti-money laundering regulations), to prevent fraud and to exercise rights in legal proceedings.
Any refusal by you to provide this information would still allow you to use the App, but would prevent you from using some of our Services reserved for registered users.
In addition, your personal data must be processed in order to fulfil the contractual relationship arising from the purchase of Moncler products. The provision of such data is a contractual obligation. Should you need suggestions about sizes, we will process your body sizes with your prior consent. You are free to disclose your data to us or not, but in the absence of the requested data it will not be possible to conclude or execute the agreement and your requests. This means that you will not be able to purchase Moncler products and that it will not be possible to handle your requests.
3.4 Further purposes of the processing
With your consent, which is optional, Industries will use your personal data for further purposes such as marketing, commercial or advertising communications, direct sales, market research, in-store sales support worldwide through email (newsletter), telephone, SMS, MMS,, instant messaging, and traditional mail, including sending invitations to events. You may at any time indicate your preferred means of contact from among those listed above and you may refuse the receipt of promotional communication by any or all of these means of contact. For profiling and marketing purposes performed through cookies or other tracking technologies, please refer to the cookie section and relevant online consent form.
With your consent, which is optional, Industries collects information about your preferences, habits and lifestyle as well as details of purchases made in order to use these to create group and individual profiles ("profiling") and to send you personalised communications. Personalised communication may be sent by email (newsletter), phone, SMS, MMS, instant messaging and post mail. You may at any time indicate your preferred means of contact from among those listed above and you may refuse the receipt of promotional communication by any or all of these means of contact.
Consent for the above marketing and profiling purposes is optional and refusal will not have any consequences. Data may be provided by you on registration at our points of sale by means of paper and/or electronic forms, acquired during visits to our stores belonging to the Moncler Group or through interaction with websites, internet applications and mobile applications belonging to the Moncler Group.
3.5 Legal grounds for processing
Your personal data is only processed if one of the legal requirements laid down by current legislation is met, and specifically:
3.6 Information collected through cookies and other technologies
On the App you may also find social buttons/widgets, in other words those distinctive "buttons" showing social network icons like Facebook, Instagram and Twitter. These buttons allow users who are using the App to share and interact with social networks with a simple "click".
We hereby inform you that our Services use:
The above cookies may be:
While the use of technical cookies does not require the user's consent, the use of profiling cookies always requires the user's optional consent and the user can choose which profiling cookies to consent to.
Cookies can be managed and disabled using the dedicated cookie consent tool, when accessing the App.
The table below shows the cookies used to offer our Services:
|Domain||Supplier||Type||Name of cookie||Purpose|
|adnxs.com||AppNexus||Profiling Third Party||various||Used to display targeted advertising to users who have previously visited this site. User preferences are stored in order to customize the advertisements.||30 days|
|360yield.com||Improve Digital (PubliGroupe)||Profiling Third Party||various||Used to display targeted advertising to users who have previously visited this site. User preferences are stored in order to customize the advertisements.||90 days|
|adsrvr.org||TheTradeDesk||Profiling Third Party||various||Used to display targeted advertising to users who have previously visited this site. User preferences are stored in order to customize the advertisements.||1 year|
|bidswitch.net||IPONWEB per RTB||Profiling Third Party||various||30 days|
|bluekai.com||Bluekai (Oracle)||Profiling Third Party||various||6 months|
|casalemedia.com||CasaleMedia||Profiling Third Party||various||1 year|
|krxd.net||Salesforce||Profiling Third Party||various||10 years|
|lijit.com||Federated Media Publishing per Criteo||Profiling Third Party||various||1 year|
|openx.net||OpenX||Profiling Third Party||various||2 year|
|outbrain.com||Outbrain||Profiling Third Party||various||1 day|
|rlcdn.com||Live Ramp Inc (Rapleaf)||Profiling Third Party||various||1 year|
|rubiconproject.com||Rubiconproject||Profiling Third Party||various||366 days|
|smartadserver.com||Smart||Profiling Third Party||various||13 months|
|tapad.com||TapAd||Profiling Third Party||various||30 days|
|teads.tv||Teads||Profiling Third Party||various||1 year|
|yieldlab.net||Yieldlab||Profiling Third Party||various||24 months|
|yoox.biz||YNAP||Profiling Third Party||various||10 years|
|yoox.it||YNAP||Profiling Third Party||various||10 years|
|criteo.com||Criteo||Profiling Third Party||various||9 years|
|doubleclick.net||Profiling Third Party||various||13 months|
|google.com||Profiling Third Party||various||13 months|
|yandex.ru||yandex||Profiling Third Party||various||1 year|
|amazon-adsystem.com||Amazon||Profiling Third Party||various||13 months|
|facebook.com||Profiling Third Party||various||180 days|
|adroll.com||adRoll||Profiling Third Party||various||120 days|
|adnxs.com||AppNexus||Profiling Third Party||various||30 days|
|yahoo.co.jp||Yahoo||Profiling Third Party||various||60 days|
|bing.com||Bing||Profiling Third Party||various||13 months|
|igodigital.com||Saleforce Marketing Cloud||Profiling Third Party||various||180 days|
|youtube.com||YouTube||Profiling Third Party||various||2 years|
4 • Methods of data processing and data storage
Period of Use and Retention of Personal Data
We will retain your personal data until the purpose for their use is achieved according to our internal data retention policy. In particular, we hereby specify that we have a general retention period of 10 years from the time of initial collection for your personal data that is processed for our invoicing and accounting purposes, save for the circumstances in which national applicable law may provide for different retention requirements.
In principle, we will promptly destroy your personal data in our possession once we achieve the purpose of collection and use of your personal data. However, the following categories of your personal data will be retained by us for the duration of the periods specified below.
Data relating to payment: until such time as the payment has been confirmed and the administrative and accounting formalities relating thereto have been completed, after the expiry of the right of withdrawal and after the deadline for contesting the payment.
Data collected in connection with the use of Services offered on the App (e.g. "pick-up in store", "return in store", "click from store", "click and reserve"): such data is stored until the service has been fully performed; data related to user requests to our Customer Service department: relevant data will be retained until your request is resolved.
With particular reference to the legal protection of our rights, we hereby specify that we keep data in accordance with the local statute of limitations.
If you have consented to your personal data being processed, the data relating to your purchases will be kept for marketing and profiling purposes for a period of 7 years as per the authorization obtained from the Italian Data Protection Authority, issued on May 25, 2018 in favour of Industries S.p.A., which is the entity in charge of such processing operations. After this retention period, the data will be automatically deleted or permanently
and irreversibly anonymised.
In any case, for technical reasons, the termination of the processing and the subsequent cancellation or irreversible anonymisation of the related personal data will be final within thirty days of the terms indicated above.
Procedure and Method for Destruction of Personal Data
In principle, we will promptly destroy your personal data in our possession once we achieve the purpose of collection and use of your personal data.
The process and means of destroying your personal data are as follows.
Your personal data will be transferred to a separate database (or separate document file for paper documents) and destroyed after storage for a certain period pursuant to our internal policy or applicable laws and regulations (please refer to the provisions on retention and use period).
Such personal data will not be used for any purpose other than the purpose permitted under the applicable laws and regulations.
The personal data that has been printed on paper will be shredded through the use of document shredder or incinerated.
The personal data stored in electronic file format will be deleted by using technical means that will not allow data recovery.
5 • Scope of disclosure
5.1 Internal and external communication of personal data
Personal data is accessible to our duly authorised personnel (e.g., Digital, CRM, Retail, IT personnel) as necessary and is disclosed to third parties in the following cases: (i) when disclosure is required by laws and regulations applicable to legitimate third party recipients, such as authorities and public bodies for their respective institutional purposes, e.g. anti-money laundering legislation, court authorities; (ii) disclosure to third parties in the event of extraordinary transactions (e.g. mergers, acquisitions, sale of business, etc.); (iii) communication to the third party in charge of fraud prevention services.
Personal data is also shared with our service providers, e.g. for services of a technical and organisational nature that are necessary for the purposes indicated above, such as independent partners, including associates, shipping companies, marketing, payment management, etc, the list of which could be communicated upon request.. We provide such parties only with the data necessary to perform the agreed services and they act as data processors in accordance with art. 28 GDPR, based on instructions received from Industries (depending on the relevant data controller).
It is expressly stated that Industries does not disclose your personal data to third parties for marketing or profiling purposes.
Finally, for the purposes of profiling, marketing and customer relationship management (to provide you with the same level of service worldwide), other companies in the Moncler Group may access your personal data as data processors in accordance with art. 28 GDPR, based on instructions received from Industries.
5.2 Data transfer abroad
For the performance of certain processing activities concerning your Personal Data, Moncler Companies communicate such data to external parties located in countries that do not belong to the European Union (EU) or the European Economic Area (EEA) (hereinafter referred to as "Third Countries"), the list of which will be updated from time to time and/or available upon request; the lawfulness of such transfer is, in any case, guaranteed through the mechanisms provided for by art. 46 of the GDPR, since Moncler Companies have executed the Standard Contractual Clauses approved by the European Commission (supplemented by additional technical/organisational/legal measures) or, as applicable, due to the existence of an adequacy decision pursuant to Art. 45 of the GDPR issued by the European Commission.
These external parties will process your Personal Data as independent data controllers or as data processors, regularly appointed by Moncler Companies in accordance with the legislation regulating data protection (depending on the role they have in relation to the processing).
6 • Rights of the data subject
Below is a general description of them and how to exercise them:
National laws may provide for additional data subjects rights. For additional information you can contact us at the contact details indicated below.
To exercise the rights described above, you can:
If you believe that your personal data has not been processed correctly, you may lodge a complaint with the local supervisory authority.
To obtain the list of our external data processors, of the third parties with whom Moncler share your personal data please contact the controllers through the modalities set forth above.