With this policy we intend to inform the visitors to the website www.geox.com of the policy adopted regarding the Protection of Personal Data, underlining our commitment and attention for the protection of your privacy. Please read carefully our Privacy Policy which applies both in case you access the Site and simply decide to browse using our services, without purchasing any products, and in case you decide to shop with us.

-

This Policy is effective as of September, 2023.

Geox S.p.A. hereby wishes to inform visitors to the “www.geox.com” website (hereinafter the “Website”) of its policy with respect to collecting, using and sharing of personal data of Website users, emphasizing its commitment and attention to protecting the privacy of Website visitors. Please read our Privacy Policy carefully, as it applies when you access, view or use the Website, even when you simply navigate it without purchasing any products.

Please also read the Terms and Conditions of Use of the Website, into which this Privacy Policy is incorporated by this reference, and which, together (and also including any additional documents referenced in, or incorporated into the Terms and Conditions), form the agreement between you and Geox S.p.A. with respect to your use and access to our Website.

Navigation within the Website is free and does not require registration, with the exception of certain areas in which you may freely and expressly provide a set of personal data to access certain services (e.g. to register for My Geox, sign up for email updates or request information, etc.). Data provided by you to access these additional services shall be in accordance with EU Regulation 679/2016 General Data Protection Regulation (the “Regulation”) and in accordance with the provisions of this policy. “Personal data” as used herein means any information relating to an identified or identifiable natural person, such as, but not limited to, your name, email address, phone number, or mailing address.


APPLICABILITY

This policy applies to information we collect:

  • On the Website.
  • In email, text, and other electronic messages between you and the Website.
  • When you use our “contact us” or similar feature on the Website, when you call our telephone number listed on the Website, or when send emails to the e-mail address listed on our Website.
  • In our brick and mortar stores.
  • Through any other means associated with or relating to the Website.

This policy does not apply to information collected by:

  • us through any other means, including on any other website operated by Geox S.p.A. or any third party (including our affiliates and subsidiaries); or
  • any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.


THE CHILDREN’S ONLINE PRIVACY PROTECTION ACT DISCLOSURE (PERTAINING TO CHILDREN UNDER THE AGE OF 13)

In accordance with the requirements of The Children’s Online Privacy Protection Act and its equivalent legislation in California, we do not knowingly collect personal data from children under the age of thirteen (or sixteen in California). If you are under thirteen (or sixteen if you live in California)), do not use or provide any information on this Website or on or through any of its features or register on the Website, make any purchases through the Website or contact us, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under thirteen (sixteen in California) years of age, we will delete that information. If you believe we might have any information from or about a child under the age of thirteen (sixteen, if you live in California), please contact us at privacy@geox.com.


INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

We may collect several types of information from and about users of our Website, including information:

  • that is personal data;
  • that is about you but individually does not identify or permit us to identify you, such as the type of browser you use; and
  • about your internet connection and service provider, the equipment you use to access our Website, your browsing history, and other usage and technical details.

We collect this information:

  • Directly from you when you provide it to us;
  • Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies; or
  • From third parties, for example, our business partners.


INFORMATION PROVIDED ACCORDING TO THE REGULATION (AS DEFINED HEREIN).

1. Who is the Data Controller

1. Who is the Data Controller

Geox S.p.A., with registered office at Via Feltrina Centro 16, 31044 Biadene di Montebelluna, Treviso (Italy), VAT no. IT03348440268, is deemed pursuant to the European General Data Protection Regulation (the “Regulation”) to be a data controller, because it makes decisions as to what personal data about you it requires or needs to collect or process, and how to use and share that data (hereinafter “Data Controller”) and S & A Retail, Inc. with registered office at 530 7th Avenue, Suite 1005, New York NY 10018, Federal Tax ID no. 58-2485366, is joint Data Controller pursuant to the Regulation with respect to your personal data related to sales of our products to you, invoicing, delivery and after-sales services.

When we refer to “Geox” or “us”, “our” and similar variants in this policy, we are referring to both Geox S.p.A. and S & A Retail, Inc., collectively.

2. How you can contact us

2. How you can contact us

For any questions, need for information or exercise of your rights, you can contact us by sending an e-mail to privacy@geox.com or by writing to: 


S & A Retail, Inc. 

530 7th Avenue, Suite 1005

New York

NY 10018, USA

Attention: Customer Service


Geox S.p.A. 

Via Feltrina Centro n. 16

31044, Biadene di Montebelluna (TV), Italy.

Attention: Customer Service


Data Protection Officer of Geox S.p.A. can be contacted at dpo@geox.com.

3. Types of personal data processed

3. Types of personal data processed

Registration is not required in order to simply view or access the Website. However, there are sections of the Website that do require registration or the use of a username and password to access certain information (e.g., to register your account). There are also services on our Website for which you need to provide your personal details (e.g. receive our email updates or when you contact us, etc.).

Personal data obtained by Geox through the use of the Website will be processed by Geox in accordance with this policy.

The personal data we request on the Website such as your first and last name, telephone number, and e-mail address, may be marked as “mandatory” [e.g., indicated with a (*)] as they are necessary to access the services of the Website you wish to use (e.g., if you place an order). Failure to provide this data marked as “mandatory” will result in our inability to provide you the requested service (e.g., if you fail to give us your email address, we cannot send you our email updates; if you fail to provide your mailing address, we cannot send you any products you may wish to order). Failure to provide data marked as “optional” will not have any consequences.

4. Purposes

4. Purposes

We may collect non-personal data (data which does not by itself identify you specifically, and which cannot be used when combined with other data for the purpose of identifying you specifically) about your computing devices, network, internet service or other technical data pertaining to your equipment, internet service provider, and your use of the Website, without limitation, and process, use or share this data for any purpose without notice to you, or consent from you.

Personal data about you is collected, processed, used, and sometimes shared with third parties as described in this policy, for the following purposes which are related to your use of the Website and our services (e.g., when you purchase our products):


A. Purchasing:

Data provided by completing the purchase process on the Website are necessary to:

  1. complete the sale of the products you purchased (which allows us to perform our obligations pursuant to our contract with you relating to such sale);
  2. fulfil tax and accounting obligations relating to your purchase (e.g., to report taxes you paid on the purchase to the applicable taxing authority and disburse those tax funds to them);
  3. handle any after-sales services (e.g. customer service functions, such as if you need to make a return or tell us about a concern with a product you purchased);
  4. o comply with our legal obligations.

Our collection, processing and use of this type of personal data does not require your specific consent pursuant to the Regulation.


B. Sign up e-mail registration (newsletter):

If you sign up to receive our newsletter, email updates, you will be required to provide us with your email address. This personal data will be processed on the basis of your consent (when you sign up to receive our email updates).


C. Benefeet Loyalty Program:

If you join our Benefeet loyalty program, we will process your data – and data relating to your purchases – to:

  1. Create and maintain your personal Benefeet account so that you may access special members-only services, initiatives, and benefits on the Website (e.g., getting discounts, access to dedicated promotions, making purchasing faster with “fast checkout”, checking your purchase history, etc.). Your personal data in this case will be processed on the basis of your consent (when you provide it by opening your personal account), pursuant to Article 6(1)(a) of the Regulation. Your personal data in this case will be processed on the basis of the contract concluded with you (when you register and open your personal account).
  2. Marketing purposes: If you have provided your consent for us to do so, we may send you e-mails updating you about our products, our services, including by sending you advertising and promotional materials, which may include personalized information obtained through profiling (if you have agreed in advance to receive such communications from us). You can freely withdraw your consent at any time by updating your preferences on the Website. You may also refuse to provide your consent to these activities initially but can still subscribe to Benefeet.
  3. Purpose of analysis of your preferences: If you have consented, we will collect your personal data for the purpose of profiling (a marketing tool we use to understand our customers, which includes analyzing your online activities, so that we may understand your interests, and your purchasing preferences, among other things). This activity allows us to improve our offerings and our Website, and to personalize our offers to you.

We will process this personal data based on your consent only. You can always freely withdraw your consent by updating your preferences on the Website. You may also refuse to provide your consent to these activities initially but can still create your Benefeet account.

Please note that all of our data analytics concerning your preferences will not be entirely automated and may be carried out and assessed by our representatives.

Please see our Benefeet Policy for a detailed description of how and for which purposes we process your data.


D. Contact us:

We will collect your personal data when you provide it to us through the “contact us” (“Customer Service”) or similar available feature (e.g. live chat) on our Website, or if you contact us via e-mail or at the telephone number listed on our Website. Please note that, if you use our live chat feature, your data will be processed for providing you with the requested assistance and customer care purposes.

Collection, processing and use of this type of data is necessary for us to respond to your query or request for information, as well as for allowing us to better improve our products and services. Your consent is not required for this type of processing, as our processing of this information is required for us to complete our obligations pursuant to our contract with you.

5. Security

5. Security

We may process your personal data in both electronic and paper form.

Geox will use commercially reasonable efforts in an attempt to ensure that your personal data entrusted to us as described in this policy will be processed lawfully.

We will use commercially reasonable efforts to ensure that your personal data collected from the Website is transmitted from the Website to our servers through an https connection, in an attempt to prevent interception by unauthorized third parties.

We implement security measures designed to ensure the security of the Website.

6. Profiling

If you give us your consent to use your personal data for marketing and profiling purposes, we may analyze your information (e.g. your purchases, Website usage data – including pages visited, products you put into your shopping cart on our Website, etc.) and put that information together with your personal data in order to understand your tastes and preferences, so that we can improve our services and also send you personalized offers.

Please note that all of our data analytics concerning your preferences may not be solely automated, but may be carried out and assessed by our representatives.

7.  Data retention

7. Data retention

We may retain, share, process and use non personal data in perpetuity for any purpose.

The following retention periods will apply to your personal data:

  • Purchasing: Your personal data will be processed for as long as it is necessary to manage and complete your purchases, and thereafter as required for us to comply with our tax, accounting and legal obligations; subsequently the data will be deleted or rendered anonymous.
  • Sign up e-mail registration: Your personal data will be processed for the entire time that you subscribe to the email updates service or, in any event, until your consent is withdrawn (which you may do at any time); thereafter, the data will be deleted or rendered anonymous.
  • Benefeet loyalty program: The data related to your registration are retained for 5 years from your last purchase, access to your profile, or from your registration. Data concerning the details of your purchases are generally kept, for marketing and analysis purposes, for 36 months. Please see our Benefeet Policy.
  • Marketing and profiling: If you provide your consent for us to process your personal data for marketing and profiling purposes, we will process your sales-related data for up to 36 months (for marketing and profiling purposes).
  • Contact Us: Your personal data will be processed for the time it takes to properly handle your request and to allow us to better understand our customers and improve our services; then your personal data will be anonymized (once anonymized, it will no longer be considered personal information).  

Any personal data provided to us on or through the Website or when contacting us at the email address or telephone number provided on the Website shall be processed for the length of time specified above.  

With regard to the retention times for data collected through the use of tracking technologies (e.g. cookies), please see our Cookie Policy.

8. Links to other websites

If you access such other websites by using a link provided on our Website, please be aware that this policy does not apply to collection, processing, transfer or use of your information on such sites. Please review the privacy policy on those third party sites to understand the third party’s privacy policies. We do not control and are not responsible for any data collection, usage, sharing or processing activities of such third parties.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

9.  Tracking and/or personalization tools

9. Tracking and/or personalization tools

The Website uses “cookies” or other tracking technologies, which may be technical (i.e. to facilitate navigation and use of the Website) and/or profiling (i.e. to analyze users and their behaviors and preferences, and provide them with targeted advertising). The use of the latter technologies requires your consent.

Also, some content or applications, including advertisements, on the Website may be served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal data or they may collect information, including personal data, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

For a detailed explanation of cookies used by this Website and how to deactivate them, please read our Cookie Policy

10. Data processors and disclosures of personal information

10. Data processors and disclosures of personal information

In addition to Geox, the data processing connected with the services provided by or through the Website may be carried out by: (i) authorized data processing personnel appointed by Geox; (ii) companies providing services related to the management, maintenance and development of the Website; (iii) companies entrusted to manage the sales, payment and delivery functions for the products; (iv) companies responsible for the preparation, handling and sending of email updates, advertising and promotional materials; (v) companies that analyze your purchases (e.g., the type of products and when you purchased them) and the use of our Website (e.g., your browsing on our Website, your interest in our advertising etc.); (vi) companies responsible for the handling of “Customer Service”; (vii) our affiliates and those who operate our and their respective retail stores.

A complete list of external data processors appointed by Geox can be obtained by contacting privacy@geox.com. Geox will endeavor to provide this list within a reasonable time from your verifiable request.

11. Data transfer outside US and the European Union

11. Data transfer outside US and the European Union

To enable us to properly manage our Website, your personal data will be held in the European Union, or transferred to countries outside the European Union. When doing so, Geox will use reasonable efforts in an attempt to ensure that such transfer occurs in compliance with the guarantees, safeguards and rights provided in the Regulation, to the extent applicable to you.

The Regulation provides that the transfer of personal data to third countries outside the European Union can be carried out when: (i) such transfer is performed in accordance with Article 45 of the Regulation) (i.e., if data are transferred to a country to which the EU Commission has granted the designation of “adequate”, meaning they are considered to provide an adequate level of protection with respect to personal data); or (ii) as permitted pursuant to Articles 46 and 47 of the Regulation (e.g., to companies which have agreed to be bound by certain standard contractual clauses published by the European Union, if certain circumstances are met; or to companies who are subject to binding corporate rules approved by the European Union authorities; or companies part of the “Data Privacy Framework” between the US and the EU: you can find more information on the agreement at https://www.dataprivacyframework.gov/s/). Geox endeavours to comply with). Geox endeavors to comply with these provisions of the Regulation.

Upon request and given a reasonable amount of time for us to respond, you may write to privacy@geox.com to request information on the existence of an adequacy decision or on the safeguards adopted to allow your data to be transferred.

12. Privacy Rights

12. Privacy Rights

By writing to privacy@geox.com, you can at any time exercise your rights under Articles 15 to 22 of the Regulations, including accessing your data, updating them, requesting their deletion, requesting copies, revoking your consents or objecting to their processing. 

Read in detail about your Privacy Rights.

All such requests will be processed in accordance with the Regulation.

Please be aware that the making of any of the requests set forth herein does not guarantee that we will comply with your request, if there is a reason for us not to do so in accordance with the Regulation.

13. Where to lodge a complaint

13. Where to lodge a complaint

If you believe that the processing of your personal data violates the provisions of the Regulation, you may make a complaint to the Italian Data Protection Authority (www.garanteprivacy.it), or to the Data Protection Authority of the country in which you reside, if applicable, or, finally, of the place where you believe the violation occurred.

14. Revision clause

Geox reserves the right to revise, amend or simply update this Privacy Policy, in whole or in part, at its sole discretion, in any manner and/or at any time. If it does so, it will endeavor to (i) e-mail users registered on the Website to notify them of the change, or (ii) publish on the homepage of the Website a notice of such a change. The revised Privacy Policy will be binding as soon as published and communicated as set forth herein. Please access this section regularly for publication of the most recent and updated Privacy Policy or check your e-mail.

15. Do Not Track

Do Not Track (“DNT”) is a concept promoted by certain regulatory authorities and industry groups for development and implementation of a mechanism that would allow internet users to control the tracking of their online activities across websites. Currently, various browsers (including Edge, Firefox, and Safari) offer a DNT option that allows a user to set a preference in the browser to not have his/her activities on the internet tracked. You can usually access your browser’s DNT option in your browser’s preferences. When a user’s browser is set to DNT, some cookies and other tracking technologies may become inactive, depending on how the website visited responds to DNT browser settings. At this time, our Website is configured to honor DNT signals, but please keep in mind that this technology is evolving, and there may be times when the signal is not properly recognized.

The Site uses cookies and other tracking tools to (i) enable the proper functioning of the Site and the provision of related services; (ii) perform aggregate statistical analysis to understand and improve the user’s browsing experience (e.g., count the number of visitors to the Site, understand how popular a product or service is; etc.); (iii) analyze the preferences and navigation of users who visit the Site to send advertisements in line with their expressed preferences and personalize content.

-

The following information refers to both the use of “cookies” and other tracking tools that may be used (except where indicated otherwise). For convenience, we will use the term “cookies” to refer to all different tracking technologies, except where expressly stated otherwise.

Information about who we are, how we process personal data, how you can contact us, and what your privacy rights are can be found in the Privacy Policy of the Site.

Pursuant to Article 13 of EU Regulation 2016/679, General Data Protection Regulation (the “Regulation”) and Directive 58/2002 as subsequently amended and supplemented, Geox S.p.A., as the Data Controller (“Geox” or the “Company”), provides the following information.

1. What is a cookie

1. What is a cookie

Cookies are text files that are sent by a web server (i.e., the computer in which the website visited is “hosted”) to the user’s browser (Microsoft Edge, Mozilla Firefox, Google Chrome, Opera, Safari, etc.) and are stored on the fixed or mobile device used for browsing. The cookie allows the Site to identify the user’s device, through the information stored in it, whenever the user reconnects to the Site through that device. 

Through the use of cookies (or other tracking tools), it is possible for us to make it easier for you to navigate within the Site, as well as to analyze your preferences and tastes by verifying your browsing (profiling activities), and consequently to offer promotions of products and services that are more consistent with your interests and expectations (e.g., by having advertisements displayed in line with your interests).

Cookies can either be “session” cookies (when they are only stored for as long as the website browsing session lasts and are deleted when the browser is closed), or “permanent” cookies (when they are stored for a longer period of time, until they expire or are deleted by the user). Further, cookies or other tracking tools may be either “first-party” tools (when they are created and used only by the owner of the website that issued them and are not transferred to third parties) or “third-party” tools (when they are issued and managed by persons other than Geox).

An example of other tracking tools are “tracking pixels,” small snippets of code embedded in the website that, once downloaded to the user’s browser, allow the social media provider (e.g., Facebook, Instagram, tiktok) to monitor the user’s session, collecting data for user analysis and profiling purposes.

Cookies and tracking tools do not collect directly identifying information about you.

2. What types of cookies (or tracking tools) does the Site use

Cookies and technical or necessary tools

These are the cookies used in order to ensure the navigation and thus the telematic transmission of data on the network or that are strictly necessary for the provision of services provided by the Site.

These cookies can be either first-party or third-party cookies and do not require the acquisition of prior and express consent from the user as they are strictly necessary to provide the service requested by the user of the Site. 


Statistical cookies 

Analytical cookies, including third-party cookies, allow us to understand how users use the site. No information directly traceable to your identity and personal information is collected with these cookies. The information collected is normally processed in aggregate and anonymous form through the use of partial IP obfuscation mechanisms; these cookies, in the presence of other security and minimization measures for processing, are equated with technical cookies and do not require the acquisition of prior user consent.

If, for example, such obfuscation mechanisms are not present instead, the use of these cookies will require the user’s express and informed consent. 


Personalization cookies

So-called personalization cookies permit the recording of user preferences while using the Site (e.g., the language chosen and the country of interest) or facilitate the user’s navigation within the Site (e.g., by remembering the data provided by the user when filling in forms on the Site (so called user input cookies), recognizing the user after he/she has logged in to the Site (so-called authentication cookies); these are tools that are not strictly necessary for browsing the Site and if retained even after the browser is closed require the acquisition of prior and express consent from the user. Such cookies can be either first-party or third-party. 


Profiling (or marketing) cookies

These are the cookies aimed at creating profiles related to the user, for example, in order to send advertising messages consistent with the user’s preferences (e.g., thanks to the use of these cookies, the user will be able to view advertising content of the products for which he/she has expressed an interest on other sites as well). They can be either first- or third-party; session or permanent.

Other tracking tools (e.g., Facebook’s pixels) also work in similar ways (e.g., allowing the user to display advertisements on the social network, or to remember that the user has visited the Site).

The use of these cookies and tools requires the express and informed consent of the user. Consent will only be required when you first access the Site: thereafter, through the use of a technical cookie, we will store your consent to allow you to access the Site pages directly when you return. It is understood that your consent may be revoked at any time in the manner specified in Section 3 of the Cookie Policy.

No other profiling tools are used in the absence of user consent (e.g., spyware).


Third-party cookies

The Site uses both so-called “first-party” cookies and tracking tools, i.e., issued by Geox and the Site, and so-called “third-party” cookies and tracking tools (e.g., Google Analytics; Social Network cookies; etc.), i.e., tools that are issued and managed by parties other than Geox.

On the Site you can also find social buttons/widgets (social plug-ins), which are those special “buttons” depicting the icons of social networks such as Facebook, instagram, X, etc. These buttons allow users who are browsing the Site to reach and, and, in some cases, to interact with a “click” directly with social networks. For more information, see Section 8.

3. Your consent

When you access the Site, you will see a “banner” warning about cookies and other tracking tools that may be used.

The banner provides concise information to enable the user to understand what cookies/tools are used and for what purposes; in addition, using the “settings” button the user can also check in detail what types of cookies and tools are used.

The user can then freely choose whether and which cookies and other tracking tools to allow.

We will capture whether user has given or denied consent to allow direct access to the pages of the Site without having to display the “banner” again, except in particular cases (e.g., if user deletes cookies, if it is necessary to update users about the cookies used, etc.).

  • Consent can be revoked at any time simply by (i) selecting the “Cookie Management” link at the bottom of each page of the Site (the command allows you to redisplay the banner with the possibility of updating your consent), or (ii) accessing this Cookie Policy found in the privacy section of the Site and accessible by selecting the “Privacy” link at the bottom of each page of the Site (information regarding consent given/denied with the possibility of modifying the choices made is available in section 8).

Your consent applies to the following websites: www.geox.com

4. Disabling/deleting cookies via web browser

You can in any case disable/enable or delete cookies at any time by use of your web browser settings. In particular, if you do not wish to receive cookies, you can set your browser to alert you to the presence of a cookie so that you can decide whether or not to accept it; you can also automatically reject all cookies by activating the appropriate option in your browser. You can also delete specific cookies that have already been stored within your browser, or block specific websites from storing cookies on your computer, or block third-party cookies.

Each browser (Firefox, Chrome, Edge, Safari, Opera, etc.) has its own cookie management methodology: in the settings or preferences panel it is possible to change/manage the parameters related to cookies and/or proceed to their deletion.

To do so, it is necessary to consult the information in the browser’s User’s Guide ( Help Page) or click on the following links:

You can also manage your cookie preferences at http://www.youronlinechoices.com 

5. Who will have access to your data

5. Who will have access to your data

The data collected through cookies and other tracking tools will not be disclosed to the public and will be processed by specifically authorized persons within Geox (specifically the CRM, e-commerce, Marketing, Information Technology function).

In order to manage the Site and, if you provide your consent, to review your preferences and browsing, and to enable you to view content and promotional ads that may be of interest to you, the data will be processed by (i) companies in charge of managing the Site and (ii) IT service providers. These individuals will act as Data Processors designated by Geox.


5.1 Social networks

Data related to navigation within the Site may in some cases be transmitted to social networks (such as Facebook, instagram, tiktok, etc. -- see the table below for the list of social networks that interface with the Site). In general, the interaction between a site and the social network is used, for example, to:

(i) allow you to login using the social network (e.g., when you choose to login to your private area of the Site using Facebook, there is an exchange of data between the social network and the Site to allow user recognition and authentication);

(ii) allow sharing of content on social (e.g., if you use the sharing feature -- so-called social plug-ins -- you will be able to post, and thus share, within your social profile content of interest);

(iii) have promotional and advertising content displayed when visiting social networks (e.g., the social network may display advertisements related to the Geox brand and products that were viewed within the Site). This can occur mainly in two ways:

    a. a.     data relating to the user’s navigation within the Site and collected by means of cookies or other tracking tools will be shared with the social network which, by identifying the user, will display advertising content to the user, then providing Geox with statistics on the advertising campaigns carried out;

    b. a.     if the user has provided his or her e-mail address, the data can be exchanged (in encrypted and protected mode) with the social network which, by identifying the user by e-mail, will display advertising content to him or her, then providing Geox with statistics on the advertising campaigns carried out. 

For such processing, social networks will process the data -- as joint controllers (Art. 26 GDPR) or of autonomous data controllers -- to the extent necessary to enable, for example, Geox-related news/advertising to be displayed. 

 

The following is some information regarding the processing carried out social network data within the Site:

 

  • Meta (e.g. facebook, instagram)

The joint data controller is Meta Platforms Ireland Ltd. 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

A joint controllership agreement (Art. 26 of the Regulation) governs the processing of personal data carried out by means of the tracking tools provided by Meta and present on the Site: the agreement defines the respective responsibilities regarding compliance with the obligations under the Regulation in relation to joint processing. A copy of the agreement is available at the following link: https://it-it.facebook.com/legal/controller_addendum (by selecting your language at the bottom of the page).

Meta, on the other hand, is the autonomous owner of the user data processing carried out subsequently. As the controller, Meta is responsible for providing the data subjects with information about the processing carried out or allow them to exercise their privacy rights (Art. 15 - 20 of the Regulation).

The Site uses cookies and Meta tracking tools (e.g., pixels) to (i) have users display personalized promotional and advertising content, (ii) provide statistical reports on advertising campaigns and users’ browsing of the Site, and (iii) improve the publication of content on the Site.

For these purposes, data related to your browsing within the Site and collected through cookies or other tracking tools are shared with Meta.

Details on how Meta processes data, the relevant legal basis for processing, and how you can exercise your privacy rights recognized by the Regulation against Meta are available at https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0.

Facebook’s Data Protection Officer (the Data Protection Officer) can be contacted at: https://www.facebook.com/help/contact/540977946302970

 

  • Pinterest

The data controller is Pinterest Europe Limited, located at 2nd Floor, Palmerston House, Fenian Street, Dublin 2, Ireland.

The Site uses cookies and tracking tools from Pinterest (e.g., pixels) to (i) have users display personalized promotional and advertising content, (ii) provide statistical reports on advertising campaigns and users’ browsing of the Site, and (iii) improve the publication of content on the Site.

For these purposes, data related to your browsing within the Site and collected through cookies or other tracking tools are shared with Pinterest.

Details of the data privacy agreement with Pinterest can be viewed at Exhibit B at the following link: Pinterest Business

More information about the processing carried out by Pinterest is available at: Privacy Policy | Pinterest Policy (by selecting your language in the-eea

 footer of the page). The Pinterest Data Protection Officer can be contacted at the following link: Contact form of the data protection officer | Pinterest Help (by selecting your language in the footer of the page)


  • TikTok

TikTok Technology Limited (an Irish company) and TikTok Information Technologies UK Limited (a UK company) are the joint data controllers.

The Site uses TikTok tracking tools (e.g., pixels) to (i) display customized promotional and advertising content to users, (ii) provide statistical reports on advertising campaigns and users’ browsing of the Site, (iii) improve the publication of content on the Site.

For these purposes, data relating to the user’s navigation within the Site and collected through tracking tools are shared with TikTok.

More information on the processing carried out by TikTok is available at: Data Protection Policy | TikTok

The TikTok Data Protection Officer can be contacted at the following link: Contact the Data Protection Officer (tiktok.com)


For more information on the processing carried out by social networks, please also check the privacy policy provided by the social network (also, by using the “Cookie Management” link found on all screens of the Site, you can view the list of cookies/tracking tools used on the Site and the relevant links to their respective policies).

6. What are your rights

6. What are your rights

Writing to privacy@geox.com, you may at any time exercise your rights under Articles 15 to 22 of the Regulation, including accessing your data, updating it, requesting its deletion, requesting copies, revoking your consents or objecting to its processing. 

Read in detail about your privacy rights.

 

7. Transfer of your data outside the European Union

7. Transfer of your data outside the European Union

Data collected through the Site are generally not transferred abroad, as processing is done through providers using servers located in the European Union (or European Economic Area).

In contrast, data collected using cookies and other tracking tools -- particularly from Social Networks -- may be transferred outside the European Union (e.g., data collected through Facebook’s tracking tools are subject to transfer). The applicable privacy legislation provides that specific consent to the transfer is not required when the transfer is made to a country that provides an adequate level of protection (Article 45 of the Regulation) or on the basis of the adoption of appropriate safeguards (Articles 46 and 47 of the Regulation), and in particular on the basis of the adoption of binding rules for groups of companies or the adoption of contractual clauses approved by the European Commission: the transfer of data collected through cookies/tracking tools is governed by these contractual clauses (e.g., https://www.facebook.com/help/566994660333381?ref=dp).

By simple request to privacy@geox.com you will be able to receive more information about the transfer of data and the guarantees provided for their protection as well as the means of obtaining such data or the place where they have been made available.

8. Details of cookies and tracking tools used by the Site

In order to enable you to make a free and informed choice, we provide the following indication regarding (i) the provider and identifier of cookies/tracking tools (ii) their characteristics and purposes, and (iii) their duration/expiration. The same detailed information is available at the “Cookie Management” link found on all screens of the Site that allows you to view the list of cookies/tracking tools used on the Site

Cookie Statement last updated 05/03/21 by Cookiebot:

For further information on the processing of your data through the Website, please visit the Privacy section.

We provide you with information to understand how we process your data, so that you can manage your profile and your membership with Benefeet. If you wish, you can give your consent to receive communications about our initiatives and offers, allowing us to improve by analyzing your interests. Your data will not be shared with third parties, other than our affiliates and service providers. We remind you that you can exercise your privacy rights at any time on our website, or by contacting our customer service.

Who is the Data Controller

Who is the Data Controller

Geox S.p.A. (“Geox”), with registered office in Biadene di Montebelluna (TV), Italy, Via Feltrina Centro no. 16, privacy@geox.com, is the Data Controller (meaning the business, that alone or jointly with others, determines the purposes and means of the processing of your personal data).

How to contact us and the Data Protection Officer

How to contact us and the Data Protection Officer

If you have any questions, need information or wish to exercise your rights, you can contact us by sending an e-mail to privacy@geox.com or by writing to: Geox S.p.A., Customer Service, Via Feltrina Centro no. 16, 31044, Biadene di Montebelluna (TV), Italy.

The Data Protection Officer can be contacted by e-mail at dpo@geox.com.

Why we process your data

Why we process your data

We will process your personal data to manage your participation in the Benefeet loyalty program, create your personal account and allow you access our services. If you give us your consent, we may also process your personal data to send you commercial communications or analyze your preferences and interests and improve our offerings.
Below you can find a detailed explanation of the purposes for which we collect and use your personal data, and the legal basis for processing it:

 

Purpose Legal basis
Joining the Benefeet loyalty program, which operates on the www.geox.com website: this allows you to access benefits (e.g., accumulate the purchases made, use accrued vouchers,), promotions, competitions, and dedicated initiatives under the terms of the Benefeet rules available at www.geox.com. Execution of the contractual relationship
To Activate your personal Geox account and allow you to access the services offered by Geox, to update your data and any consents you may have given, to verify your purchases made on the Geox website and your Benefeet achievements. Execution of the contractual relationship    
Access to services (e.g., dedicated after-sales service request product availability, managing your wish list; etc.). Execution of the contractual relationship.
Sending service communications related to purchases made and the Benefeet program (e.g., reminders on the value of purchases made and vouchers accrued, receipt of award codes, communications on the expiry dates of the spending period and use of vouchers, on the birthday discount, on dedicated benefits, etc.) and communications aiming at verifying the degree of satisfaction on the purchases made. Execution of the contractual relationship    
Updating (by means of newsletters, e-mail, telephone contact, instant messages, push notifications, paper mail, messages or communications of initiatives on social networks, etc.) you about our products, services (e.g., purchasing methods, home delivery, etc.) or initiatives (e.g., competitions), and sending advertising and promotional material, including personalised material, and participation in market research - by means of e-mail or telephone contact. Your consent is optional.
Analysis of your data, your interests and your purchasing preferences in order to improve our commercial offerings and browsing of the www.geox.com website. Your consent is required, but optional. 
Claiming a right (including in court) and/or preventing and detecting any fraud or other unlawful conduct. Geox’s legitimate interest in complying with the rules of the Benefeet program and preventing fraud or unlawful conduct
Processing of data for statistical purposes in aggregated and anonymous form. The legitimate interest of Geox in analyzing the business activities carried out.

 

The required data and consents

The required data and consents

The “compulsory” data marked with (*) are necessary for you to join Benefeet and guarantee you access to promotions and services reserved for members. Your data can always be updated at any time.

Your consents are all “optional” and will always be freely revocable.

If you choose not to give your consent, you can still join Benefeet, but we won’t be able to keep you updated on our products, services, or initiatives, send you advertising/promotional material, analyze your interests and preferences, send you personalized communications, or contact you for market research purposes. You can always revoke your consents at any time by writing to privacy@geox.com or simply by accessing your personal Geox account. If you no longer wish to receive commercial communications via email, you can also use the ‘unsubscribe’ option available in every email.

Please note that if you wish to register your purchases and have access to the benefits of the program you will need to log in to your Geox account. However, you can still complete your purchases as a “guest,” but we will not be able to record and process your spending on your Benefeet profile. You can update your personal details at any time by accessing your personal account or by writing to privacy@geox.com. Please note that for security reasons, your date of birth can only be changed by writing to privacy@geox.com; your e-mail address cannot be changed, and a new registration must be created if your e-mail changes (for further information, please contact privacy@geox.com).

How we process your data

How we process your data

Geox will process your data according to the Regulation UE 2016/679 general data protection regulation (GDPR).

We will process your data using computer systems to allow you to access the benefits reserved to members and provided for by the Benefeet Terms and Conditions published at geox.com.

With your consent we can also analyze your purchases and enable you to receive personalized commercial communications.

In particular, by creating your Benefeet profile we process your data, granting you discounts/prizes, associating your spending volumes - the amount of your purchases (excluding taxes or shipping costs) - to spending levels provided in the program rules; you will access the benefits reserved for members (e.g.: receiving the birthday discount, access to special benefits limited to the Benefeet subscribers, etc.) and update your data and consent simply accessing to your profile.

As a Benefeet customer, you may also be encouraged to express your degree of satisfaction on the purchases just made: you will receive from us an email or a message on our website inviting you to take part in our surveys, thereby allowing us to improve our products and services.

If you give us your consent, we may analyze your data in order to try to understand your tastes and preferences (e.g., by analyzing which products you have bought or put in your shopping cart or wish list; when you shop; which products interest you; etc.), so that we can improve and send you interesting offers, including personalized offers (e.g., if you have bought women’s footwear in the past, we may send you our new Women’s Catalogue, or promotions on women’s products or matching products; etc.). Please note that data relating to your browsing on the www.geox.com website may be processed only if you provide your consent to the use of cookies and tracking tools when accessing the website (please read our Cookie Policy available at geox.com).

Our analysis activities shall not be carried out in an exclusively automated manner, but shall always involve the intervention and evaluation of our personnel in charge.

If you use your “back in stock” service, we can update you by email on the availability of products requested by you.

Geox may carry out specific, non-continuous checks to verify compliance with the Benefeet rules, the correct use of the reserved advantages and the services used, and to protect itself against fraudulent conduct, in compliance with the applicable legislation and the corporate procedures and regulations in force.

How long we keep your data

How long we keep your data

We adopt stringent rules in an attempt to ensure not only the preservation of your data, but also their deletion. The data related to your registration are retained for 5 years from your last purchase, access to your profile, or from your registration.

Data concerning the details of your purchases are generally kept for 36 months.

In particular, your personal and membership data for the Benefeet profile are kept during the entire duration of your registration. If you do not purchase or use your Geox account for more than 5 years, all your data and your registration shall be erased.

Unless otherwise required by law, your purchase details shall be stored for 36 months from when they were registered for the purpose of analyzing your preferences or sending you advertising material and commercial communications (only if you give us your specific consent). If you withdraw your consent, your data shall only be processed for the purposes provided for by law (e.g., accounting and tax).

Who will have access to your data

Who will have access to your data

Your personal data shall not be disclosed to the public or transferred to third parties, except our service providers and affiliates. In order to manage your Benefeet subscription and allow us to process your data for the purposes for which you have given us your consent, your data shall be processed by persons specifically authorised by Geox (in particular, the CRM, e-commerce, Information Technology, and shop departments), as well as by our suppliers, in their capacity as Data Processors, by

(i)         companies in charge of processing the value of purchases made and discount vouchers (e.g., as provided for in the Benefeet rules);

(ii)       companies analyzing your purchases;

(iii)     companies in charge of providing customer support (both in relation to after-sales services and the management of “privacy requests”);

(iv)      companies in charge of processing, managing and sending newsletters and advertising and promotional material;

(v)        companies that organize and manage market research and surveys;

(vi)      companies in charge of managing our website and computer archives;

(vii)    suppliers of IT services;

(viii)  (if any) third party companies that manage franchised “Geox” shops. A full list can be obtained from privacy@geox.com.

 Furthermore, if you give us your consent for marketing purposes, your e-mail address (or your mobile phone number) may be temporarily disclosed - in encrypted form - to social networks (e.g., Facebook, Instagram) which will process your data - in their capacity as joint data controllers - to the extent necessary for you to see news or advertising relating to Geox on the social network. Further information on the use of social networks and the exchange of data with Geox is available in the Cookie Policy on the geox.com website.

Transfer of your data outside the European Union

Transfer of your data outside the European Union

For all the above purposes, your personal data will be transferred to Geox and reside on servers located within the European Union.

Only in some cases your data may be transferred, in part and for a limited period of time outside the European Union, in particular:

(i)       If you take part in our surveys to verify the degree of satisfaction on your purchases, your data (only name and contacts) may be transferred to countries that are not members of the EU but have been considered adequate by the European Commission (e.g., the UK, Canada, Argentina, Israel, etc.) or to other third countries (e.g., the United States of America) based on agreements or the adoption of contractual clauses approved by the European Commission. In any case, the data will be transferred for a limited period of time and subsequently erased;

(ii)     If you have given your consent to our marketing activities, your data (email or mobile number) may be temporarily communicated – in an encrypted form – to social networks (e.g., Facebook. Instagram) to display news or advertisements related to Geox. In these instances, the data can be transferred to countries outside the European Union (e.g., the United States) based on agreements or the adoption of contractual clauses approved by the European Commission.

You may write to us at privacy@geox.com for more information.

Your rights

Your rights

By writing to privacy@geox.com, you may at any time exercise your privacy rights under applicable laws, including accessing your personal data, updating them, requesting their erasure, requesting a copy of them, revoking your consent or opposing to the processing of them, if you have such rights under applicable laws.

Please read your privacy rights in detail, available also at geox.com.

Who you can contact to submit a complaint

Who you can contact to submit a complaint

If you believe that the processing of your personal data is in violation of the provisions of the Regulation, you may always make a complaint with the Italian Data Protection Authority (www.garanteprivacy.it), or, if different, with the Data Protection Authority of your country.

If you have made purchases, or simply want to give us your opinion about our products, services or about our site, we will process your data mainly in an anonymous and aggregate form; it is only if you are a registered user that your data may be stored. 

Please note that you can exercise your privacy rights and contact our customer service at any time.

-

The filling in of the questionnaire under the “Feedback” section does not imply the collection of any personal details. Your data will be collected only if you provide it voluntarily during the survey. If you decide to provide your data, it will be processed and stored pursuant to this Privacy Disclosure, which we invite you to read.

Moreover, we inform you that, if you are registered with the Single Digital Profile (available in some countries) or with a Geox account, the answers you provide by filling in the questionnaire will be associated with your profile and processed on the basis of the consents you gave upon registration and pursuant to the Single Digital Profile disclosure 

Who is the Data Controller

Who is the Data Controller

Geox S.p.A. (“Geox”), with registered office in Biadene di Montebelluna (TV), Italy, Via Feltrina Centro n. privacy@geox.com, is the company that processes your personal data as the Data Controller. 

How to contact us and the Data Protection Officer

How to contact us and the Data Protection Officer

If you have any questions, need information or wish to exercise your rights, you can contact us by sending an email to privacy@geox.com or by writing to: Geox S.p.A., Customer Service, Via Feltrina Centro n. 16, 31044, Biadene di Montebelluna (TV), Italy.

You can contact the Data Protection Officer at dpo@geox.com.

Why we process your data

Why we process your data

The data you provide to us voluntarily through the questionnaire in the “Feedback” section will enable us to improve the services and products offered to our clientele.

The data will be processed on the basis of the agreement stipulated with you (if you have purchased our products or used our services) or our legitimate interest in improving our services and products.

The requested data

The requested data

There is no obligation to provide personal details when filling in the questionnaire, and the answers to our satisfaction survey are optional.

How we process your data

How we process your data

Your personal details will be processed mainly using electronic equipment to improve our products and services.

The data will be processed in accordance with the applicable regulations and, nonetheless, in a way that guarantees its security and confidentiality and prevents its unauthorised use or disclosure, alteration or destruction.

If you are registered with the Single Digital Profile (available in some countries) or with a Geox account, your data will be processed pursuant to the privacy disclosure supplied to you upon registration and in conformity to the consents you gave (e.g., if you have provided your consent for your preferences and interests to be analyzed when you signed up for the Single Digital Profile/Geox account, the answers you provided to our survey may be stored). For further information on the Single Digital Profile or on My Geox, please read the relevant disclosure. For more information about registering a Geox account, read the disclosure.

How long we keep your data

How long we keep your data

Your data will be processed for the time necessary to understand the degree of satisfaction of our customers and will subsequently be stored so that we can improve our services (approximately 90 days, unless you are a registered user); your data will then be erased or stored in anonymous or aggregate form. You can request further information by writing to privacy@geox.com.

Who will have access to your data

Who will have access to your data

Your data will not be shared or sold to third parties, and may come to be known by the Geox staff authorised to process it and, in their role of data processors, by i) the company entrusted with managing our “customer service”; (ii) our providers of services used to manage the website; (iii) companies that organise and manage market surveys. The names of the data processors can be requested by writing to privacy@geox.com.

Transferral of your data to countries outside the European Union

Transferral of your data to countries outside the European Union

Your personal details (if provided) may be transferred to countries outside of the European Union but subject to adequacy decisions approved by the European Commission (e.g. United Kingdom, Canada, Argentina, Israel, etc.) or to third countries (e.g. United States) on the basis of agreements or the adoption of contractual clauses approved by the European Commission. You can receive further information by writing to privacy@geox.com.

What are your rights

What are your rights

By writing to privacy@geox.com, you can exercise your rights under Articles 15 to 22 of the Regulation at any time, including accessing your data, updating it, requesting that it be deleted, requesting a copy, revoking your consents or objecting to its processing.

To read about your privacy rights in detail, please see.

Who you can contact to submit a claim

Who you can contact to submit a claim

Should you feel that the data processing concerning you breaches the provisions of the Regulation, you can submit a claim to the Italian Data Protection Authority (www.garanteprivacy.it) or, if different, to the data protection authority of the country where you live or work or where you believe the breach occurred.

The privacy legislation recognizes, to all those who are interested in the processing of their personal data, the possibility of exercising specific rights against the data controller. 

Below you can find a summary listing of what rights you can exercise and guidance on how to exercise them. If you have any concerns or questions, please contact us at privacy@geox.com.

-

-

Articles 15 to 22 of EU Regulation 2016/679 (General Data Protection Regulation) grant the data subject the following rights: 

Right of access: a data subject may request what data concerning him or her is being processed, the purposes of the processing, the categories of data processed, the recipients to whom the personal data has been or will be communicated, whether the data has been transferred outside the European Union, the period of data retention, the existence of automated decision making (including profiling), and the origin of the data if it is not collected from the data subject himself or herself (Art. 15 of the Regulation). 

Right to rectification: the data subject may request the correction or updating of inaccurate data or, taking into account the purpose of the processing, the integration of incomplete personal data (Art. 16 of the Regulation). 

Right to erasure (right to be forgotten): (where applicable) a data subject has the right to obtain the erasure of personal data concerning him or her, such as when the personal data is no longer necessary for the purpose for which it was collected. However, it will not be possible to request the deletion of data if they are necessary to fulfill a legal obligation (e.g., bookkeeping, security, etc.) or for the establishment, exercise or defense of a right in court (Art. 17 of the Regulation). 

Right to limitation: a data subject may request that data processing be limited, for example when the accuracy of personal data is disputed, for the period necessary to verify the accuracy of such data (Article 18 of the Regulation). 

Right to notification: the data subject has the right to be informed of any rectification or erasure or restriction of processing carried out in relation to personal data concerning him or her, and of the recipients to whom they have been communicated (Article 19 of the Regulation). 

Right to portability: (where applicable) the data subject has the right to receive data concerning him or her in a structured, commonly used, machine-readable format (e.g., in .excel, .csv format). However, this right is limited to data processed by automated means and on the basis of a contract with, or consent of, the data subject. If technically feasible, it will be possible to request the transmission of data directly to another data controller (Art. 20 of the Regulation). 

-

-

Right to object: (where applicable) the data subject has the right to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her carried out, for example, in pursuit of a legitimate interest of the data controller or a third party (including profiling). The data subject can also always object to the processing of data carried out for direct marketing purposes, including profiling related to such direct marketing (Article 21 of the Regulation). 

Right not to be subjected to automated decisions, including profiling: (where applicable) the data subject has the right not to be subjected to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or significantly affects him or her, except where the automated decision is necessary (i) for the conclusion or performance of a contract between the data subject and a data controller, (ii) is required by law, subject to measures and safeguards, (iii) is based on the data subject’s explicit consent (Article 22 of the Regulation). 

The full text of the Regulation is available here

How to exercise your rights:

How to exercise your rights:

E-mail: privacy@geox.com 

Sito web www.geox.com:  

  • you can use the Customer Service contact form accessible from the footer of the site; 
  • if you have subscribed to Geox’s Unique Digital Profile or registered a Geox account, by accessing your profile you can change your consents and object to the processing of your data.  

Unsubscribe: by using the “unsubscribe” link in all of our emails, you can always opt out of having your information processed for marketing purposes and receiving promotional emails. For further inquiries you can write to us at privacy@geox.com 

Telephone: 00800 43694369 

Mail: Geox S.p.A., Customer Service, Via Feltrina Centro no. 16, 31044, Biadene di Montebelluna (TV), Italy. 

How to contact our Data Protection Officer:

How to contact our Data Protection Officer:

The Data Protection Officer (Data Protection Officer) of Geox S.p.A. can be contacted at dpo@geox.com.

With whom can you lodge a complaint

With whom can you lodge a complaint

As a reminder, if you believe that the processing of your personal data is in violation of the provisions of the Regulation, you may always lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it), or, if different, with the Data Protection Authority of the country in which you reside or work or of the place where you believe the violation occurred (a list of Authorities can be found here: https://edpb.europa.eu/about-edpb/about-edpb/members_en).