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PERSONAL DATA PROCESSING POLICY

Brooks Brothers Europe S.r.l. (“BBE”) is aware of the importance of protecting the personal data of its customers (“Data Subjects”) and informs that the personal data collected through the forms of the “Contact Us” page of the web site events.brooksbrothers.it (“Site”) will be processed in compliance with the applicable law.

Therefore, pursuant to Regulation (EU) no. 2016/679, Art. 13, (“Regulation”) BBE provides the following information on the methods of management and processing the personal data of its customers who visit the Site.

1. Types of data collected

Data provided deliberately by Data Subjects

Upon filing the form on the “Contact Us” section of the Site, BBE will collect the following data deliberately provided by the Data Subjects (“Data”): (i) personal details; (ii) contact details; (iii) data concerning the request of contact.

Data subject are requested not to insert or indicate through the “Contact US” form any (i) data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; (ii) genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation; (iii) data relating to criminal convictions and offences . If provided, such Data will be immediately deleted.

2. Purpose and legal basis of the processing

BBE will process the Data collected in the “Contact Us” section of the Site for the following purpose:

  1. Fulfil the requests made by the Data Subjects. Legal basis of the processing is art. 6 par. 1, lett. b) of the Regulation, as it is necessary for the performance of a service of which the customer is a part of;
  2. Discharge obligations resulting from the law in accounting and tax matters. Legal basis of the processing is art. 6 par. 1, lett. c) of the Regulation, as it is necessary to fulfil a legal obligation to which the data controller is subject;
  3. to assert or defend a right in court. Legal basis of the processing is art. 9 par. 2 lett. f) of Regulation, as it is necessary to ascertain, exercise or defend a right in court;

3. Data retention period

The data collected through the “Contact Us” form of the Site for the purposes referred to in point 2.a will be retained exclusively to fulfil Data Subjects’ requests and then immediately removed. The data collected for the purposes referred to in point 2.b and 2.c will be retained to comply with legal obligation (such as the ones set by fiscal, accounting, and administrative regulations) and document the activities performed. In such cases, the Data will be deleted in the terms provided for by the aforementioned regulations.

4. Modalities for data processing

The Data will be stored and processed with electronic tools and will be saved both electronically and on paper, organized in a database, and on any other type of appropriate support.

Specific security measures are followed to prevent data loss, illicit or incorrect use and unauthorized access.

The processing of Data carried out by BBE does not involve automated decision-making processes.

5. Provision of Data

The provision of Data is necessary to allow BBE to fulfil Data Subjects requests and therefore mandatory for the purposes referred to in points 2.a, 2.b and 2.c of this policy: failure to communicate data, for these purposes, will make it impossible to fulfil the requests

6. Entities to whom personal data may be disclosed

The Data will not be disseminated and may be communicated to: (i) subjects who are entitled and have the interest to access to the Data; (ii) Data Controller’s internal staff; (iii) companies, associations or professional offices that, appointed as Data Processors (“Processors”), provide services and activities on behalf of the Data Controller for the fulfilment of legal obligations as well as for every organizational and administrative need necessary to provide the services requested.

The names of the Processors are listed in an updated list available at BBE premises (to be requested at the addresses indicated in points 9).

7. Transfer of data abroad or to international organizations

BBE does not transfer the Data collected through the “Contact Us” section in countries located outside the European Union or to international organizations.

8. Rights of Data Subjects

The Data Subjects have the right to exercise at any time the rights provided for by the Regulation, such as:

– to obtain information on: (i) Data source; (ii) purposes and methods of processing; (iii) logic applied; (iv) identifying details of BBE and of Processors;

– to obtain: (i) access, updating, correction or integration of data; (ii) deletion, transformation into anonymous form or blocking of Data processed in violation of the law; (iii) the limitation of data processing; (iv) copy of the Data in standard format;

– to object, in whole or in part:

(a) for legitimate reasons, the processing of the Data, even if pertinent to the purposes of the collection;

(b) to the processing of the Data necessary (i) for the performance of a task carried out in the public interest or in the exercise of official authority vested in BBE or (ii) for the purposes of the legitimate interests pursued by the controller or by a third party, included profiling;

(c) to the processing of the Data for the purposes of sending advertising or direct sales material or for carrying out market research or commercial communication;

– to revoke the consent to processing, when this is based on the hypothesis provided for by art. 6, par. 1 (a) (when “the data subject has given consent to the processing of their personal data for one or more specific purposes“), or by art. 9, par. 2 (a) (when “the data subject has explicitly consented to the processing of such personal data for one or more specific purposes”) of the Regulation, at any time without prejudice to the lawfulness of the treatment based on the consent given prior to the revocation. In particular, in order to no longer receive e-mails or promotional mail, the Data Subjects can at any time request a free cancellation from the service by sending a message to the addresses indicated in points 9 and 10 of this statement.

If Data Subjects consider that the processing of the Data is in violation of the law, they have right to lodge a complaint with a supervisory authority, particularly in the Member State in which they usually reside or work or where the alleged violation has occurred. The Supervisory Authority can be reached at the addresses on its own website

9. Data controller – Contact details

The Data Controller is Brooks Brothers Europe S.r.l., Via Forcella Vincenzo 3, 20144 – Milan (MI), Italy, in the person of the legal representative pro tempore. The Company may also be contacted at the e-mail address europe.info@eu.brooksbrothers.com.

To exercise the rights listed above, the Data Subject may make a request using the e-mail account europe.info@eu.brooksbrothers.com or by contacting the Data Protection Officer at the addresses indicated below.

The Company retains the right to update this privacy policy.

10. Data protection Officer

BBE has appointed a Data Protection Officer (“DPO”), who can be contacted by Data Subjects on all matters relating to the processing of their personal data and the exercise of their rights. +The DPO is reachable at the following addresses: dpo@eu.brooksbrothers.com; Via Forcella Vincenzo 3, 20144 – Milano (MI), Italy