GIORDANO PRIVACY NOTICE

1- Introduction

Giordano International Limited (“Giordano”, “we” or “us”) takes the protection of your personal data seriously. This Privacy Notice sets out information about Giordano’s privacy practices and your rights.
We may amend this Privacy Notice at any time and for any reason. The updated version will be available by following the “Privacy Notice” link on our website homepage. You should check the Privacy Notice regularly for changes.

2- Data protection laws

Giordano is based in Hong Kong and is subject to the Personal Data (Privacy) Ordinance (“PDPO”). Giordano processes all personal data in accordance with the PDPO (See our Privacy Policy at our official website).
In addition, when:

then Giordano is also subject to the General Data Protection Regulation 2016/679 (“GDPR”). Therefore, if you are located in the EU, Giordano will also process your personal data in accordance with the GDPR and you may have additional rights under the GDPR.
In this Privacy Notice, the terms personal data, controller, processor, data subject, consent, recipient, third party, processing and profiling have the meanings given to them in the GDPR.

3- Controller contact details

The controller for the processing of personal data under this Privacy Notice is:

Giordano International Limited
5th Floor, Tin On Industrial Building
777-779 Cheung Sha Wan Road
Kowloon
Hong Kong


The controller’s representative in the EU for the purposes of the GDPR is:

Kennedys
31 Rue de Lisbonne
75008 Paris
France
Phone: +33 1 84 79 37 80

4- Data Protection Officer contact details

If you have any questions about this Privacy Notice or about our personal data processing practices, or if you wish to exercise any of your rights as a data subject, you may contact Giordano’s Data Protection Officer at dataprotection@giordano.com or as follows:


Mark Loynd
Executive Director, Group Counsel & Group Human Resources Director
Giordano International Limited
5th Floor, Tin On Industrial Building
777-779 Cheung Sha Wan Road
Kowloon
Hong Kong
Fax: +852 2370 8864
Email: dataprotection@giordano.com

5- Supervisory authority contact details

If you have a complaint about our personal data processing practices, you should first contact Giordano’s Data Protection Officer. If you are not satisfied with our response, you have the right to lodge your complaint with a data protection authority.If you are outside the EU, you can lodge your complaint with your local data protection authority or the Hong Kong Privacy Commissioner for Personal Data:


Privacy Commissioner for Personal Data
Room 1303, 13/F, Sunlight Tower
248 Queen's Road East
Wanchai
Hong Kong
Fax: 2877 7026
Email: complaints@pcpd.org.hk  
Website: https://www.pcpd.org.hk/


If you are in the EU, you can lodge your complaint with your country’s supervisory authority. A list of supervisory authorities is available here.

6- Specific situations in which we may process your personal data

Giordano collects and processes personal data in a number of different situations.

6.1- Purchasing products from our physical stores

We process certain personal data about customers who purchase products from our physical stores.

When you purchase a product from our physical stores and pay by credit or debit card, we will collect your card details required through our payment terminal to process your payment.
At the time of your purchase, we may also invite you to join a loyalty scheme. See section 6.4 below for details about loyalty scheme membership. 

We may use your card details to process your payment.

Using your card details to process your payment is necessary for our legitimate interests as a retailer. See section 7 below for more details about Giordano’s legitimate interests.

We may disclose your card details to our bank, your bank and your card association for authorisation. 

If our bank or your bank is located overseas, the credit card authorisation process may involve your card details being transferred overseas. Your card details are kept secure in accordance with the Payment Card Industry Data Security Standard.

We may retain your transaction details for as long as we require them for legal and commercial reasons. Generally, we retain transaction details for a period of seven years after your transaction. Once Giordano has no legal or commercial reasons to retain personal data, it will be securely deleted or destroyed.

6.2- Creating a Giordano Online Store profile

Before you make a purchase from the Giordano Online Store, you will first need to create a profile.  Note that we also have online stores on third-party platforms and that you may need to create a separate profile with those platforms – you should check their privacy policies online for details about how they process your personal data.

To create a profile, you will be required to provide either your email address or mobile phone number. You can optionally add a photo, a nickname and your date of birth (to receive birthday discounts).

We may use the personal data in your profile to provide you with discounts on purchases.
If you consent to receive communications when you register, we may send you promotional offers, information about new products, and invitations to special events by email or SMS.

Using your personal data to provide you with discounts is necessary for our legitimate interests as a retailer. See section 7 below for more details about Giordano’s legitimate interests.
Using your personal data to send you promotional messages is based on your consent. You may withdraw your consent by unsubscribing from promotional emails and/or SMS messages at any time on your profile page.

We may disclose your personal data to third parties who provide administrative, storage, telecommunications, information technology and other services to us in support of our business. However, we will ensure that all such service providers are subject to obligations not to use or disclose that data.

We may transfer your personal data overseas. Giordano’s information systems are hosted on central servers located in Hong Kong, mainland China and Dubai. Any personal data that we store on our systems will be transferred to one of those locations. See section 8 below for information about the safeguards Giordano adopts when transferring personal data overseas.

We may retain your profile details for as long as we require them for legal and commercial reasons. If you unsubscribe from promotional messages, we may retain your email address on a “no marketing” list to ensure we do not inadvertently send you promotional messages in the future.

6.3- Purchasing products from our online stores

We will process certain personal data about customers who purchase products from our online stores.

When you purchase a product from our online stores, we may collect your name, mobile phone number, e-mail address, and (unless you choose to pick up your order from a physical store) delivery address.  Payment is via PayPal – PayPal’s privacy policy is available at https://www.paypal.com . We have no access to any personal data you provide to PayPal. 

We may use your contact details to contact you about your order and your delivery address to deliver your order.

The processing described above is necessary for our legitimate interests as a retailer. See section 7 below for more details about Giordano’s legitimate interests.

We may disclose your delivery details to our delivery provider to arrange delivery. We may disclose your payment details to your card issuer or to a payment processor for verification. 
We may also disclose your personal data to third parties who provide administrative, storage, telecommunications, information technology and other services to us in support of our business. However, we will ensure that all such service providers are subject to obligations not to use or disclose that data.

We may transfer your personal data overseas. Giordano’s information systems are hosted on central servers located in Hong Kong, mainland China and Dubai. Any personal data that we store on our systems will be transferred to one of those locations.
If our bank or your bank is located overseas, the credit card authorisation process may involve your card details being transferred overseas. Your card details are kept secure in accordance with the Payment Card Industry Data Security Standard.
See section 8 below for information about the safeguards Giordano adopts when transferring personal data overseas.

We may retain your order details for as long as we require them for legal and commercial reasons. Once Giordano has no legal or commercial reasons to retain personal data, it will be securely deleted or destroyed.

6.4- Loyalty scheme membership

We will process certain personal data about customers who join one of Giordano’s loyalty schemes (“loyalty schemes”). Loyalty schemes vary by country and/or region and include World Without Strangers, BSX, Giordano Junior and Giordano Ladies Privilege Card.

When you make a purchase over a certain amount from a Giordano retail store, we may invite you to join a loyalty scheme. The information we collect when you join differs depending on the loyalty scheme:

(*required)

We may use your personal data to enrol you in the loyalty scheme, provide you with member discounts and other entitlements, (for World Without Strangers) track your accumulated points, communicate with you about loyalty scheme member discounts and other entitlements and notify you of any changes to the loyalty scheme rules.

By joining the loyalty scheme, you consent to us processing your personal data for the above purposes. You can withdraw your consent at any time by contacting us at wws@giordanogroup.com, but you will then cease to be a member of the loyalty scheme and forfeit any accrued points or privileges.

We may disclose your personal data to third parties who provide administrative, storage, telecommunications, information technology and other services to us in support of our business. However, we will ensure that all such service providers are subject to obligations not to use or disclose that data.

We may transfer your personal data overseas. Giordano’s information systems are hosted on central servers located in Hong Kong, mainland China and Dubai. Any personal data that we store on our systems will be transferred to one of those locations. See section 8 below for information about the safeguards Giordano adopts when transferring personal data overseas.

We will store your personal data for as long as you are a loyalty scheme member. Once Giordano has no legal or commercial reasons to retain personal data, it will be securely deleted or destroyed.

6.5- Subscribing to Giordano promotional eNews

We will process certain personal data about customers who sign up to receive promotional eNews from Giordano.

You may sign up to receive promotional eNews from Giordano by entering your email address in the eNEWS SUBSCRIPTION box on the Giordano website.

If you provide us with your email address, you consent to us using your email address to send you promotional offers, information about new products, and invitations to special events.

By entering your email address in the eNEWS SUBSCRIPTION box on the Giordano website, you consent to us processing your personal data for the above purposes. You can withdraw your consent at any time by unsubscribing using the link in our emails.

We may disclose your personal data to third parties who provide administrative, storage, telecommunications, information technology and other services to us in support of our business. However, we will ensure that all such service providers are subject to obligations not to use or disclose that data.

We may transfer your personal data overseas. Giordano’s information systems are hosted on central servers located in Hong Kong, mainland China and Dubai. Any personal data that we store on our systems will be transferred to one of those locations. See section 8 below for information about the safeguards Giordano adopts when transferring personal data overseas.

We will store your personal data for as long as you consent to receive promotional eNews from Giordano. If you unsubscribe, we may retain your email address on a “no marketing” list to ensure we do not inadvertently send you marketing communications in future.

It is entirely optional to subscribe to promotional eNews.

6.6- Service Providers

Giordano will collect certain personal data about individuals who are, or who are associated with, Giordano service providers.

To engage you or your organisation as a service provider, we will need to collect personal data about you, including your name, position, address, contact details, business details, qualifications and experience.

We may process your personal data for the purpose of allowing you or your organisation to provide, and for receiving, your services and for other purposes related to that purpose (for example, to pay you for your services).

If you are an individual service provider, you will have a contract with Giordano for the provision of services. The processing described above is necessary for taking steps to enter into that contract, or for the performance of that contract.
If you are an individual associated with a service provider, the processing described above is necessary for the purposes of Giordano’s legitimate interests in operating its business. See section 7 below for more details about Giordano’s legitimate interests.

We may disclose your personal data to third parties who provide administrative, storage, telecommunications, information technology and other services to us in support of our business. However, we will ensure that all such service providers are subject to obligations not to use or disclose that data.
In exceptional circumstances, we may be required or permitted by law to disclose personal data, for example to law enforcement authorities or to prevent a serious threat to public safety.

We may transfer your personal data overseas. Giordano’s information systems are hosted on servers located in Hong Kong, mainland China and Dubai. Any personal data that we store on our systems will be transferred to one of those locations. See section 8 below for information about the safeguards Giordano adopts when transferring personal data overseas.

Giordano will only retain personal data for as long as it has a legitimate purpose to do so. Giordano will need to retain personal data for commercial and legal purposes. How long it will need to retain personal data for these purposes will depend on the specific personal data. Giordano will generally retain your personal data for at least six years after you last provided services to us. Once Giordano has no legal or commercial reasons to retain personal data, it will be securely deleted or destroyed.

It is optional to provide most of the above personal data. However, in many cases, if you do not provide that data, it may affect our ability to assess your suitability to provide services to us, or your ability to provide services to us.

6.7- Contacting us with a query

Giordano will collect certain personal data about you if you contact us with a query, in store, by mail, email, fax or through our website.

We may collect your name and contact details, and any other personal data in your correspondence to us.

We may use your personal data to respond to your query.

The processing described above is necessary for the purposes of Giordano’s legitimate interests serving its customers. See section 7 below for more details about Giordano’s legitimate interests.

We may disclose your personal data to third parties who provide administrative, storage, telecommunications, information technology and other services to us in support of our business. However, we will ensure that all such service providers are subject to obligations not to use or disclose that data. Otherwise, we will not disclose your personal data outside Giordano, unless that is necessary to respond to your query.

We may transfer your personal data overseas. Giordano’s information systems are hosted on central servers located in Hong Kong, mainland China and Dubai. Any personal data that we store on our systems will be transferred to one of those locations. See section 8 below for information about the safeguards Giordano adopts when transferring personal data overseas.

Giordano will only retain personal data for as long as it has a legitimate purpose to do so. Giordano will need to retain personal data for commercial and legal purposes. How long it will need to retain personal data for these purposes will depend on the specific personal data.
Giordano may retain your personal data for as long as it takes to respond to your query. After we have responded to your query, we may retain your personal data for follow up or record-keeping purposes.
Once Giordano has no legal or commercial reasons to retain personal data, it will be securely deleted or destroyed.

You may choose what personal data you provide when you send us a query.

7- Legitimate interests

As noted in section 6 above, in some situations, Giordano may process your personal data on the basis of its “legitimate interests”.
Giordano Group is a global fashion retailer. As such, Giordano has a legitimate interest in:

Giordano will only rely on those legitimate interests to process personal data where:

8- Transfers

As noted in section 6 above, Giordano may transfer your personal data to other countries and/or regions.
The information systems of Giordano are hosted on central servers located in Hong Kong, mainland China and Dubai. Any personal data that we store on our systems will be transferred to one of those locations.
For the purposes of the GDPR, the European Commission issues adequacy decisions on the data privacy laws of non-EU countries and/or regions. A list of current adequacy decisions is available here: https://ec.europa.eu/info/strategy/justice-and-fundamental-rights/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
The majority of countries and/or regions to which Giordano may transfer personal data are not covered by an European Commission adequacy decision. However, many of them do have local data privacy laws which are similar to the GDPR.
Giordano will require that any overseas third party to which it discloses your personal data to: (a) only use that personal data for the purposes for which it was disclosed; (b) use all technical and organisational measures which are reasonable in the circumstances to secure that personal data; (c) delete that personal data when it is no longer required; and (d) treat that personal data in accordance with this Privacy Notice and their local data privacy law.

9- Automated decision-making including profiling

Giordano does not engage in any automated decision-making or profiling.

10- Website tracking and cookies

When you visit our website, we may maintain log files recording the following information:

The log files provide us with statistical information on how people use the site and what content people are viewing. They do not contain any personal data and they are not used to identify any individual.
We use cookies to collect the above information. For more information about our use of cookies, please refer to our Cookie Policy.

11- Your rights

If you are located outside the European Union and the United Kingdom
The PDPO provides you with the right to seek access to any personal data we hold about you, and to request correction of that data if it is incorrect. To make a request pursuant to these rights, contact Giordano’s Data Protection Officer (see section 3 above).
If you are located in the European Union or the United Kingdom
If you are located in the EU or the UK, you have additional rights in relation to your personal data as follows:

For more information about these rights, visit https://ico.org.uk/for-the-public/.
To make a request pursuant to these rights, contact Giordano’s Data Protection Officer (see section 4 above).

[Ref.: PN(EN)-201810]




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giordano fashions l.l.c
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