SYNTHETIC PRIVACY NOTICE

Art. 13 of the Regulation (EU) 2016/679 General Data Protection Regulation

The data you will provide us by filling in the present form (e.g. title, name, surname, date of birth, nationality , e-mail address, telephone number, mobile phone number, address, country of residence, ID card number) will be processed by the company Fendi Private Suites S.r.l ("FPS") in order to provide and manage our hotellerie services and connected services as well as to provide the level of hospitality expected, also based on your requests.

Furthermore, if you wish to provide your consent, FPS may use your data in order to:

  • contact you (e.g. by Newsletter, mail, e-mail, calls via operator, text messages, instant messaging, such as WhatsApp, WeChat and Social networks in general, posts, messages or communication on initiative on social networks, etc.) and keep you updated on FPS offers, promotions and/or services, initiatives and events organized by FPS or to which FPS adheres (e.g. new opening of hotels) or to have you participate in market surveys;

  • disclose your data to the company Fendi S.r.l. ("Fendi"), which may contact you (e.g. by Newsletter, mail, e-mail, calls via operator, text messages, instant messaging, such as WhatsApp, WeChat and Social networks in general, posts, messages or communication on initiative on social networks, etc.) and keep you updated on Fendi brand products, services, initiatives and events, or to have you participate in market surveys.

Should you not wish to provide your consent you can still take advantage of the services offered by us. Your consent can be freely withdrawn.

In general, personal data will be retained for no longer than is necessary for the purposes for which the data were collected. Your data necessary for managing the hotellerie services will be processed for the time necessary to reach such purposes and, subsequently, to comply with the related legal requirements (e.g. taxation and accounting requirements), after which the data will be cancelled or anonymized.

Processing of data collected by FPS and Fendi for the purposes of contacting you by sending communications on their products, services, offers and events and to participate in market surveys will be based on the consents you will provide us with, which can be in any case withdrawn at any given time. With limited reference to data collected for marketing purposes, data will be retained for a maximum period of 24 months by FPS and 7 years by Fendi.

At the time when consent will be revoked or, as the case may be, when the term above mentioned expires, data will be deleted or anonymized.

Please note that by sending an e-mail to info@fendiprivatesuites.com. for FPS and to customerprivacy@fendi.com for Fendi, you will always be able to access your personal data, update and delete them, withdraw or modify the consent you provided us with, and receive or ask for the transmission of your data to another data controller. Furthermore, you will always be able to object at any time to the processing of your personal data, especially for marketing purposes; you will have the right to lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it) or, if different, with the supervisory authority of the Member State of your habitual residence, place of work or place of the alleged infringement.

Should you need any further information, please read the complete text of the Full Privacy Notice hereinbelow, at the FPS concierge or on www.fendiprivatesuites.com. For Fendi, please read the complete text of the Full Privacy Notice Clients in Store in store or on www.fendi.com.

FULL PRIVACY NOTICE

Art. 13 of the Regulation (EU) 2016/679 General Data Protection Regulation

a) Who processes your personal data:

  • FENDI Private Suites S.r.l. with registered office in Via della Fontanella Borghese 48, 00186, Roma (RM), Italy, Fiscal Code, VAT Number and Register of Companies of Rome no. 13484701001, e-mail address info@fendiprivatesuites.com ("FPS") is the company in charge of the sale of Fendi brand hotellerie services and, in its quality of Data Controller, collects and processes your personal data, pursuant to Regulation (EU) 2016/679 General Data Protection Regulation (the "Regulation") for the purposes no. 1), 2) and 3) as set forth in paragraph b) below.

  • In case of expressed consent, Fendi S.r.l., with registered office in Palazzo della Civiltà, Quadrato della Concordia n.3, 00144, Rome (RM), Italy, Fiscal Code, VAT Number and Register of Companies of Rome no. 00900541004, telephone number +39 06 334501, e-mail address: customerprivacy@fendi.com ("FENDI"), in its quality of Data Controller, processes your personal data, pursuant to the Regulation for the purpose no. 4) as set forth in paragraph b) below.

b) How we collect and why we process your data:

The data you are providing to us:

- by filling in the present form and possibly your fiscal details (e.g. your fiscal code/VAT number, if necessary for tax free or invoicing)

will be processed, as the case, in order:

  1. to provide and manage the hotellerie services, the level of hospitality expected, also based on your requests, and fulfill the contract executed with you and the related services (e.g. reservation management, Customer Service, etc), as well as exercise our related rights, even in court.

  2. to fulfill legal obligations deriving from laws, regulations and EU laws and relevant obligations set forth by internal regulations (e.g. as regards taxation, accounting, anti-terrorism, money laundering and fraud, notifications and communications to the competent authorities - e.g. Questura -, internal audit).

  3. to keep you updated by sending you promotional material (e.g. by mail, e-mail, calls via operators, text message, instant messaging, (e.g. via WhatsApp, WeChat and Social networks in general), posts, messages or communications on initiative on social networks, etc.) on offers, promotions and/or services offered by us, initiatives and events organized by FPS or to which FPS adheres (e.g. new opening of hotels), as well as to have you participate in market surveys in order to improve our offer.

We specify that within the context of such services, FPS may also send you greetings for special occasions (e.g. Christmas).

  1. to disclose your personal data (title, name, surname, e-mail address, country of residence) to FENDI in order to keep you updated by sending you promotional material (e.g. by Newsletter, mail, e-mail, calls via operators, text message, instant messaging, (e.g. via WhatsApp, WeChat and Social networks in general), posts, messages or communications on initiative on social networks, etc.) on Fendi brand products (e.g. clothing, leather goods, accessories, home, etc.), services of Fendi world (e.g. purchasing methods, home delivery, etc.), initiatives and events organized by FENDI or to which FENDI adheres (e.g. new opening of Fendi stores), as well as to have you participate in market surveys to improve our offer.

The legal basis of the processing of your personal data will be, as the case, (i) the performance of the contract and the fulfillment of the obligations provided for by the law and regulations for purposes no. 1, 2 pursuant to art. 6, para. 1, lett. b) and c) of the Regulation, and (ii) the consent you may provide us with, for the purposes no. 3 and 4, pursuant to art. 6, para. 1, lett. a) of the Regulation.

At any rate, the processing will take place in compliance with the relevant Italian Data Protection Authority’s decisions (the "Authority") - and following updating and/or amendments - (among which the Decision on Loyalty Cards and Safeguards for consumers: Guidelines applying to loyalty programs – 24 February 2005. and Guidelines on Marketing and against Spam – 4 July 2013) as well as in compliance with the guarantees and measures prescribed in the Authority’s authorization to FENDI dated 22 December 2015.

c) Your consent:

In order to keep you updated on initiatives, offers, promotions and/or our services offered by us, as well as to disclose your personal data to FENDI in order to FENDI may, in turn, keep you updated on Fendi brand products (e.g. clothing, leather goods, accessories, home, etc.), services of Fendi world (e.g. purchasing methods, home delivery, etc.), initiatives and events organized by FENDI, as well as to have you participate in market surveys (purposes no. 3 e 4 paragraph b) we need your explicit consent. Should you not wish to provide your consent you can still take advantage of the FPS hotellerie services (purposes no. 1 e 2 paragraph b). Your consent can be freely withdrawn (as set forth in lett. j) of this Privacy Notice) at any time even by sending an e-mail to info@fendiprivatesuites.com for FPS and to customerprivacy@fendi.com for FENDI. the withdrawal of your consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Please note that, in case of withdrawal of your consent for sending updates, promotional communications or market surveys (purposes no. 3 and 4 paragraph b), you will no longer be the recipient of any type of communication. If you wish, you may withdraw your consent only to the receipt of communications via electronic means (e.g., newsletter, e-mail, sms, instant messaging), continuing to receive commercial communications only by mail or calls via operators, if provided and vice versa.

d) Which data are processed and which ones are mandatory:

For the purposes indicated above, FPS and FENDI shall process respectively and, as the case may be, the following categories of personal data:

  • personal details (title, name, surname, date of birth, nationality, ID card).

  • contact details (address, country of residence, e-mail address, telephone number, mobile telephone number).

We ask you to provide all the data requested as "mandatory" (e.g. name, surname, date of birth, nationality, address, country of residence, ID card) as needed to provide you hotellerie services and the level of hospitality expected or for the fulfillment of our legal obligations (e.g. communication to the competent Questura, fiscal/accounting obligations). in case of missing or incomplete compilation of such data, the services required cannot be provided. Failure to provide the data marked as "optional" (that are, the additional personal data (e.g. some contact details as the mobile phone number) useful to carry out the marketing activities listed above), will simply not allow us to use your data for the purposes no. 3 and 4 set forth in par. b) for which you have provided your consent. any refusal will have no consequences on your possibility of taking advantage of the hotellerie services, but it will not be possible for FPS and FENDI to inform you about their products, services, offers, initiatives and events.

If you provide personal data of third parties (e.g. your family members, other customers or potential customers) you must ensure that such third parties are informed and have consented (if necessary) for their data processing according with the hereby privacy notice.

e) How do we process your data:

Your data will be processed with and without the aid of electronic tools and stored,respectively by FPS and FENDI, on servers located in Italy.

In particular, if you provide us with your consent to use your data for the purposes no. 3 and 4 paragraph b, your data will be organized and processed using automated methods to keep you update by sending you promotional material on offers, promotions and/or services offered by us, initiatives and events organized by FDS or to which FDS adheres and, in case of disclosure of your data to FENDI, to keep you update on Fendi brand products (e.g. new collections), services of Fendi world (e.g. purchasing methods, home delivery, etc.), initiatives and events (e.g. invitations to events organized by FENDI or to which FENDI adheres), as well as to have you participate in market surveys (e.g. through interviews, telephone contact, e-mail, etc.).

We specify that all the processing activities carried out by FPS and FENDI will always involve the intervention and evaluation of our persons in charge of the processing.

The data will always be processed in compliance with the current legislation and, in any case, in order to guarantee their security and confidentiality and prevent their disclosure or unauthorized use, alteration or destruction.

f) Data entry into FENDI CRM (Customer Relationship Management) system:

The insertion of your data into FENDI CRM system – for the purpose no. 4) of paragraph b) above - is optional and will only take place if you provide us with your consent to the processing of your data. The insertion of your data into FENDI CRM system, will entail the possibility of reading, inserting and amending them by employees and staff (at the offices and stores) of FENDI and other retail companies of Fendi brand products in Italy and abroad (each for its respective field of competence) specifically authorized to data processing, pursuant to art. 29 of the Regulation.

g) How long do we store your data:

In general, personal data will be retained for no longer than is necessary for the purposes for which the data were collected. For the purposes no. 1 and 2 paragraph b) your data will be processed for the time necessary to manage the services provided and related services, and to comply with obligations provided by the laws and regulations (e.g. as regards taxation, accounting, money laundering and fraud, anti-terrorism, internal audit). afterwards the data will be deleted or anonymized.

For the purposes no. 3 and 4 paragraph b) your data will be processed, as the case may be, on the basis of the consents you will provide us with, which can be withdrawn at any given time (as set forth in lett. j) of this Privacy Notice). With limited reference to data collected for purposes no. 3 and 4 paragraph b) data will be processed for a maximum period of 24 months by FPS and 7 years by FENDI. At the time when consent will be revoked or, as the case may be, when the term above mentioned expires, data will be deleted or anonymized.

h) By whom your data are processed:

Your data will not be disseminated and will come to knowledge (within the respective field of competence) of the persons in charge of the processing at FPS and, as the case may be, at the competent Department, at Fendi, namely at Fendi CRM Department.

Your data will also be processed by companies appointed as external Data Processors and upon proper authorization and instructions which provide services related to hotellerie services or carry out on FPS and, respectively, Fendi, behalf and/or in on their interest activities (e.g. internal audit) or services[1].

i) Your data are transferred to Extra EU Country:

FPS will not transfer your data to extra-EU countries.

To allow FENDI to provide you with its services also in the event of purchases made at Fendi stores abroad, your personal data may be transferred to the extra-EU countries where Fendi stores are located. the list of Fendi stores is available on www.fendi.com.

Pursuant to the applicable legislation, we do not need your specific consent to transfer your data to third countries since the transfer is made on the basis of appropriate safeguards pursuant to articles 46 and 47 of the Regulation, such as the adoption of the standard data protection contractual clauses adopted by the EU Commission as it happens in the relationships with the retail companies that manage Fendi stores in the world.

The transfer of your data to any additional third countries, if necessary, will take place in full compliance with the safeguards, measures and rights as provided for by the Regulation. By simple request to be made to the contacts indicated in paragraph j), you will receive more information on the transfer of your data and on the safeguards provided for their protection as well as on the means by which to obtain a copy of the data or the place where they have been made available.

j) Which are your rights:

By sending an email to info@fendiprivatesuites.com for FPS and to customerprivacy@fendi.com for FENDI you will be able to exercise at any time the rights provided for by articles from 15 to 22 of the Regulation, such as:

  • obtaining confirmation as to whether or not personal data concerning you is being processed.

  • obtaining access to your personal data and to the information set out in Article 15 of the Regulation.

  • obtaining the rectification of the inaccurate personal data that concern you without undue delay or the supplementing of incomplete personal data.

  • obtaining the erasure of the personal data that concern you without undue delay.

  • obtaining the restriction of processing the personal data that concern you.

  • being informed of any rectifications or erasures or restrictions of processing in relation to the personal data that concern you.

  • receiving in a structured, commonly used and machine-readable format the personal data that concern you.

  • objecting at any time, on grounds associated with your specific situation, to the processing of the personal data that concern you.

In particular, you have the right to withdraw at any time the consents provided to the processing and to object to the processing of your personal data especially for marketing purposes.

k) Who you can contact to lodge a complaint:

We remind you that, should you consider the processing of your data infringes the Regulation, you may in any event lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it), or, if different, the Data Protection Authority of the Member State of your habitual residence, place of work or place of the alleged infringement.

l) Data Protection Officer (DPO):

You can contact the Data Protection Officer appointed by Fendi S.r.l at the e-mail address dpo@fendi.com.

Footnotes

1Your data may become to knowledge, as external Data Processorsand upon proper authorization and instructions, of the following recipients:

Companies with which FPS collaborates in the provision of products and services, such as car rental suppliers or suppliers of other services required.

(i) companies whit which FPS collaborates to provide goods and services, for example car rental suppliers or suppliers of other services you request.

(ii) companies on FPS behalf responsible for managing "Costumer Service".

(iii)companies in charge of processing, managing and sending newsletters and promotional material.

(iv) companies that organize and manage market research on FPS behalf.

(v) companies entrusted with the management of FPS website and the related computerised databases.

(vi) the company LVMH that can carry out, also in FPS interest, internal audit activities in relation to the compliance with obligations provided by the laws and/or regulation, including internal.

The names of all the external Data Processors can be requested to info@fendiprivatesuites.com.

In case of disclosure of your data to FENDI, your data may become to knowledge, as external Data Processorsand upon proper authorization and instructions, of the following recipients:

(i) retail companies which manage FENDI stores in Italy and abroad (if you have made purchases in FENDI stores).

(ii) if applicable, companies which on FENDI behalf carry out the analysis of your purchases.

(iii) companies on FENDI behalf responsible for managing Fendi "Customer Service".

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

(v) companies that organize and manage market research on FENDI behalf.

(vi) companies that deal with the management and technical maintenance of the FENDI CRM system.

(vii) the company LVMH that can carry out, also in FENDI interest, internal audit activities in relation to the compliance with obligations provided by the laws and/or regulation, including internal.

The names of all the external Data Processors can be requested via email to customerprivacy@fendi.com.