Your personal data shall be processed using paper, electronic or telematic means in order to pursue the purposes specified in this Information Notice, in compliance with EU Regulation 2016/679 (the ‘GDPR’), the Italian Legislative Decree no. 196/2003, as recently updated national laws in accordance with the Regulation (the ‘Privacy Code’), and the Malaysian Personal Data Protection Act 2010 and its subsidiary legislations, regulations, orders and codes of practice, as modified, replaced or re-enacted from time to time (collectively, the ‘Privacy Regulations’).

The data controller of your personal data is:

• FENDI S.r.l. with registered office in Palazzo della Civiltà, Quadrato della Concordia 3, 00144, Rome (RM), Italy, telephone 06334501, e-mail customerprivacy@fendi.com, in relation to all the purposes set forth in this Information Notice, except for processing related to the purchase of products in your country/region, made either through the Website or in the Stores;  
• The FENDI local entity, Fendi Fashion Malaysia Snd. Bhd., with registered office in Level 21, Suite 21.01 - The Gardens South Tower, Mid Valley City, Lingkaran Syed Putra, 59200, Kuala Lumpur, Malaysia, telephone +60 1800815602, e-mail customerprivacy@fendi.com, that manages the sale of products in Malaysia, either through the Website (as indicated in the Terms and conditions of sale) or in Stores, handles any related customer service activities, is in charge of organising FENDI events in Malaysia, and also processes your personal data for the Law Purposes and Business Purposes (as defined below).

(hereinafter jointly referred to as ‘FENDI’ or the ‘Company’). 

FENDI has also appointed a Data Protection Officer (‘DPO’), who can be contacted at the dedicated e-mail: dpo@fendi.com.

To the extent that they are necessary to achieve the purposes described in this Information Notice, FENDI shall process the following personal data:

• Browsing Data, i.e. IP address and domain name of the device used, URI (Uniform Resource Identifiers) notation addresses of the resources requested, time of the request, method used to send the request to the server, size of the file obtained in response, numeric code indicating the status of the response given by the server (e.g. successful, error, etc.), other parameters related to the device used, operating system and IT environment, as well as geolocation data on the Website through the ‘Locate Me’ function and data collected through cookies and other tracking technologies in accordance with the Cookie Policy;
• Identification Data, i.e.,
  • biographical data, such as title, first name, last name, country/region of residence, nationality, date of birth; 
  • contact information, such as address, city, postal code, e-mail address, phone number;
  • data relating to your Fendi profile/account, such as password, client ID, username;
• Contractual Data, i.e.:
  • payment, accounting and tax data, such as amount paid, payment method, identification references of the means of payment, IBAN and other bank data, tax code, VAT number, tax regime;
  • data on purchases made, such as body measurements (sizes), type of product or service, quantity, cost; 
  • additional data provided by you in connection with a request;
• Customer Experience Data, i.e.:
  • preferred language;
  • data on lifestyle habits and additional data (such as favourite colour, other brands you wear, marital status, number of family members and dates of birth, hobbies, profession, style, social networks, contact preferences, most visited countries/regions);
  • data on purchases made (such as products purchased and their features, price, frequency and purchase method, favourite store, favourite customer advisor, type of products purchased/preferred, spending segment, status);
  • if you subscribe to our newsletter, supplementary information on your interactions with the communications we send you.

Where you provide personal data of third parties (e.g., to facilitate delivery of purchased products), please ensure that such third parties are aware of the processing carried out under this Information Notice.
 

We process your personal data in order to manage a request or a contract concluded with you, in order to comply with legal obligations, for FENDI’s marketing and profiling purposes, as well as for meeting legitimate interests. 

1. Processing relating to the contractual relationship

FENDI offers you goods and services for which it is necessary to process personal data.

1. Contractual Purposes

The processing of your Browsing Data, Identification Data and/or Contractual Data pursues the purposes of rendering it possible to:

1. browse the Website, in order to use the specific functions and services provided therein, including, but not limited to, the option to create a user account by registering in the Fendi & Me area and thus subscribe, via the Website, to the FENDI loyalty program as described in sub b) and/or , if requested by you, to identify your position via the ‘Locate Me’ service in order to inform you of the Store nearest to you;
2. sign up and adhere to the FENDI loyalty program by filling out the relevant form, in order to take advantage of the services and benefits reserved by FENDI for its registered clients;
3. contact you in the event of a request forwarded by you in Store or through any communication channel(e.g. via the ‘Contact Us’ section, the email address and/or the phone number available on the Website as well as using our instant messaging platforms and our Live Chat on the Website and on our social channels);
4. purchase FENDI products in the Stores, on the Website, and at official events (e.g. bookings and purchases at fashion shows); 
5. manage payments and collections; 
6. provide customer care service, including after sales service, managing returns, managing refunds for defective purchases, handling of complaints, etc;
7. manage customer relations as part of events organised by FENDI (e.g. to manage invitations for attendance at fashion shows or inclusion on mailing lists for events); and
8. Send you our newsletter, if you choose to subscribe to it.

The above purposes are hereinafter collectively referred to as the ‘Contractual Purposes’.

2. Legal basis for processing for Contractual Purposes

Pursuant to Article 6(1)(b) of the GDPR, the legal basis for the processing is the performance of the contract to which you are a party or in order to take steps at your request.

The processing of your personal data for these purposes is mandatory, and if you do not wish for FENDI to proceed with the aforementioned processing, we may not be able to establish and/or perform a contractual relationship with you, thereby also preventing you from using products and services. 

This is without prejudice to the processing of Browsing Data by cookies and other tracking technologies on the Website. With respect to this, please refer to the Cookie Policy.

2. Processing in order to comply with legal obligations

FENDI is obliged to comply with legal obligations for which the processing of personal data is required.

1. Legal Purposes

Identification Data and Contractual Data will also be processed in order to comply with the obligations provided for under applicable laws and regulations and for civil, administrative, accounting and tax purposes, such as in the case of processing carried out in anti-money laundering and Tax Free regime (the ‘Legal Purposes’).

2. Legal basis for processing for Legal Purposes

Under Article 6(1)(c) of the GDPR, the legal basis for processing is the need to fulfil a legal obligation to which the Companies are subject.

The processing of your personal data for this purpose is mandatory, as it is required under the applicable regulations. 

3. Promotional, advertising and marketing processing in the broader sense

Subject to your consent, FENDI carries out business promotional activities for the products and services of the Companies.

1. Marketing Purposes

Subject to your consent, FENDI may process your Identification Data and Customer Experience Data for the following purposes: 

• market research, surveys, statistics, promotional campaigns, discounts, and/or other promotional activities concerning our products and/or services, as well as sending advertising and informative communications and material;
• invitations to events organised by the Companies;
• conducting re-engagement campaigns.

The above purposes are referred to as the ‘Marketing Purposes’. We will carry out the aforesaid processing by means of operator-assisted telephone or other non-electronic means, whether by e-mail, sms, mms, automated systems without operator assistance and similar, and other electronic means. You may express your preferences on the means used and for marketing communications by merely sending an e-mail to customerprivacy@fendi.com. 

2. Legal basis for processing for Marketing Purposes

Pursuant to Article 6(1)(a) of the GDPR, the legal basis for the processing, in all cases and processing provided for in this Section, is your prior consent, which you may in any case freely withdraw, at any time, free of charge, in the manner indicated in the Section ‘What are your rights and how you can exercise them’, without prejudice to the processing of data that has been legitimately carried out up to that time.

Should you refuse your consent for Marketing Purposes, this shall not affect your other existing relations with FENDI for which your prior consent is not required. Consent is optional, although failure to provide it will render it impossible for us to keep you updated on new products or services, promotions, and to conduct market surveys.

4. Profiling processing

Subject to your consent, we use your data as part of the profiling activities carried out in order to manage the FENDI world in a manner that is better in accordance with your requirements and preferences. 

1. Profiling Purposes

We also process Identification Data and Customer Experience Data for profiling purposes; namely, to assess certain aspects about a person, and analyse their personal preferences and interests, so as to be able to offer them personalised products and services which are in line with their needs. Through profiling, data is structured according to parameters which are defined, from time to time, according to business needs, for the purposes of creating a ‘profile’ of the data subject. For example, we may carry out profiling activities in order to perform targeted marketing campaigns (e.g., ‘look alike’ research or re-engagement).

Furthermore, the LVMH Group, to which FENDI belongs, includes many famous Maisons offering high quality products and services throughout all sectors, including Fashion and Leather Goods, Perfumes and Cosmetics, Watches and Jewellery, Wines and Spirits, Hotelerie, and Culture and Leisure (a list of all LVMH Maisons is available at https://www.lvmh.com). If you are a FENDI customer, you may also be a customer of one or more of the other LVMH Maisons. Our desire is to always improve your customer experience by providing you with personalised offers and services, and marketing communications that most closely match your expectations. For this purpose, data relating to purchases you have made with us over the past 36 months will be disclosed to LVMH as the parent company in pseudonymised form (and thus without unencrypted indication of your name and your further contact details). Your purchase data will be analysed and combined with data on other purchases you may have made with other LVMH Group Maisons during the same time period and for which you have provided similar consent. On the basis of the analysis and combination performed on such data, FENDI will receive additional information regarding your purchasing habits and preferences (without knowing, however, from which other Maison the data comes from). FENDI shall remain the sole data controller. LVMH shall act as a data processor and will not use your data for any purpose other than the one stated above, and under no circumstances will it share your data with other LVMH Group Maisons of which you are not a customer or to which you have not given your consent.

The above purposes are hereafter collectively referred to as ‘Profiling Purposes’.

2. Legal basis for processing for Profiling Purposes

In order to process for Profiling Purposes, it is mandatory to acquire your specific and separate consent (separate also from the consent for Marketing Purposes), which you may however freely revoke, at any time, free of charge, in the manner indicated in the Section ‘What are your rights and how can you exercise them’, without prejudice to the data processing legitimately carried out up to that time.

The provision of consent to the processing for Profiling Purposes is entirely voluntary and optional and, in the event of refusal of such consent, this will not affect the other existing relationships. However, failure to provide consent will entail that we will not be able to provide products and services which are in accordance with your requirements and preferences.

5. Processing in pursuit of FENDI’s legitimate interests

FENDI processes your personal data as part of operations to ensure the security and proper and effective operation of the Website, to make sure our services are effective and satisfying to you, as well as during corporate transactions and/or litigation proceedings, if any.

1. Business Purposes

FENDI processes:

1. Browsing Data, in order to ensure the security of the Website, verify its proper functioning and evaluate its use in order to obtain statistics regarding its use;
2. Identification Data and Customer Experience Data to measure the effectiveness of our services, perform customer satisfaction evaluations and analyse the commercial performance of the relationship established with you, in order to provide a service that is more in line with your needs;
3. Identification Data, Contractual Data and Customer Experience Data to carry out activities which are functional to transactions concerning transfer of businesses and business units, acquisitions, mergers, demergers or other transformations and for the performance of such transactions; and
4. Browsing Data, Identification Data, Contractual Data, and Customer Experience Data in order to assert and defend the Companies’ rights vis-à-vis you and/or third parties in any litigation proceedings, including the detection of fraud.

The above purposes are hereinafter collectively referred to as ‘Business Purposes’.

2. Legal basis for processing for Business Purposes

The processing of your personal data for these purposes is functional to the pursuit of FENDI’s legitimate interests, which are appropriately balanced against your interests, subject to the limits imposed on the relevant processing activities, and is not mandatory. You shall be entitled to object to the processing activities carried out for this purpose, as set out in the ‘What are your rights and how can you exercise them’ Section of this Information Notice, except where FENDI has an overriding interest in continuing the processing of your personal data or in asserting or defending a right pursuant to Article 21 of the GDPR or any other applicable Privacy Regulations.
 

The Companies disclose personal data to the following categories of recipients who are located – as applicable – in Italy, in the territory of the European Economic Area (‘EEA’) and in territories outside the EEA where the Companies operate:

• personnel of the Companies who need access to the data for the performance of their duties;
• banking and financial intermediaries and credit companies that provide services for the verification and management of collections and payments;
• third parties performing customer verification and fraud prevention activities; 
• companies that manage FENDI’s stores and warehouses, transport companies and couriers for the distribution and delivery of purchased products or for the collection and handling of returns;
• Website operators and suppliers in the technology field, including companies that perform documentation storage activities;
• companies that provide services to the Companies for the organisation of events (e.g., fashion shows), activities, campaigns and marketing strategies; 
• Companies that perform information assistance and support activities for data subjects (e.g., call centres); 
• professionals, consultants, companies or professional firms, that provide assistance, advice or collaboration to the Companies in accounting, administrative, legal, tax and financial matters;
• the parent company as the LVMH Group Holding Company and other companies controlled by or affiliated with FENDI;
• Public Administrations for the fulfilment of legal obligations relating to, inter alia, anti-money laundering regulations, public security laws or tax and fiscal regulations (e.g., Italian Internal Revenue Agency), as well as any other third party to whom the communication is required by law or by order of the Judicial Authority. 

To obtain the full and named list of data recipients, you may contact us at customerprivacy@fendi.com.

In any event, your personal data will not be disseminated. 
 

Your personal data is transferred to countries/regions outside of the area in which you originally provided it and, in particular, to those in where FENDI Group companies are operational and active including: Australia, Bahrain, Brazil, Canada, China, EEA, South Korea, the Philippines, Japan, Hong Kong, India, Kuwait, Macau, Malaysia, Mexico, Qatar, United Kingdom, Singapore, United States of America, Switzerland, and Thailand. 

The transfer to non-EEA countries/regions of your personal data for the purposes specified in this Information Notice shall take place on the basis of appropriate safeguards in accordance with Article 46(2)(c) of the GDPR, namely through the signing of standard contractual clauses adopted by the European Commission, as well as through the adoption of technical and organisational measures necessary to ensure, from time to time, adequate protection of your data, as required by the applicable Privacy Regulations, with the exception of countries/regions that have obtained an adequacy decision from the European Commission.
 
The personal data transfer agreement is available at the registered office of each of the Companies, of which you may request an excerpt should you wish to do so.
 

Personal data shall be retained for the time periods specified below, which are functional for the achievement of the purposes from time to time pursued by FENDI as set forth in this Information Notice.

Once the time limits below have passed, personal data will be deleted or anonymised.

1. Retention periods and deletion of data processed for Contractual Purposes

For Contractual Purposes, data is retained for the term of the contract and/or service requested (e.g., in the case of accounts created on the Website or in connection with services provided by FENDI), as well as for up to 6 years thereafter. 

2. Retention periods and deletion of data processed for Legal Purposes

For Legal Purposes, data is retained for a period equal to the duration prescribed for each type of data by law.

3. Retention periods and deletion of data processed for Marketing Purposes and Profiling Purposes

Purchase detail data processed for Marketing Purposes and Profiling Purposes is retained for 6 years following its collection. 

You may at any time terminate the processing and storage of data regarding you by notifying the Companies of your withdrawal of consent or objection to processing pursuant to Article 21 of the GDPR and any other applicable Privacy Regulations.

4. Retention periods and deletion of data processed for Business Purposes

Personal data processed for Business Purposes is retained for a period equal to the relationship established with you from time to time and for 6 years thereafter, in the event that the personal data is necessary to assert and defend the Companies’ rights vis-à-vis you and/or third parties in any litigation proceedings. In the event that the processing is for the purpose of carrying out activities which are functional to transactions concerning the transfers of business and business units, acquisitions, mergers, spin-offs, or other transformations, and with respect to the performance of such transactions, the retention periods listed above will apply with respect to the main processing that takes place.
 

Pursuant to Articles 15 to 22 of the GDPR and the applicable Privacy Regulations, we hereby inform you that you may exercise the following rights:

Right of access to your personal data in order to obtain confirmation as to whether or not personal data concerning you is being processed and, if so, to know the origin of the data, the purposes and methods of processing, and the logic adopted. 

Right to rectification and integration of inaccurate, incomplete, misleading or not up-to-date personal data concerning you. 

Right to erasure (and unless there are no specific reasons that otherwise exempt us from the obligation to erase) if (i) personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (ii) you withdraw consent and there is no other legal basis for processing; (iii) you object to processing for legitimate interests purposes; (iv) the personal data has been processed unlawfully.

Right to restriction of processing of personal data regarding you, including any personal data relating to other persons who may be identified from your personal data, in cases where (i) you contest the accuracy of personal data, for the period necessary to verify the accuracy of such personal data; (ii) the processing is unlawful and you object to the erase of the personal data and instead request that its use be restricted; (iii) although the Company no longer needs it for processing purposes, the personal data is necessary for you to establish, exercise or defend a right in court; (iv) you object to the processing pursuant to Article 21(1) of the GDPR or any other applicable Privacy Regulations, pending verification as to whether FENDI’s legitimate reasons prevail over yours. 

Right to object to the processing of personal data regarding you, including any personal data relating to other persons who may be identified from your personal data. 

Right to portability i.e. to receive your personal data in a structured, commonly used and readable format, so that such data may be retained for further use for personal purposes, and to ask us to arrange for the transmission of such data to another data controller.

You may exercise your rights as provided for by the Privacy Regulations by contacting our Client Services at +60 1800815602 or sending an e-mail to customerprivacy@fendi.com. 

The exercise of rights is not subject to any formal requirements and is free of charge. A response will be given without undue delay and, at the latest, within twenty-one (21) days from receipt of the request. 

You also have the right to file a complaint with the applicable local data protection authority, including, the Malaysian Personal Data Protection Commissioner.

This Information Notice is effective from the time of its publication. We may amend and/or supplement this Information Notice, including as a result of any subsequent regulatory amendments and/or additions to the Privacy Regulation. Amendments will be notified in advance and you can view the updated information notice at the Information Notice link.