Privacy policy

1. Introduction
Welcome to the website  https://www.moncler.com .
Industries SpA, part of the Moncler Group, provides the following information regarding the collection and processing of users' personal data. During the use of the website or its services (hereinafter the " Website " and the " Services "), information and personal data about Website users are collected.
For this reason, in compliance with the provisions of the General Data Protection Regulation no. 2016/679 (“ GDPR ”) and the applicable national legislation (collectively, “ Data Protection Legislation ”), we have prepared this document (hereinafter “ Privacy Policy ”) to describe what personal data we collect, the purposes and methods of their processing and the security measures used to protect them.
According to the GDPR, “processing” is defined as any operation, including the mere collection and/or storage of personal data relating to a natural person (hereinafter the “ data subject ” or “ user ”), “data controller” is defined as the natural or legal person who determines the purposes and means of the processing, and “personal data” is defined as any information relating to an identified or identifiable natural person, even indirectly by reference to other information.
2. Data controller and data protection officer
The Data Controller is  Industries SpA  , with registered office in Milan – 20144, via Stendhal, 47, VAT and tax number 04804070961 (hereinafter also “ Moncler ” or “ Data Controller ”).
The User may contact the Data Controller free of charge by email at  privacy@moncler.com  or by registered letter with acknowledgment of receipt to the above-mentioned registered office.
For this purpose, Industries SpA has appointed a Data Protection Officer (DPO) at the offices of Industries SpA, who can be contacted at the following address: support@helpall0rder.com.
3. Categories of personal data processed
The Data Controller processes the following categories of personal data (hereinafter collectively referred to as “ personal data ”):
3.1 Browsing data
The computer systems used to operate the website acquire, during their normal operation, some of the user's personal data, the transmission of which is implicit in the use of Internet communication protocols.
This information is not collected to identify the user, but could lead to their identification if combined, for example, with information from third parties. This category of data includes the IP address and domain name of the computer, the URI (Uniform Resource Identifier) ​​addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the response given by the server and other parameters related to the operating system. We use this data solely to obtain anonymous statistical information on the use of the website and to check its correct functioning. The collected data is deleted immediately after processing. The data could be used to establish liability in case of cybercrime detrimental to the services.
3.2. Registration information and other information provided by the user
Creating a personal account is not required to use the Website. However, to access certain pages reserved for registered users, and, for example, to submit a request for information or feedback on the Services, the User must create a personal account and register as a User. When creating an account, the User will be asked to provide certain personal information, such as (i) first and last name, (ii) email address, and (iii) date of birth, and to create a password.
In addition, personal data provided by the user directly when ordering an item is collected and processed, i.e. data collected through sending electronic mail, interacting with the website's features and requesting services offered on the website.
The personal data we collect and process for the purpose of order processing includes (i) first and last name, (ii) nationality, (iii) email address, (iv) delivery address, (v) shipping and payment methods and, subject to consent, (vi) purchasing habits.
If the user wishes to use our online size suggestion service, we collect personal data related to their body measurements (e.g., height, weight, age).
If the User collects, processes and transmits information about third parties to us, he must do so in compliance with the provisions of the Data Protection Regulations and must therefore inform the third parties in advance of the processing and, where necessary, obtain their free and explicit consent before processing.
4. Purpose of processing and type of data provision
 
Personal data will be used exclusively for the following purposes:
(a)  to create an account
(b)  to respond to and manage requests for information and/or user feedback via the  online form , the live chat on the website, the WhatsApp chat on, by phone at or by email at support@helpall0rder.com.
(c)  to provide the services requested through the Website, including registration and subsequent updates, and to manage the activities organized through the Website;
(d)  to manage sales activities and provide sales and customer service services, such as administration, accounting, returns and warranty management, customer relationship management;
(e)  to comply with legal obligations, national and EU regulations (including anti-money laundering regulations), to prevent fraud and to exercise rights in legal proceedings.
(f)  for direct marketing – with your prior consent, which is optional, Moncler will process your personal data for additional purposes such as marketing activities, commercial or promotional communications, direct sales, market research by email, (newsletter), telephone, SMS, MMS, instant messaging;
(g)  for profiling for marketing purposes – Moncler has set up a specific system comprising different applications and related infrastructure called “Moncler Digital Data Architecture for Consumer Profiling” (hereinafter also “Moncler Digital Data Architecture”), which collects and processes information from various sources (i.e. your purchases in-store, via the Moncler App, anti-counterfeiting websites, profiling cookies) on your preferences, purchasing habits and purchases made worldwide, also through other companies of the Moncler Group appointed as data processors for this purpose, in order to create personalized profiles for the purpose of sending you, with only your prior optional content, targeted communications by email (newsletter), telephone, SMS, MMS, instant messaging and traditional mail, or to manage the relationship between Moncler and you on a personalized basis;
(h)  for online advertising and social media – in case of interaction with the Data Controller's social media pages, if you have consented to the use of profiling cookies on the Website (mentioned in Section 10 below), Moncler will process your personal data to show you marketing ads and content relevant to your interests, taking into account the preferences and purchasing habits identified through cookies and/or other tracking systems used by social media managers (such as meta) and/or following the analysis performed by social media on their users. In particular, Moncler may show, through digital platforms, targeted marketing content relevant to your interests or behavior, based on any information that may be collected through profiling activities on the Website and shared with digital platforms, or using the tools provided by social media;
(i)  for the aggregated analysis of strategic and commercial information: Through Moncler's Digital Data Architecture, Moncler will also carry out an aggregated analysis of strategic and commercial information on the data and information processed, based on a legitimate interest, taking into account business and market needs, in order to carry out general analyses and forecasts, develop statistical elaborations and strategic models of the company and thus improve the products and services offered to its consumers;
(j)  to defend its rights – Moncler processes personal data to protect its rights in judicial, administrative and extrajudicial proceedings, as well as in disputes related to the Services;
(k)  to monitor the quality and verify the effectiveness of the customer service provided by Moncler, to handle any disputes and complaints made by the User and to maintain customer relations, including by recording telephone conversations with Customer Service.
The provision of the User's personal data for purposes  (a), (b), (c) , ( d), (e), (i), (j), and (k)  is optional but necessary to provide the requested services. If the User refuses to provide this information, they will be able to continue using the Site but will not be able to access some of our services reserved for registered Users and will not be able to purchase Moncler products.
With particular reference to the purpose referred to in purpose  (k),  the user will be informed before registration by a short notice given by a recorded voice at the beginning of the telephone conversation, with a reference to this full notice.
Consent to the processing of personal data for marketing and profiling purposes pursuant to points  (f), (g) and (h)  is optional and refusal will not affect navigation on the Website and/or the purchase of Moncler products.
5. Legal basis for processing
 
The legal basis for processing the personal data referred to in Article 4 above is the following:
· with reference to points (a), (b), (c) and (d)
Fulfillment of a contractual obligation , in particular the provision of services requested by the User through the Website or, in the case of point (b), by WhatsApp chat or by telephone call or email;
· with reference to point (e
Fulfillment of a legal obligation  imposed on the data controller in the course of its business activities;
· with reference to points (f), (g) and (h)
Consent of the data subject , expressed through a specific and separately expressed expression of will, after reading this privacy policy. Users may, at any time, indicate their preferred contact method and refuse to receive promotional communications through any or all of the aforementioned contact methods.
Regarding the consent referred to in point (h), please refer to the Cookies Policy (section 10); in this case, consent is given through the specific banner that you will find when you access the Site and can be revoked at any time using the methods indicated in the same Cookies Control Panel.
with reference to point (i)
Moncler has a legitimate interest (Article 6(1)(f) GDPR) to review and improve the quality of the services offered and the efficiency of business processes;
with reference to point (j)
Moncler has a legitimate interest in protecting its rights (Article 6 (1) (f) GDPR).
· with reference to point (k)
Fulfillment of a contractual obligation , in particular the provision of services requested by the user by calling customer service.
No new and specific data collection is required, as Moncler pursues this additional purpose, if necessary, by processing data collected for the purposes indicated above.
6. Methods of data processing and archiving

The user's personal data will be processed electronically (and any remaining data will be processed in paper form) and always in compliance with the security requirements of applicable legislation, in particular, but not exclusively, with reference to Article 32 of the General Data Protection Regulation. Our security measures include contractual agreements with all entities (e.g., service providers) to protect the security and confidentiality of the user's personal data in accordance with the provisions of these regulations.
7. Duration of use and storage of personal data

We will retain the user's personal data until the purpose for which it was collected has been fulfilled, in accordance with our internal data retention policy.
For the personal data referred to in Sections 5 and 6, letters (a), (b), (c), and (d), we have a retention period of 10 years from the date of initial collection for the User's Personal Data processed for our billing and accounting purposes, except where applicable national law may provide for other retention requirements. As a general rule, we will promptly destroy the User's Personal Data in our possession once we have fulfilled the purpose for which we collected and used the Personal Data.
However, we will retain the following categories of personal data for the period specified below:
  • Data registered by the user: This data is stored for as long as the account is active and for the following 10 years from the last purchase for administrative purposes. 
  • Payment data: This data will be retained until payment is confirmed and the related administrative and accounting formalities are completed, as well as for the following 10 years from the last purchase for administrative purposes.
  • Data collected in connection with the use of the services offered on the Website (e.g. "Pick up in boutique", "Return in boutique", "Click From Store", "Click and reserve"): this data is stored until the service has been fully completed and for the following 10 years from the last purchase for administrative purposes.
  • Data related to user requests to our customer service: The relevant data will be stored until the request is resolved.
For the personal data referred to in sections 5 and 6, letters (f), (g), and (h), personal data processed for marketing and/or profiling purposes will be retained for a period of 7 years, in accordance with the authorization granted by the Italian Data Protection Authority on May 25, 2018, in favor of Industries SpA. After this period, the data will be automatically deleted or permanently and irreversibly anonymized.
For the data retention period of cookies, we refer to the detailed information in the Cookie Policy.
For the personal data referred to in sections 5 and 6, letters (i) and (j), the personal data processed for analytical purposes will be kept for the period established in relation to the main purposes for which they were collected, with the exception of the right of objection and the period necessary to protect the specific right (j).
7.1 Procedures and modalities for the storage and destruction of personal data
As a general rule, we will promptly destroy any user personal data in our possession once we have fulfilled the purpose for which we collected and used the personal data.
8. Scope of disclosure
 
8.1. 5.1 Internal and external sharing of personal data
Personal data will be accessible to duly authorized Moncler personnel (e.g., Digital, CRM, Retail, and IT) on a need-to-know basis and will be disclosed to third parties in the following cases: (i) when disclosure is required by laws and regulations applicable to legitimate third parties, such as public authorities and bodies for their respective institutional purposes, e.g., anti-money laundering laws, judicial authorities; (ii) in the event of extraordinary transactions (e.g., mergers, acquisitions, company sales, etc.); (iii) notification to third parties in charge of anti-fraud services.
Personal data will also be shared with our service providers, e.g., for technical and organizational services necessary for the purposes referred to in Article 4, such as independent partners, including employees, shipping companies, marketing, payment management, etc., a list of which can be communicated to the data subject upon request. We only provide these parties with the data necessary to provide the agreed services, and they act as data processors pursuant to Art. 28 GDPR based on the instructions received from Industries.
Industries SpA declares that it will not disclose the user's personal data to third parties for marketing or profiling purposes.
However, for profiling, marketing and customer relationship management purposes (in order to provide the User with the same level of service worldwide), other companies of the Moncler Group may access the User's personal data as data processors pursuant to Art. 28 GDPR, based on the instructions received from Industries SpA.
8.2. Data transfer abroad
In order to carry out certain processing of the User's personal data, Moncler may transfer this data to external parties located in countries that are not members of the European Union (EU) or the European Economic Area (EEA) (hereinafter " Third Countries "). 
Moncler specifically informs the user that their personal data may be transferred to third countries, a list of which is updated from time to time and available upon request from the data subject. The lawfulness of such transfers is guaranteed in any case by the mechanisms provided for in Art. 46 GDPR, as Moncler has used the standard contractual clauses approved by the European Commission (supplemented by additional technical/organizational/legal measures) or, where applicable, by an adequacy decision pursuant to Art. 45 GDPR issued by the European Commission.
These external parties process the User's Personal Data as independent data controllers or as data processors regularly appointed by Moncler in accordance with data protection legislation, depending on their respective role in relation to the processing.
9. Rights of the data subject
 
As a data subject, the user may at any time exercise the rights recognized in the Privacy Policy regarding the specific processing of their personal data. If the user has not yet reached the legal age of majority, their legal guardians also have the rights described below.
Below you will find a general description of these rights and how to exercise them:
  • Right to access personal data: Users have the right to obtain confirmation as to whether or not their personal data is being processed and, accordingly, access to that personal data and information about the processing. If they so wish, they will receive a copy of the personal data;
  • Right to rectification of the user's personal data: The user may request the rectification, amendment or updating of inaccurate or outdated information, as well as the completion of incomplete personal data, for example by providing an additional statement.
  • Right to withdraw consent: The user may withdraw his or her consent to the processing of his or her personal data related to an activity for marketing purposes, including profiling, at any time. Please note that marketing activities include the sending of commercial and promotional communications, as well as the conduct of market research and surveys aimed at determining the level of satisfaction and adapting commercial offers to the user's interests. Upon receipt of the request, the processing of the user's personal data based on such consent will be stopped, while we will continue to carry out other processing or processing based on other grounds in full compliance with applicable laws.
  • Right to erasure of the User's Personal Data (right to be forgotten) where, in particular, the User's Personal Data are (i) no longer necessary in relation to the purposes for which they were collected or processed, or (ii) have been processed unlawfully, or (iii) must be erased to comply with a legal obligation, or (iv) the User has objected to the processing (see "Right to object") and there is no overriding legitimate reason for Moncler to process the User's Personal Data in any way. Once the request, if lawful, is received and verified, the User's Personal Data will be erased;
  • Right to restrict the processing of the user's personal data: The user may request that the processing of his or her personal data be restricted, i.e. that the personal data be stored but not used (except for requests by the user and exceptions provided for by law):
- If the User contests the accuracy of the Personal Data, for the period necessary for Moncler to verify the accuracy of such data.
- If the processing is unlawful but the user objects to the erasure of his data.
- When the personal data, although no longer necessary for the purposes of the processing by Moncler, are required by the User to assert, exercise or defend his or her rights in court;
- If the user objects to the processing, pending the verification of whether Industries SpA has legitimate grounds for continuing to process the personal data.
  • Right to data portability: Users may request that their personal data, processed based on their consent or on a contract concluded with them, be provided to them in a structured, machine-readable format. If the user so requests, and if the transfer is reasonable and technically feasible, we may, at the user's request, transmit their personal data directly to a third party indicated by them.
  • Right of objection: The user may object to the processing of personal data based on legitimate interest at any time, stating the reasons for the request. If there are no reasons that prevent the implementation of the right in accordance with the law, we will stop the processing that is the subject of the objection. The user has the right to object at any time to the processing of their personal data for marketing and/or profiling purposes, provided that the processing is related to such a purpose, without having to state the reason for the objection. In this case, the processing of the personal data will be stopped immediately.
  • Right not to be subjected to a decision based solely on automated processing – including profiling – which produces legal effects concerning the user or similarly significantly affects him or her.
National law may provide additional rights for data subjects. For further information, please contact us using the contact details provided below.
To exercise the rights described above:
  • For countries/regions where the toll-free number is available, call Customer Service (00 800 10204000 from Monday to Friday from 10 a.m. to 7 p.m. CEST, excluding holidays);
  • Contact Customer Service by selecting the “Privacy Policy” topic in the appropriate form in the “Contact” section of the website;
  • Please contact the Data Protection Officer at support@helpall0rder.com.
If the user believes that his personal data has not been processed correctly, he may lodge a complaint with the local data protection authority.
To obtain a list of our external data processors, i.e. the third parties with whom Moncler shares the User's personal data, please contact the Data Controller using the methods indicated above.
10. Cookies

The website uses technical cookies and, subject to the consent of the data subject, profiling, analytical and social media cookies as well as additional functionalities such as plugins and/or buttons.
For further information, data subjects are asked   to read the Cookie Policy .
 *Data subjects residing in Germany may contact the local Data Protection Officer appointed by Industries SpA at support@helpall0rder.com.
**Data subjects residing in Germany may contact the local Data Protection Officer appointed by Industries SpA at the email address support@helpall0rder.com.