PRIVACY POLICY

Prada S.p.A., with registered office in Milan (Italy), the operating holding company of the Prada Group, and its subsidiary Prada Fashion Commerce (Shanghai) Co., Ltd., with registered office in Shanghai, PRC, the company directly operating the selling of products offered on https://www.miumiu.com/cn/en.html (hereinafter the “Website”) with shipping in the People’s Republic of China (hereinafter, both referred to as “PRADA”) recognise the importance of maintaining the confidentiality, integrity and security of your personal data (“Personal Data”), and hereby inform you that any Personal Data which you provide to PRADA through our Website, as well as any Personal Data which you may provide to a Prada Group store, including through its subsidiaries and/or affiliates (collectively the “Prada Group”), will be processed in compliance with current applicable laws on privacy and with any specific local regulations applicable from time to time, including the European General Data Protection Regulation (EU) 2016/679 (“GDPR”), as well as the E-commerce Law of People’s Republic of China together with the principles and general rules of conduct contained in the Code of Ethics adopted by the Prada Group.

 

Please read and confirm that you have fully understood this Privacy Policy before using the Website. By ticking the box “I have read and agree to the Privacy Policy” and using the Website in any way, or by providing your Personal Data through the Website, you agree (or by continuing to use the Website, services, or continue to provide your Personal Data after the Privacy Policy is updated on the Website, you continue to agree) to the Privacy Policy. Should you object to any terms of the Privacy Policy, you may not use the Website and you should not provide your Personal Data to the Website.


This Privacy Policy will help you to understand the following:
(1) Types of Personal Data that PRADA can collect and use
(2) Protection of minors' Personal Data
(3) Methods that PRADA may use to collect and use the Personal Data
(4) PRADA's purpose and legal basis of collecting and using Personal Data
(5) How PRADA shares, transfers, and publicly discloses your Personal Data
(6) Global transfer of your Personal Data
(7) How PRADA protects your Personal Data
(8) Retention period 
(9) Data Controller, Data Protection Officer and contact information
(10) Data subject’s rights
(11) Amendments to this Privacy Policy



1.      Types of Personal Data that PRADA can collect and use:
 

“Personal Data” means any information recorded electronically or otherwise that can identify a particular natural person or reflect the activity of a particular natural person, either alone or in combination with other information.
Based upon the information you provide or share, Personal Data may include:
(1) Personally identifiable information and contact information;
(2) Network identity information (such as account number, IP or email address and passwords, common orders, etc. related to the foregoing);
(3) Voice recognition features (such as phone call recording information);
(4) Personal property information (such as transaction records and account balances, bank accounts and coupons information, etc.);
(5) Body size and style preferences;
(6) Personal hobbies;
(7) Personal online records (such as website browsing records, software records, click records);
(8) Personal shopping records (offline or online);
(9) Address book information;
(10) Information about the usual equipment (such as hardware model, operating system type, etc.) describing the basic conditions of personal equipment;
(11) Personal location information (including itinerary information, precise location information, accommodation information, latitude and longitude, etc.);


In addition, “sensitive personal data” refers to Personal Data that, if divulged, illegally disclosed or abused, can harm personal or property safety, or can result in the damage of reputation, physical as well as physiological health or cause the person to be discriminated against, including: address book, personal phone number, mobile phone number, web browsing history.

 

 

2.      Protection of minor’s Personal Data 



You must be at least 16 years old (or older depending on the state of residence) in order to provide PRADA with Personal Data, and at least 18 years old to purchase products from our Website. If you are a minor, you should obtain prior written consent from your parent or legal guardian before providing your Personal Data. PRADA protects the Personal Data of minors in accordance with the relevant national laws and regulations.
For the collection of Personal Data of a minor with the consent of the parent or legal guardian, PRADA will only use or publicly disclose this information if it is permitted by law, with the explicit consent of the parent or guardian or the protection of the minor.
If PRADA discovers that it has collected Personal Data about a minor without the prior consent of a verifiable parent or legal guardian, it will de-activate the minor’s account and try to delete the data as soon as possible.



3.      Methods that PRADA may use to collect and use the Personal Data


Browsing data
During their normal operation, the computer systems and software procedures used to operate our Website collect certain Personal Data (log files). The transmission of such data is inherent to the use of internet communication protocols. This information is not collected in order to be associated with specific data subjects. However, due to its nature, this information can allow users to be identified by means of their processing and integration with data held by third parties. Such information includes the IP addresses or domain names of the computers you use to visit our Website, URIs (Uniform Resource Identifiers) of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, the numerical status code of the server reply (successful, error, etc.) and other parameters concerning the user's operating system and computer environment. This data is used with the sole purpose of obtaining anonymous statistical information on the use of our Website and to guarantee its correct operation.

 

Cookies
Our Website uses cookies to ensure its efficient functioning and to improve our services. Cookies are small text files that are sent to your computer (usually to your browser) by the websites you visit. Cookies are stored in your computer to be recognised by those websites on your subsequent visits. For more information on cookies, on the types of cookies used on our Website, on how to disable them and on how you can revoke your consent,  see our cookie policy.

 

Personal Data voluntarily provided by the data subject
PRADA collects, processes and use the Personal Data that you directly and voluntarily provide through our Website when: (i) you place online orders; (ii) register to our Website; and/or (iii) you use other functionalities available on the Website (for example: to subscribe to our newsletter, to send a request to our Client Service, to book an appointment in the store, etc.) PRADA may also collect, process and use the Personal Data that you may provide by filling in our customer card (hereinafter the “Customer Card”) at our stores. 
 

The items of Personal Data collected include personal information (title, name and surname, location, date of birth), contact and billing details (postal address, billing address, email, telephone), details of purchases and/or other information regarding you that you may decide to provide during the interactions with our Client Service or with sales staff. Mobile telephone number is required for verification purposes when you register an account. Addresses and telephone numbers are also required to process your online purchase order and to contact you for the requested delivery of your purchased product as well as contacting you for marketing purposes if you have consented to section 4(f) below. If you do not provide us with those details, we will not be able to perform the requested services. Furthermore, when you voluntarily send an e-mail through our Website and/or to the addresses indicated in our Website, PRADA collects your e-mail address so that PRADA can reply to any request, as well as any additional Personal Data contained in your message.
 

If you call our Client Service team or our Client Service team contacts you with the details you have provided to us, please note that calls may be recorded for quality assurance and training purposes and the recordings.Before recording you will be anyhow advised of this circumstance again.
 

In addition, PRADA may also obtain information about you as a result of authentication or identity checks (for example, you may be asked to present your identity document when you pick up your purchase in-store). PRADA use this information to identify you as a customer, to process your order, to deliver products and services and/or to process payments. 

The provision of Personal Data is optional. However, if you wish to make a purchase order for the products offered on our Website, and/or register to the Prada Group customer database, and/or use any other services offered on the Website, you need to fill in all mandatory fields of the relevant forms, otherwise PRADA cannot proceed with the contractual services requested.

You may expressly choose whether or not to consent to PRADA's collection, processing and use of your Personal Data for the purposes referred to under section 4, letters (c), (d), (e) and (f) above. If you do not consent, you may still place online purchase orders, but we will not be able to proceed with the indicated purposes including notifying you of any initiatives of interest to you, and/or send you any other commercial information on products, services, initiatives and events of the Prada Group, and you will not have access to the additional exclusive features reserved for registered members that may be useful for your shopping experience.

Please note that if you consent to the processing of your Personal Data for the purposes referred to undersection 4, letters (d), (e) and (f), after your registration into the Prada Group customers database, your Personal Data will be automatically visible to, and shared with, all Prada Group stores (inside and outside the People’s Republic of China and the European Union) to provide you with the same level of service around the world. PRADA will take all appropriate security and confidentially measures as required by applicable legislation to ensure an adequate standard of data protection.

You may withdraw or modify your consent to the processing of your Personal Data at any time, by writing to the Data Controller at the contact addresses indicated in section 9, or by using the “unsubscribe” link included in all of our commercial electronic communications, and/or by using any other appropriate procedures which may be made available to you by PRADA.

Please also note that unless you delete your Personal Data or withhold your consent for PRADA to collect your Personal Data, it is deemed that you have authorised PRADA to use all the Personal Data you have provided while using the Website for the duration of your use of the Website. Once you deregister your account, relevant Personal Data will be deleted or anonymised after fulfilment of any obligations due to you or otherwise required by laws.

 

4.      PRADA's purpose and legal basis of collecting and using Personal Data
Your Personal Data may be processed and used for the following purposes:
a)      to respond to all your requests and to manage your relationship with PRADA. (For this purpose, you need to provide your title, first name and last name, email address, phone number, location, language, and details of your request.)
b)      to fulfil your online purchase orders and perform all management activities connected with it (including administrative management of the contract, delivery of goods, payment processing, management of any claims and litigation, and fraud prevention), and to comply with any applicable legal or regulatory obligations. (For this purpose, you need to provide your title, first name, last name, email address, billing and shipping addresses, method of payment, mobile phone/telephone number.)
c)       to send by email the newsletter and other marketing communication regarding the Prada Group’s products, services, initiatives and events as a result of your subscription to the service. (For this purpose, we only require your email address)
 

Furthermore, if you agree to register to the Prada Group customers database (as a result of your registration to the Website or your signing of the Customer Card at a Prada Group store), your Personal Data will be managed by Prada S.p.A. and shared with all Prada Group’s stores globally, and may be processed and used, together with the details of your purchases online and/or in stores, for the following purposes:

d)      to confirm your identity as a registered Prada Group customer and, consequently, to provide a customized global customer service and post-sale service and allow you to access exclusive services and benefits reserved for registered members (e.g.: preservation of your purchase order history, faster online checkout, simplified procedures for product repair and warranty, commercial discounts, pre-sale and other promotional events, etc.).
e)      profiling: to perform individual or group studies, surveys, statistical analyses and market research with regards to your preferences for MIUMIU and the other brands, products and services of the Prada Group, so that a personalised service can be offered and cultural and recreational activities may be promoted based on customers’ interests.
f)      marketing: to contact and/or send you (by post, telephone, e-mail and any other form of electronic communicationor digital means including social network platforms and other instant messaging applications) information and promotions, including of a commercial nature, newsletters, advertising, catalogues and invitations to events concerning MIUMIU and the other bands, products and service of the Prada Group.

 

(For the purposes in (d), (e) and (f), you need to provide your title, first name, last name, location, and if you register through the Website, also your mobile phone number, email address and password. Your purchase details (including exchanges, refunds and repairs) are automatically uploaded from data saved in your account if you place a purchase order as a registered member). If you provide us with your date of birth as additional information, it will help us provide you with a more personalised service. If you do not provide such additional information, the basic functions of the services will not be affected.) 


The Personal Data processing referred to letters (a), (c) and (d) is necessary to provide the service requested by the data subject. The processing referred to letter (b) is necessary to execute the contract with the data subject or the related pre-contractual measures and to fulfill the connected legal obligations of an administrative and fiscal nature. Further, the data processing referred to letters (e) and (f) is based on the prior consent of the data subject.


If PRADA uses your Personal Data for other purposes not covered by this Privacy Policy, or if the information collected for a specific purpose will be used for other purposes, your specific consent will be sought in advance.



You are fully aware that PRADA does not require your consent to collect, process and use Personal Data inthe following situations:

• related to national security and national defense security;

• related to public safety, public health, and major public interests;

• related to criminal investigation, prosecution, trial and execution of judgments;

• in order to protect the data subject or other individuals’ lives and property, and the consent of the data subject is hard to obtain;

• the collected information has already been publicized by the data subject;

• collected from legally publicly disclosed information, such as legitimate news reports, government information disclosure, etc.;

• necessary to maintain the security and stability of the Website and Services provided, such as to fix the website or service;

• necessary to legitimate news reporting;

• other circumstances as stipulated by laws and regulations.


 

5. How PRADA shares, transfers, and publicly discloses your Personal Data


Sharing
Your personal data will not be used for promotional purposes of third parties, which are not related to the Prada Group, or for the promotion of products, services or programs of other entities other than the members of the Prada Group. At the same time, your Personal Data will not be disclosed to unknown persons under any circumstances. Where necessary for, and / or instrumental to, the above purposes, other entities acting as data processors may process your Personal Data on behalf of PRADA, including:

Other Prada Group’s companies and franchisees operating Prada Group stores (PRADA’s Affiliates);

• Companies, consultants, firms that provide advice and/or consulting activities, or perform related services that are instrumental to data processing on behalf of PRADA (such as service providers, couriers, IT technicians, companies hired by PRADA to arrange and/or manage their products or services, etc.) (“Service Provider”).

 

However, PRADA will only share the necessary Personal Data and the sharing is bound by the purposes stated in this Privacy Policy. Moreover, PRADA will only share your Personal Data for legitimate, proper, necessary, specific, and clear purposes. PRADA's Affiliates and Service Providers are not authorized to use the shared Personal Data for any other purpose.

 

Transfer
PRADA will not transfer your Personal Data to any company, organization or individual except:

• with explicit consent;

• In the event that PRADA has a merger, acquisition or bankruptcy liquidation situation, or other circumstances involving mergers, acquisitions or bankruptcy liquidation, if a Personal Data transfer is involved, PRADA will require the new company or organization holding your Personal Data to continue to be bound by this Privacy Policy, or the relevant company, organization and individual should obtain your specific consent.

 

Public Disclosure
PRADA will only publicly disclose your Personal Data under the premise of complying with safety precautions in the following circumstances:

• Disclose the Personal Data you specify in accordance with your needs with the disclosure methods that you expressly agreed to;

• Your Personal Data is required in accordance with the requirements of laws, regulations, mandatory administrative enforcement or judicial requirements.

 

In the following circumstances, sharing, transfer, and public disclosure of your Personal Data does not require your prior consent:
• related to national security and national defense security;

• related to public safety, public health, and major public interests;

• related to criminal investigation, prosecution, trial and execution of judgments;

• in order to protect the data subject or other individuals’ lives and property, and the consent of the data subject is difficult to obtain;

• the collected information has already been publicized by the data subject;

• collected from legally publicly disclosed information, such as legitimate news reports, government information disclosure, etc.;
 

Please be aware that, in accordance with applicable law, if PRADA takes technical measures and other necessary measures to deal with Personal Data, so that the data becomes anonymous or by removing personally identifiable information from the data, then the sharing, transfer and disclosure of such anonymised data need not require notification to, nor consent from, you.


 

6. Global transfer of your Personal Data
 

In principle, the Personal Data collected and generated by PRADA in the People's Republic of China will be stored in the territory of the People's Republic of China. However, all data stored in applications and systems of PRADA are stored in the European Union. 

 

However, as PRADA is part of an international network and uses global services, your Personal Data may be transferred abroad in accordance with applicable legislation, including to countries outside the People’s Republic of China and the European Union where PRADA pursues its interests, by adopting all appropriate security measures and safeguards to ensure an appropriate level of data security.


 

7. How PRADA protects your Personal Data
 

PRADA has adopted industry-standard, reasonably practicable security measures to protect your information from unauthorized access, public disclosure, use, modification, damage or loss. For example, when you exchange data between your browser and the server, it is protected by SSL protocol encryption; PRADA also provides HTTPS protocol secure browsing for the website; PRADA uses encryption technology to improve the security of Personal Data; PRADA uses trusted protection mechanisms that prevents Personal Data from being subject to malicious attacks; and PRADA deploys access control mechanisms to ensure that only authorized personnel have access to Personal Data. Your Personal Data will be processed by suitable electronic or automated means and computerised tools, or manually and on hard copy, exclusively for the purposes for which they have been collected and guaranteeing the security and confidentiality of any processed information. Your Personal Data will be processed only by the Prada Group’s internal staff duly authorised to do so under their respective job duties. 

 

PRADA will take reasonable and practicable steps to avoid collecting unrelated Personal Data. PRADA will only retain your Personal Data for the period of time required to achieve the purposes stated in this Privacy Policy (unless the law otherwise has a mandatory retention requirement).

 

The Internet is not an absolutely secure environment. When using the Website, please use a complex password to help PRADA secure your account. PRADA will do its utmost to ensure the security of any information you send to PRADA. If the physical, technical or managerial protective facilities of PRADA are damaged, resulting in unauthorized access, public disclosure, alteration or destruction of the information, resulting in damage to your legal rights, PRADA will bear the corresponding legal responsibility.

 

In the event that there is a Personal Data security incident, PRADA will notify you in accordance with the requirements under the relevant laws and regulations and the content of the notification should include, but not be limited to, the nature and possible impact of the security incident, the measures taken or to be taken, suggestions for how you can mitigate risks, and possible remedies for you. PRADA will inform you by mail, letter, telephone, notification, etc. When it is difficult to inform the individual information subject one by one, PRADA will issue a notice in a reasonable and effective manner.

 

At the same time, PRADA will report any Personal Data security incidents in accordance with the requirements of the regulatory authorities.


 

8. Retention period 
 

Your Personal Data will be processed and stored for as long as required to carry out the purposes for which they were collected, and in accordance with the storage periods required by the applicable laws, or until you revoke your consent to the processing, if applicable.  After the conclusion of such period, and where there is no legal or business purpose for retaining your Personal Data, it will be automatically and permanently erased or made anonymous. 
In particular, regarding the data processing of registered members into PRADA Group customer database:

• Personal Data collected for the purposes of customer management to offer personalized services and advantages reserved for registered members, are kept for a period of 7 years from the date of your last interaction with the PRADA Group; and

• Purchase details are kept for a period of 7 years from the date of purchase.


 

9. Data Controller, Data Protection Officer and contact information
 


For the purpose of managing and executing your online purchase order referred to in section 4 (a) and (b) above, the Data Controller is: 
Prada Fashion Commerce (Shanghai) Co., Ltd. 
Rooms 4109 & 4110, 41/F, Plaza 66 Office Tower Two, No. 1366 Nan Jing Xi Road, Jing An District, Shanghai, PRC
Email address: client.service.china@miumiu.com

 


For the purposes of data processing referred to in section 4 (c) to (f) above, the Data Controller is: 
Prada S.p.A., Via Antonio Fogazzaro 28, Milan, Italy
Email address: privacy@prada.com 

 

If you want to exercise your rights or receive any information on your rights and/or this Privacy Policy, please contact the Data Controller or the Group Data Protection Officer (“DPO”) by writing to Prada S.p.A., at the address/email address listed above.


 

10. Data subject’s rights
 

Please note that you may exercise the rights under the applicable privacy laws, by contacting the Data Controller as set out in section 9 above, including the right to:

• Access and correction of your Personal Data 

• Complete or delete your Personal Data. 

In the following situations, you can request PRADA to delete Personal Data :

- If PRADA's handling of Personal Data violates laws and regulations;

- If PRADA collects and uses your Personal Data  without your consent;

- If PRADA's handling of Personal Data violates the agreement with you;

- If you deregister your PRADA account;

- If PRADA terminates the Website.

 

If PRADA approves your request for deletion, PRADA will also notify the entity that has obtained your Personal Data from PRADA and request that the relevant data be deleted in a timely manner, unless otherwise required by law or regulation, or if these entities have obtained your separate consent. When you delete information from PRADA's services, PRADA may not immediately delete the corresponding information in the backup system, but PRADA will delete the information when the backup is updated.

 

You may withdraw your consent to the processing of your Personal Data by us at any time, by contacting the Data Controller as set out in section 9 above or by using any other appropriate procedures which may be made available to you by PRADA. For security reasons, PRADA may require you to provide a written request, or other ways to prove your identity, and PRADA will respond to your request within 30 days of receiving your feedback and verifying your identity. Please understand that each business function requires some basic Personal Data to be provided. When you withdraw your consent, PRADA cannot continue to provide you with the service corresponding to the withdrawal of consent, and will not process your relevant Personal Data. However, your decision to withdraw your consent will not affect the processing of Personal Data previously based on your consent before its withdrawal. 

 

In principle, PRADA does not charge any fees for your reasonable request, but for repeated requests that exceed reasonable limits, PRADA may charge a fee as appropriate. For those requests that are unreasonably repetitive, requires excessive technical requirements (for example, to develop new systems or fundamentally change existing practices), pose risks to the legal rights of others, or are very impractical, (for example, involving information stored on backup tapes), PRADA may refuse to assist in such requests.

 

PRADA will not be able to respond to your request in accordance with legal and regulatory requirements in the following situations:
• related to national security and national defense security;

• related to public safety, public health, and major public interests;

• related to criminal investigation, prosecution and trial;

• there is sufficient evidence that you have subjective malice or abuse of rights;

• responding to your request will result in serious damage to the legitimate rights and interests of you or other individuals or organizations;

• involving trade secrets.

 

If you are dissatisfied with PRADA's response, especially if you believe that PRADA's Personal Data handling actions have harmed your legal rights, you may lodge a complaint to the competent supervisory authority or seek a solution by filing a lawsuit in the court of the district where PRADA’s office is located namely Jing An District Court in Shanghai. 


 

11. Amendments of this Privacy Policy
 

PRADA reserves the right to amend this Privacy Policy at any time. However, PRADA will post any changes to the Privacy Policy on the website. For major changes, PRADA will also provide more conspicuous notices (including notifying you via the website or even providing you with a pop-up reminder). The Privacy Policy currently in force is the version published on our Website.

 

 

 

Last updated: 12 November 2019

 

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