The purpose of this document is to inform you about the characteristics of the processing of your personal data carried out by the Companies of the Kiton Group when you make a purchase in one of our boutiques or through our e-Commerce accessible from the website www.kiton.com

1. Data Controller

The Kiton Group, given its international character and pursuing the objective of providing customers with a homogeneous shopping experience within its boutiques, has intended to optimize the processing of intra-group data by dividing them by the various legal entities according to the purposes pursued. The attribution of the various treatments is summarized below:

a) In relation to purchases made at our boutiques, the processing carried out for contractual purposes (referred to in paragraph 2 point a), administrative/accounting, financial and tax purposes fall under the ownership of the individual legal entity to which the boutique belongs (for the detailed list of our boutiques see: https://it.kiton.com/pages/boutiques) where the purchase was made, among those listed below:

• Kiton Italia Srl with registered office in Via Della Spiga 9 – 20121 Milano e Partita IVA 3865070969
• Kiton Deutscheland GmbH with registered office inNeuturmstrasse 10, 80331 Munchen and VAT NUMBER 129369080
• Kiton Germany Retail GmbH with registered office inNeuturmstrasse 10, 80331 Munchen and VAT NUMBER 268087713
• Kiton France Sasu with registered office in29 Rue Marbeuf – 75008 Paris and VAT NUMBER46487808420
• Kiton Austria GmbH with registered office in Börseplatz 4 1010 Wien and VAT NUMBER079644805
• Kiton Kondon UK Ltd with registered office in17 Grosvenor Street, Mayfair, London and VAT NUMBER874870968
• Kiton Switzerland AG with registered office in18, Bahnoffstrasse – 8001 Zurich and VAT NUMBER107465458 Ciro Paone New York Inc with registered office in4 East 54th Street, 10022 New York, N.Y.
• Kiton Fifth Avenue LLC with registered office in 4 East 54th Street, 10022 New York, N.Y.
• K Madison LLC  with registered office in4 East 54th Street, 10022 New York, N.Y.
• Kiton FS NY LLC with registered office in4 East 54th Street, 10022 New York, N.Y.
• Kiton  Las Vegas   LLC  with registered office in4 East 54th Street, 10022 New York, N.Y.
• Kiton Brickell City Centre LLC  with registered office in4 East 54th Street, 10022 New York, N.Y.
• Kiton  Miami   LLC  with registered office inStore 150  9700 Collins Ave Ste 115, Bal Harbour, 33154
• Kiton  Palm Beach  LLC  with registered office in340 Royal Poinciana Way, Palm Beach, Fl 33480
• Kiton  Aspen  LLC  with registered office in4 East 54th Street, 10022 New York, N.Y.
• Kiton  San Francisco LLC  with registered office in4 East 54th Street, 10022 New York, N.Y.
• Kiton  Houston LLC  with registered office in4444 River Oaks District Westheimer RD. Suite A165, 77027

For all of them, the reference email for issues related to the protection of personal data is privacy@kiton.it

b) for marketing, profiling and “soft spam” purposes (both for online and offline purchases) the Data Controller is the Parent Company and owner of the Kiton brand, Ciro Paone S.p.A., with registered office in Via San Pasquale a Chiaia, 83, Naples – Tax Code and VAT number 06034520632. The company employs a data protection officer who can be reached at dpo@kiton.it

c) for processing related to purchases on our e-commerce (and only for administrative/accounting, financial and tax purposes and related to delivery logistics, customer care management) the Data Controller is:

1. For the EU: the company Kiton Italia S.r.l. – with registered office in Via Della Spiga n.9 – Milan Tax Code and VAT number 03865070969 – privacy@kiton.it
2. For the UK, the company Kiton UK Limited with registered office at 17 Grosvenor Street, Mayfair, London
3. For Switzerland, the company Kiton Switzerland AG with registered office at 18, Bahnoffstrasse – 8001 Zurich
4. For the USA, the company Ciro Paone New York Inc with registered office at 4 East 54th Street, 10022 New York, N.Y.

For all the above-mentioned companies, the reference email for issues relating to the protection of personal data is concierge@kiton.it

2. Purpose, legal basis of the processing and data retention period

Your personal data will be processed for the following reasons:

1. to (i) manage the sale of its products and provide sales and after-sales services (including, for example, fraud prevention, returns, product warranties and customer support, handling any complaints and disputes); (ii) in the context of online activities, create and maintain your personal account (iii) respond to your requests for information submitted through the contact channels of the Data Controller. The legal basis is the performance of the contract between the Parties. The maximum data retention period is 10 years from purchase.
2. to comply with current legal obligations in accounting, financial and tax matters. The legal basis is the fulfilment of a legal obligation imposed on the Data Controller. The retention period is set by each Data Controller according to the applicable national legislation.
3. for marketing purposes, i.e. to send newsletters and commercial communications relating to Kiton Group products and/or services, through traditional (e.g. ordinary mail, telephone, etc.) and electronic (sms, WhatsApp, etc.) systems with prior consent, and/or to invite you to exclusive events and/or to carry out Customer Satisfaction surveys. The legal basis for the processing is the freely expressed consent, which can be revoked at any time. Personal data will be stored until the consent given is revoked.
4. for profiling purposes, i.e. to analyse, subject to consent, your personal data (e.g. geographical origin, gender, etc.) and your purchasing habits and preferences, and browsing behaviour on our website, communications and personalised offers. The legal basis for the processing is the freely expressed consent, which can be revoked at any time. The data retention period has been set, considering the nature of the goods in question, at 7 years from the last purchase made and/or from the last contact with you (for example, participation in an event, use of a specific service, opening commercial communications), on the basis of an impact assessment on the processing carried out by the Data Controller.
5. for “soft spam” purposes, i.e. the possibility for the Data Controller to send you, in the event that you have not expressed an express message, promotional electronic communications relating to products and services similar to those previously purchased. The legal basis for the processing is the legitimate interest of the Data Controller, to which the data subject may object at any time by using the unsubscribe mechanism provided at the bottom of each communication or by writing to the address dpo@kiton.it. The data is processed until any objection is made.

3. Personal data subject to processing

Your personal data, which are processed for the purposes referred to in the previous point, belong to the following categories:

• identification and personal data, such as: name, surname, gender, origin, date of birth.
• contact information, such as phone number and e-mail address;
• data relating to purchases made, such as type of products purchased, spending volumes, purchase history, order number, etc.;
• billing data, such as tax code or VAT number;
• shipping data such as delivery address and personal data of the recipient;
• data relating to your personal account or navigation on the ww.kiton.it site, such as navigation data and tracking data obtained from cookies installed on the site (for more information, see the website’s cookie policy).

4. Methods of processing personal data

The processing of personal data will take place with the use of paper-based and digital methods. For marketing and profiling purposes, the processing will take place in automated and telematic form (e-mail, WhatsApp, text messages, automated call systems without operator) and/or traditional (paper media, ordinary mail or non-automated telephone communication). In any case, the processing will take place with logics strictly related to the purposes indicated in order to guarantee the security and confidentiality of the data.

5. Scope of data circulation

Your data may be processed by the following categories of subjects (so-called “data subjects”). Recipients):

• Personnel of the Kiton Group company operating as data controllers, expressly designated/authorised to process the data and duly instructed and trained for this purpose;
• Third-party companies, internal or external to the Kiton Group, or freelancers who carry out services or instrumental activities (e.g. tax and tax consultancy; communication agencies, hosting providers, software houses, payment service providers, etc.) on behalf of the Data Controller, which operate on the documented instructions of the Data Controller on the basis of specific contractual agreements and confidentiality constraints;
• Public bodies, bodies and authorities to which the communication may be required by applicable law to the Data Controller in question.
• We also inform you that if you consent to the processing of your Personal Data for marketing, profiling and soft spam purposes, your data will be automatically visible and/or shared with all Kiton Group stores located in Europe, Switzerland, the United Kingdom and the USA, adopting all the appropriate and appropriate security and confidentiality measures required by the relevant applicable legislation and in any case according to standards equal to or higher than those provided for ensure  GDPR compliance.

In the event of the transfer of personal data abroad, each Data Controller undertakes to ensure an adequate level of protection, where appropriate through the stipulation of specific contractual clauses.

6. Rights of data subjects

As an interested party, you may exercise your rights, including the right of access to personal data, the right to request its correction and/or updating, and, where the conditions are met, the right to erasure or limitation of processing and the right to object to the processing or to revoke the consent given.  you will have the right to lodge a complaint with the competent Supervisory Authority identified on the basis of the country of origin of the Data Controller in question. In order to exercise your rights, you may contact the competent Data Controller, through the channels identified in point