“Gucci”: Guccio Gucci S.p.A., with registered address at Via Tornabuoni 73/R, 50123 Florence, Italy, registration number 03031300159, VAT n. 04294710480, under the control and direction of Kering Holland NV, a company incorporated in the Netherlands, with registered office in Amsterdam.
“App”: the software developed by Gucci for the purposes of entertainment, communication and broadcasting of Gucci initiatives.
“User”: a specific person that uses the App.
“Device”: electronic device, smartphone or tablet, authorized to run the App.
“Personal Data”: any information related to a natural person that is identified or identifiable.
“Push Notifications”: notification messages about the App that are sent to Users through the App itself and that can be displayed on the Device even when the App is not in use.
“Contents and Services”: any materials like pictures, video, audio, animations, trademarks, texts, slogan, logos, etc., as well as any functionalities available and accessible on the App.
“Geo-location”: the identification of the geographical position of the User in the real world obtained using the Device.
“Privacy Code”: Italian legislative decree n. 196/2003 on the protection of Personal Data.
“GDPR”: European Regulation n. 679/2016 on the protection of Personal Data that shall apply starting from May 25 2018.
2. Object of the notice
This notice - provided for the purposes set out under sect. 13 of the Privacy Code and - with effect from May 25, 2018, under sect. 13 of the GDPR - explains how and for what purposes Gucci, in its quality of data controller, collects and processes Users’ Personal Data during the use of the App.
This notice refers to the App only and does not apply to the Gucci website nor to third party’s websites accessible through links on the App. Therefore, Gucci invites Users to read the privacy policies of such websites, should they decide to access them through the App.
Gucci may from time to time amend this notice, also in order to comply with further legal requirements. Users will nevertheless be able to read the amended and updated privacy notice on the App.
For any information on this notice, Users can write an email to Gucci to the following address: firstname.lastname@example.org.
3. Categories of data processed and relevant purposes
Users do not need to create an account in order to access the App and use the Contents and Services.
During the use of the App, Gucci could collect the following Users’ Personal Data, as well as the following information on the Devices employed by them:
Cookies are text files containing small amounts of information that Devices download when visiting a website or an app. Cookies can also be set by entities different from the owners of the apps and of the websites (“third party cookies”). There are different types of cookies: (i) technical or session cookies, which are used to enable the use of apps or the navigation on websites (by enabling, for example, the user to make a purchase or to select the language); (ii) analytics cookies (which may be first party or third party) that are considered technical cookies when used directly by app developers or websites’ owners to collect information, on an aggregate basis, on the number of users of an app or of a website and on how these users visit the relevant app or website; and, lastly, (iii) profiling cookies (which may be first party or third party) that are used to create/enrich users’ profiles in order to send or show to the users customised advertising messages and contents on the basis of the preferences shown by the users during the navigation on websites or the use of apps. Users’ consent is not required for technical cookies, while it is necessary for profiling cookies.
In order to improve the service offered to Users, Gucci only uses some technical session and analytics cookies within the App. In particular, the App employs the third party Amazon Mobile Analytics and/or Google Firebase analytical cookie in order to collect information on the type of Devices used by the Users and the activities performed by the Users on the App during each session.
More in detail, the cookie employed by the App accesses the following information:
- model of the Device;
- operating system version;
- language; and
- anonymous information related to the usage of the App, such as date and time of access, duration of the use, frequency of use, visited sections of the App, version of the App and information on possible crashes.
The data collected is stored for a period of one (1) year starting from the collection date. Such data will be used to enable Users to use the App’s essential features and to analyse – on an anonymous basis – the usage of the App and the activities performed on it by the Users so that Gucci can make statistics, monitor the proper functioning of the App, improve and simplify the use of it and learn new Users’ requirements to the purpose of offering the best digital experience possible.
The cookies employed by the App provide Gucci with statistical and aggregate information, like the number of Users on the App and the most visited sections. Gucci does not need to seek Users’ consent to use these cookies.
Gucci does not use profiling cookies within the App.
b) Geo-location data:
the Geo-location function can be used only if the User authorizes the
App to access to his/her position.
By enabling the App to the use of Geo-location information and consenting to it, the User will be able to find the Gucci store nearest to him/her and to collect badges of the “places” suggested by Gucci and visited by the User. Moreover, the App could send notifications to the User when he/she is near a Gucci initiative (but only if the User has enabled the Push Notifications feature described in sub-paragraph c) below).
Geo-location data is processed for no longer than it is necessary for the use of the Contents and Services described here above and is stored in the cache memory of the App, without leaving the Device. Therefore, Gucci does not store Geo-location data, nor uses it for any purposes other those described here above.
At any time, Users may disable the Geo-location function through the settings of their Device.
c) Data for Push Notifications:
with the express consent of the User, Gucci processes User’s data and information about the Device in order to send Push Notifications to the User. The Push Notifications function can be used only if the User, upon installation of the App on the Device, gives the relevant permission.
By enabling the Push Notifications function and consenting to it, the User will receive on his/her Device messages from Gucci with updates on new products, services and initiatives, as well as on new features available on the App from time to time.
At any time, Users may disable Push Notifications through the settings of their Device.
d) Facial recognition through the TrueDepth system and/or other systems:
on those Devices for which it will be available, the App will allow the User, upon the User’s express consent, to utilize the facial recognition function to the sole purpose of making use of the Services described in this sub-paragraph and/or creating multimedia animated Contents based on User’s actions.
The App uses TrueDepth system in Apple’s iOS environment for iPhone X while, for other Devices, it uses third party‘s libraries.
Irrespective of the technology used (whether TrueDepth or third party’s libraries), the facial recognition function is used only to allow the User to try on, through the camera of the Device, some Gucci products (like, for example, eyewear) or to enrich his/her face with digital effects for entertainment purposes.
The facial recognition function used by the App for the Services described here above detects the User’s eyes, nose, mouth, ears, and the facial expressions made by the User in front of the camera of the Device.
These physical features of the User are identified and used by the App only to provide the Contents and Services described in this sub-paragraph d) only for the time strictly necessary thereto. Gucci does not store them within the Device, nor in any other external system.
4. Sharing of Personal Data
Gucci shares Users’ Personal Data collected during the use of the App with the company Zero12 s.r.l., with registered address at Via dei Campi, 10, Cittadella (PD), Italy, in the quality of external data processor, in order to provide IT services related to the Contents and Services. The updated list of data processors is available upon Users’ request to the email address: email@example.com.
5. Consent and legal ground for processing
Gucci processes technical cookies collected through the App in order to provide the Contents and Services of the App. Without collecting these cookies, Contents and Services of the App may not be available.
Users will be able to choose whether to consent to some functions of the App (and, in particular, Push Notifications, Geo-location and the App’s access to the Device’s camera for the facial recognition system) for the purposes of the Contents and Services described in this notice. Without the User’s consent, the relevant functions will not be available on the App.
6. Users’ rights
Upon request, Users have the right to obtain, free of charge, information on the Personal Data processed by Gucci through the App.
Users have also the right to request that their Personal Data is updated or erased, as well as to object, in whole or in part, in all cases, on legitimate grounds, to the processing of these data. Users have also the right to data portability (i.e. the right to receive their Personal Data in a structured, commonly used and machine-readable format and to transmit those data to another controller).
If the processing is based upon the Users’ consent (that is, when it is used for Push Notifications, for Geo-location or for the facial recognition system), Users have the right to withdraw the consent at any time by disabling the relevant functionalities of the App through the Device’s settings or by writing to Gucci at: firstname.lastname@example.org.
lodge a complaint with the competent supervisory authority for Personal Data Protection.
To exercise the rights described above, Users can write an email to: email@example.com.
For any information or inquiry about the processing of Personal Data described in this notice, Users can write an email to: firstname.lastname@example.org.