Privacy and Cookie Policy

1 • Preamble

Welcome to our website moncler.com. The companies YOOX NET-A-PORTER GROUP S.p.A. ("YNAP") and Moncler S.p.A. - Moncler Group ("Moncler") hereby provide you with the following information about the collection and processing of your personal data. When you use the site or its services (hereinafter, the "website" and the "Services"), information and personal data about you is collected. For this reason, in accordance with the provisions of the General Data Protection Regulation no. 2016/679 ("GDPR") and applicable national legislation (collectively, "Privacy Legislation"), we have created this document (hereinafter "Privacy Policy") for the purpose of describing what personal data we collect, the purposes and methods of its processing and the security measures used to protect it.

2 • Data controllers and their respective Data protection officers

YNAP and Moncler act as independent data controllers.

As an independent data controller, YNAP will process your personal data in order to manage online sales activity (e.g. managing orders and payments), as well as for "pick-up in store", "return in store" and "click from store" services.
YNAP can be contacted by writing to YOOX NET-A-PORTER GROUP S.p.A., via Morimondo 17 – 20143 Milano, Italy.
YNAP has appointed a Data Protection Officer (DPO), who can be contacted personally at the following addresses:
Address: Data Protection Officer - DPO at YOOX NET-A-PORTER GROUP S.p.A., via N. Nannetti n. 1, 40069 – Zola Predosa, Bologna (BO), Italy;
Email: DPO@ynap.com.

As an independent data controller, Moncler will process your personal data in order to carry out marketing activities (e.g. newsletters), profiling, as well as for the "click and reserve" service.
Moncler can be contacted by writing to Moncler S.p.A. – Moncler Group, via Stendhal n. 47, 20144 - Milan (MI), Italy.
Moncler has appointed a Data Protection Officer (DPO), who can be contacted personally at the following addresses:
Address: Data Protection Officer - DPO at Moncler S.p.A. – Moncler Group, via Stendhal n. 47, 20144 - Milan (MI), Italy;
Email: privacy@moncler.com and dpo@moncler.com.

3 • Sources of data and the purposes of data processing

3.1 Browsing data

During their normal operation, the computer systems used to operate the Website acquire some of your personal data, the transmission of which is implicit in the use of Internet communication protocols. This information is not collected for the purpose of identifying you, but may lead to your identification if, for example, it is combined with information held by a third party. This category of data includes the IP address and domain name of your computer, the URI (Uniform Resource Identifier) addresses 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 code indicating the status of the reply given by the server and other parameters relating to your operating system. We use this data for the sole purpose of obtaining anonymous statistical information on the use of the Website and to check it is working properly. The data collected is deleted immediately after processing. The data could be used to ascertain responsibility in the event of cybercrime committed to the detriment of the Services.

3.2 Registration information and further information provided by the user

Use of the Website does not require the creation of a personal account. However, in order to access certain pages reserved for registered users and, for example, to send us a request for information or feedback on the Services, you must create a personal account and become a registered user. When you create your account, you will be asked to enter the following registration information:

• first name and surname,
• email address,
• password,
• date of birth,
• gender.

In addition, personal data voluntarily provided by you when you place an order to purchase an item will be collected and processed, this consists of data collected by sending electronic mail, interacting with the functionality of the Website and requesting services offered by the Website. The personal data we collect and process includes your first name, surname, gender, nationality, email address, and shopping habits.

Finally, personal data voluntarily provided by you in case of contact request for assistance by phone, which can made by contacting a dedicated toll free number, as well as further information such as the calling phone number (if not hidden) and call duration, will be collected and processed. For the purposes described below, Moncler does register both customer service’s inbound and outbound phone calls.
Should you collect, process and disclose information about third parties to us, you must do so in accordance with the provisions of the Privacy Policy and, therefore, you must provide them with prior notice of the processing and, if necessary, you must obtain their free and express consent before carrying out the processing.

3.3 Purpose of the processing

Providing the above registration information is necessary in order to create an account and also to respond to and manage requests for information and/or user feedback; to provide the services requested through the Website, including registration and subsequent updates and to manage the activities organised through the Website; to carry out statistical analysis and surveys; to manage sales activities and to provide sales and after-sales services, such as administration, accounting, returns and guarantee management, fraud prevention, customer relationship management, including compliance with legal obligations, regulations and EU regulations (including anti-money laundering regulations) and to exercise rights in legal proceedings.
Any refusal by you to provide this information would still allow you to use the Website, but would prevent you from using some of our Services reserved for registered users.
In addition, your personal data must be processed in order to fulfil the contractual relationship arising from the purchase of Moncler products. The provision of such data is a contractual obligation. You are free to disclose your data to us or not, but in the absence of the requested data it will not be possible to conclude or execute the agreement and your requests. This means that you will not be able to purchase Moncler products and that it will not be possible to handle your requests.

Providing your personal data in case of contact for phone assistance is necessary in order to reply to and manage your request of assistance. Providing such data is necessary for the execution of a contract you are a part to or to execute pre-contractual measures adopted upon your request. You are free to provide your personal data or not, but in case we miss the requested data, we will not be able to fulfill your request of assistance. Registering both inbound and outbound customer service phone calls is necessary in order to improve quality and efficiency of the offered customer care service. This is feasible by virtue of the evaluations of impact made by Moncler on the possible prevalence of your essential interests, rights and freedom requesting personal data protection on its own legitimate interests to register inbound and outbound phone calls, seeing the main reason of the prevalence of its own legitimate interests in the common interest of supplying to customer an efficient and punctual service.

3.4 Further purposes of the processing

With your consent, which is optional, Moncler will use your personal data for further purposes such as marketing, commercial or advertising communications, direct sales, market research, in-store sales support worldwide through email (newsletter), telephone, SMS, MMS, chat, instant messaging, social networking and traditional mail, including sending invitations to events. You may at any time indicate your preferred means of contact from among those listed above and you may refuse the receipt of promotional communication by any or all of these means of contact.

With your consent, which is optional, Moncler collects information about your preferences, habits and lifestyle as well as details of purchases made in order to use these to create group and individual profiles ("profiling") and to send you personalised communications. Personalised communication may be sent by email (newsletter), phone, SMS, MMS, chat, instant messaging, social networking and traditional mail. You may at any time indicate your preferred means of contact from among those listed above and you may refuse the receipt of promotional communication by any or all of these means of contact.

Consent for the above marketing and profiling purposes is optional and refusal will not have any consequences. Data may be provided by you on registration at our points of sale by means of paper and/or electronic forms, acquired during visits to our stores belonging to the Moncler Group or through interaction with websites, internet applications and mobile applications belonging to the Moncler Group.

3.5 Legal grounds for processing

Your personal data is only processed if one of the legal requirements laid down by current legislation is met, and specifically:

1. for the conclusion and execution of a contract to which you are party in relation to the purchase of products offered on the Website, as well as the provision of Services for registered users and of phone assistance through dedicated toll free number;
2. to fulfil a legal obligation to which the controllers are subject within the context of the purposes of their activities;
3. for the legitimate interests of the controller, with particular reference to the prevention and prosecution of fraudulent activities, for improvement of the offered customer care services, as well as for internal administrative purposes, on the basis of which communication of the data to companies belonging to the controller’s group of companies is legitimate;
4. with your consent in respect of marketing and profiling activities.

3.6 Information collected through cookies and other technologies

The following information concerning the use of cookies and similar technologies on the site www.store.moncler.com ("Site"), is provided to the user/visitor ("you") in compliance with European and Italian legislation on the processing of personal data and electronic communications.

YNAP and Moncler act as independent data controllers.

As an independent data controller, YNAP will process your personal data in order to manage online sales activity (e.g. managing orders and payments), as well as for "pick-up in store", "return in store" and "click from store" services.
YNAP can be contacted by writing to YOOX NET-A-PORTER GROUP S.p.A., via Morimondo 17 – 20143 Milano, Italy or by writing to our Customer Care department and choosing "privacy".

As an independent data controller, Moncler will process your personal data in order to carry out marketing activities (e.g. newsletters), profiling, as well as for the "click and reserve" service.
Moncler can be contacted by writing to Moncler S.p.A. – Moncler Group, via Stendhal n. 47, 20144 - Milan (MI), Italy.
Email: privacy@moncler.com. The DPO can be contacted at the following address: dpo@moncler.com.

What are cookies?

Cookies are small text files that are sent to you and saved on your computer or mobile device, which are then retransmitted to the same sites the next time you visit. Thanks to cookies, the site remembers the user's actions and preferences (such as login details, preferred language, font size, other display settings, etc.) so that they do not have to be indicated again when the user returns to the site or navigates from one page of it to another. Cookies, therefore, are used to perform digital authentication, session tracking and storage of information regarding users' activities when accessing a site and may also contain a unique identification code that tracks a user's navigation within the site itself for statistical or advertising purposes. While browsing a site, you may also receive cookies from sites or web servers other than the one you are visiting (third party cookies) on your computer or mobile device. Certain actions cannot be carried out without the use of cookies, which in certain cases are technically necessary for the site to function properly.

There are different types of cookies and their functions vary according to their characteristics. They can stay on the user's computer or mobile device for different periods of time. For example, session cookies are automatically deleted when the browser is closed, whereas persistent cookies remain on the user's device for a predetermined amount of time.

According to current legislation, the use of cookies does not always require the express consent of the user. In particular, technical cookies do not require such consent; in other words, they are cookies that are essential for the operation of the site or necessary to perform activities requested by the user.

On the other hand, the user's prior consent is required for profiling cookies, i.e. those aimed at creating profiles related to the user and used to send advertising messages in line with the preferences expressed by the user when surfing the web.

Which cookies are used on the Site?

The Site uses all of the above mentioned types of cookies in order to: operate the Site and for the provision of the services, understand and improve the user's browsing experience, as well as send you advertisements in line with your preferences when surfing the web and use other types of cookies.
We can divide the various types of cookies into:

• technical cookies, i.e. browsing or session cookies which are strictly necessary for the operation of the Site or to allow you to take advantage of the content and services requested by you; functionality cookies, i.e. used to activate specific Site features and a number of selected criteria (e.g. language, products selected for purchase) in order to improve the service provided and analytical cookies, including third party cookies, which allow us to understand how you and other users use the Site;
• profiling cookies, including those from third parties, i.e. cookies aimed at creating profiles related to the user and used in order to send you advertisements in line with your preferences expressed while surfing the web;

Profiling cookies are activated and used by the Site only if you give your prior consent for such use. Third party cookies, i.e. cookies from websites or web servers other than store.moncler.com, are also used for purposes specific to these third parties. Further details of the cookies used on the Site are as follows:

How to enable or disable cookies

Browser

You can authorise, block or delete (in whole or in part) cookies through the specific functions of your browser. In the event that some or all of the cookies (technical or functional cookies, even including third party cookies) are disabled, the Site: may not be available; some services or certain functions of the Site might not be available or won't function correctly; you may be forced to modify or manually enter certain information or preferences each time you visit the Site.

For details on how to set preferences for the use of cookies through your browser, please refer to the relevant instructions.
Below are links to settings regarding cookies for the major browsers:

• Internet Explorer: https://support.microsoft.com/help/17442/windows-internet-explorer-delete-manage-cookies
• Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
• Chrome: https://support.google.com/chrome/answer/95647?hl=en&hlrm=en
• Opera: https://www.opera.com/privacy/cookies
• Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac

Cookie Control

You can choose to maintain only technical cookies active, accept or refuse all cookies and manage your preferences in the Cookie Control on your first visit by clicking on the respective buttons located in the banner at the bottom of the homepage.
You can also confirm or modify your consent at a later date by accessing the Cookie Control from the appropriate link found in the footer of the site.

Please remember that:

• since technical, functional and analytical cookies (including those of any third parties) are strictly necessary for the functioning of the Site or to use the content and services requested, it is not possible to disable this type of cookie, as this would compromise the correct functioning of the Site or the use of its content and services;
• not authorising profiling cookies (including those of any third parties) will not affect the operation of the Site.

The choices you make with regard to the Site's cookies will in turn be recorded in a special technical cookie, the characteristics of which are shown in the cookie table. This cookie may, in some circumstances, not work properly. In such cases, we recommend that you delete unwanted cookies and inhibit their use via your browser settings.
Your cookie preferences will need to be reset if you use different devices or browsers to access the Site or delete cookies from your device.

HTML5 Local Storage

Some functionalities of the Site may also use technology that is similar to cookies (particularly HTML5 Local Storage) which stores information in your browser's local storage. To delete the information saved in local storage on your browser at any time, proceed as follows.

You can delete the information in your Local Storage by clicking on "Delete All" which can be reached from the "View All" link found by scrolling down the "Recently Viewed" section. To use your browser, you need to delete your browsing data by following the instructions at the links below, ticking the "Cookies and website data" box.
The procedures for major browsers are as follows:

• Internet explorer: https://support.microsoft.com/en-us/topic/view-and-delete-your-browsing-history-in-internet-explorer-098ffe52-5ac9-a449-c296-c735c32c8678
• Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/view-and-delete-browser-history-in-microsoft-edge-00cf7943-a9e1-975a-a33d-ac10ce454ca4
• Safari: https://support.apple.com/en-gb/HT201265
• Chrome: https://support.google.com/chrome/answer/95589?co=GENIE.Platform%3DAndroid&hl=en
• Firefox: https://support.mozilla.org/en-US/kb/storage

More information

More information and details on the various types of cookies, the way they work and their characteristics can be found on the following site (completely independent and not affiliated) www.AllAboutCookies.org
For general legal information about store.moncler.com and the use of the Site, please see the General Conditions of Use of the Site. For information related to personal data processing by store.moncler.com via the Site, please see the relevant Privacy Policy.

Last updated on March 2021.

4 • Methods of data processing and data storage

Your personal data will be processed both in paper form and using electronic means and always in compliance with the security requirements of applicable legislation, with particular but not exclusive reference to art. 32 of the GDPR. Our security measures include contractual arrangements with any contractor (e.g. service providers) or other party in order to protect the security and confidentiality of your personal data in accordance with the provisions of our Privacy Policy.
Your personal data is stored in compliance with the following terms and criteria:

1. data collected to conclude and execute agreements for the purchase of products on the website: until the administrative and accounting formalities have been completed. Billing information will be retained for ten years from the date of the original invoice;
2. registered user data: this data will be stored for as long as the account is active. Even after the account is closed, we will retain your information if it is necessary to do so in order to comply with legal or regulatory obligations, to protect our rights, to prevent fraud, or to comply with this Privacy Policy;
3. data relating to payment: until such time as the payment has been confirmed and the administrative and accounting formalities relating thereto have been completed, after the expiry of the right of withdrawal and after the deadline for contesting the payment;
4. data collected in connection with the use of Services offered on the Website (e.g. "pick-up in store", "return in store", "click from store", "click and reserve"): such data is stored until the service has been fully performed;
5. data related to user requests to our Customer Service department: relevant data will be retained until your request is resolved;
6. If you have consented to your personal data being processed, the data relating to your purchases will be kept for marketing and profiling purposes for a period of 7 years, after which time the data will be automatically deleted or permanently and irreversibly anonymised.

In any case, for technical reasons, the termination of the processing and the subsequent cancellation or irreversible anonymisation of the related personal data will be final within thirty days of the terms indicated above.
With particular reference to the legal protection of our rights, we hereby specify that we have a retention period of ten years for personal data commencing from the closure of the account, based on the ten-year limitation period referred to in art. 2946 of the Italian Civil Code.

5 • Scope of disclosure

5.1 Internal and external communication of personal data

Personal data is accessible to our duly authorised personnel (e.g., Digital, CRM, Retail, IT personnel) as necessary and is disclosed to third parties in the following cases: (i) when disclosure is required by laws and regulations applicable to legitimate third party recipients, such as authorities and public bodies for their respective institutional purposes, e.g. anti-money laundering legislation, court authorities; (ii) disclosure to third parties in the event of extraordinary transactions (e.g. mergers, acquisitions, sale of business, etc.).
Personal data is also shared with our service providers, e.g. for services of a technical and organisational nature that are necessary for the purposes indicated above, such as independent partners, including associates, shipping companies, marketing, payment management, etc.. We provide such parties only with the data necessary to perform the agreed services and they act as data processors, based on instructions received from Moncler or YNAP (depending on the relevant data controller).
It is expressly stated that Moncler and YNAP do not disclose your personal data to third parties for marketing or profiling purposes.
Finally, for the purposes of profiling, marketing and customer relationship management (to provide you with the same level of service worldwide), other companies in the Moncler Group may access your personal data as data processors, based on instructions received from Moncler.

5.2 Data transfer abroad

Your personal data may be transferred outside of Italy to third party recipients established within the European Union. This is a free transfer as each EU country guarantees an adequate level of data protection. However, for the purposes indicated above, we may also transfer your data to third party countries, not belonging to the European Union, which do not guarantee the same level of data protection. However, you are advised that such transfer to third party countries will always be in accordance with the provisions of the Privacy Policy, i.e. by obtaining your consent, when necessary, or by adopting any other measure necessary to ensure the security of the data being transferred. These measures include possible contractual agreements based on the standard contractual clauses as drafted by the European Commission.

6 • Rights of the data subject

As a data subject, you may at any time exercise the rights acknowledged by the Privacy Policy with regard to the specific processing of your personal data.
Below is a general description of them and how to exercise them:

1. right of access to your personal data: you can obtain confirmation that your personal data is or is not being processed and, consequently, obtain access to your personal data and information about its processing. If you wish, you will be provided with a copy of your personal data;
2. right to rectification of your personal data: you can obtain the correction, modification or updating of any inaccurate or out-of-date information, as well as obtaining the supplementation of incomplete personal data, including by providing an additional statement;
3. right to withdraw your consent: you may at any time withdraw your consent to the processing of your personal data in connection with any activity for marketing purposes, including profiling. In this regard, please note that sending commercial and promotional communications, carrying out market research and surveys to measure satisfaction and tailoring commercial offers to your interests are considered marketing activities. On receipt of your request, the processing of your personal data based on such consent will cease, while different processing operations or processing based on other grounds will continue to be carried out in full compliance with applicable laws;
4. right to the deletion of your personal data (right to be forgotten) when your personal data, in particular, (i) is no longer necessary for the purposes for which it was collected or processed, or (ii) has been processed unlawfully, or (iii) must be deleted in order to comply with a legal obligation, or, lastly, (iv) you have objected to its processing (see "right of objection" below) and there is no overriding legitimate reason that would allow YNAP or Moncler to process your personal data in any way. Once we have received and reviewed your request, if it is lawful, your personal data will be deleted;
5. right to limit the processing of your personal data: you may request that the processing of your data be limited, i.e. that your personal data be stored but not used ( with the exception of your requests and exceptions provided for by law):
   • when you challenge the accuracy of your personal data for the period necessary for YNAP or Moncler to verify the accuracy of such data;
   • when the processing is unlawful, but you object to the deletion of your data;
   • when, although your data is no longer needed by YNAP or Moncler for processing purposes, you need it to ascertain, exercise or defend your rights in legal proceedings;
   • when you object to the processing, pending verification of whether YNAP or Moncler have legitimate grounds to continue processing the data;
6. right to data portability: you may request to receive data that is processed based on your consent or on a contract entered into with you, in a structured format and readable by an automated device. If you wish, where this is not excessive and technically possible, we may, at your request, transfer your data directly to a third party indicated by you.
7. right of objection: you may at any time object to the processing of your personal data carried out based on a legitimate interest, explaining the reasons supporting your request. Unless there are reasons to prevent acceptance of the same as provided by law, we will cease the processing to which you have objected. You have the right to object at any time to the processing of your data for marketing and/or profiling purposes, as long as it is related to that purpose, without the need to specify the reason for your objection. In this case, the processing of your data will cease immediately.

To exercise the rights described above, you can:

• call the freephone number 00 800 10204000 from Monday to Friday from 10 a.m. to 7 p.m., excluding public holidays; or
• write to Customer Services by selecting the "privacy" topic in the relevant form in the "Contact us" section of the Website; or
• contact YNAP and Moncler directly at the addresses indicated in paragraph 2 above.

To ensure that the data of users of the Website is not compromised or misused by third parties, prior to accepting your request to exercise any of the rights listed above, you may be asked to provide certain information to confirm your identity.

7 • Complaints

If you believe that your personal data have not been processed fairly, you may lodge a complaint with the competent supervisory authority in the Member State of the European Union where you normally reside, work or where the alleged breach occurred.
In Italy, complaints may be filed with the Garante per la Protezione dei Dati Personali, for further information please see www.garanteprivacy.it.
For contact details of all the other competent European supervisory authorities, please see https://edpb.europa.eu/about-edpb/board/members_en.