Privacy Policy Sections CCPA AND TDPSA

Legal

YOUR CALIFORNIA PRIVACY RIGHTS

This section of the privacy policy applies solely to California residents.

We adopt this Section of the privacy policy in order to comply with the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act of 2020 (“CPRA”).

Please note that certain terms used in this California-specific section of the privacy policy, such as “Personal Information,” “Sale,” “Share” and “Sensitive Personal Information” have the meanings given to such terms in the CCPA/CPRA, and not the common meanings of these terms in conversational English.

California Residents

California Civil Code Section § 1798.83, known as the “Shine The Light” law, permits users of our Website who are California residents to request and obtain from us a list of what Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding year, and the names and addresses of those third parties. You may request this information from us no more than once a year, but such request will be handled by us free of charge to you. To make such a request, please send an email to privacy@ferragamo.com.

Data Collection

We have collected the following categories of Personal Information for the following purposes within the last twelve (12) months:

Category of Personal Information	Categories of Sources of Collection	Business or Commercial Purpose for Collection
A. Identifiers, including: name, email address, phone number, postal address, IP address, and—for employees and job applicants—Social Security number and driver’s license number.	Business partners, including retailers and distributors Our service providers Employees/job applicants/independent contractors Website users Customers	To provide our products and services and manage our business To improve our products and services To identify potential customers To market our products and services To offer employment, to provide insurance and benefits, for background checks
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), including: name, email address, phone number, postal address, IP address, credit card number, and —for employees and job applicants—Social Security number and driver’s license number.	Business partners, including retailers and distributors Our service providers Employees/job applicants/independent contractors Website users Customers	To provide our products and services and manage our business To improve our products and services To identify potential customers To market our products and services To offer employment, to provide insurance and benefits, for background checks
C. Protected classification characteristics under California or federal law, including age, marital status, citizenship, immigration status, and gender.	Employees	To offer employment, to provide insurance and benefits, for background checks
D. Commercial information, including records of products purchased or considered.	Customers Prospective customers Business partners, including retailers and distributors	To provide our products and services and manage our business To market our products and services To improve our products and services For research and development To maintain business relationship with partners
E. Biometric information.	None	None
F. Internet or other similar network activity, including: browsing history, search history, information on a user’s interaction with the Website or advertisements, and IP address.	Customers Website users	To provide our products and services and manage our business To market our products and services To improve our products and services (e.g., usage pattern data) To drive sales
G. Geolocation data.	Customers Prospective customers Website users	To provide our products and services and manage our business For fraud prevention purposes
H. Sensory data.	None	None
I. Professional or employment-related information, including —for employees and job applicants—current or past job history.	Employees Job applicants	To provide employment opportunities, and administer employee benefits
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)), including —for employees and job applicants—educational records, grades, and transcripts.	Employees Job applicants	To provide employment opportunities, and administer employee benefits
K. Inferences drawn from other Personal Information, including: product preferences and purchasing trends.	From Website activity	To provide our products and services and manage our business To market our products and services To improve our products and services For research and development
L. Sensitive Personal Information, including: customer’s login credentials; and —for employees and job applicants—Social Security number, driver’s license number, citizenship, and immigration status.	Customers Employees Job applicants	To provide employment opportunities, to process payroll, to administer employee benefits, for background checks To manage and improve our diversity efforts To make our Website available and offer our products and services To process orders

We do not knowingly collect any Personal Information of persons under the age of 16.

We allow our service providers, including the following vendors, to control the collection of Personal Information as part of the analytics and other services they provide to us. These third parties may use such Personal Information for their own purposes, and we do not control this. Please visit these third parties’ privacy policies to learn more about their data processing practices:

Google
CS
SaleCycle Limited
Akamai
Riskified Ltd.
Inside That Matters

California Consumer Rights Pursuant to the CCPA/CPRA

Except where any such disclosures would require us to reveal a trade secret, as a California consumer, you have specific rights regarding how your Personal Information is collected and used.

You have the right to request that we disclose to you or your authorized agent acting on your behalf the following information covering the past twelve (12) months:
- Specific pieces of Personal Information that we have collected;
- Categories of Personal Information collected;
- Categories of sources from which Personal Information is collected;
- Categories of Personal Information Sold (as this term is defined in the CCPA/CPRA), Shared for cross context behavioral advertising, or disclosed for a business purpose;
- Categories of third parties to whom we Sold, or with whom we Shared or disclosed the Personal Information for a business purpose;
- Our business purpose for collecting (or Selling or Sharing) Personal Information;
- The categories of Sensitive Personal Information to be collected and the purposes for which the categories of Sensitive Personal Information are collected or used and whether such information is Sold or Shared, except for such information that is collected or processed without the purpose of inferring characteristics about you.
You have the right to request correction of any inaccurate Personal Information that we maintain about you;
You have the right to request deletion of your Personal Information (with exceptions noted by law – more on this below);
You have the right to request that your Personal Information not be Sold to or Shared with third parties;
You have the right not to be discriminated or retaliated against because you exercised these rights; and
You have the right to request that we limit our use and disclosure of your Sensitive Personal Information, such that we use such information solely to provide you our services or process your transactions.

Data Deletion

As permitted by the CCPA/CPRA, in the event you request deletion of Personal Information that we have collected about you, we, our service providers, and our contractors may be unable to comply with such a request if your Personal Information is necessary to:

Complete the transaction for which the Personal Information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you;
Prevent, detect, and investigate security incidents, protect against malicious deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
Debug to identify and repair errors that impair existing intended functionality;
Exercise free speech, ensure the right of another Consumer to exercise his or her right of free speech, or exercise another right provided for by law;
Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with section 1546) of Title 12 of Part 2 of the Penal Code;
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of that information is likely to render impossible or seriously impair the achievement to such research, if you have provided informed consent;
Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
Comply with a legal obligation; or
Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Non-Discrimination

We will not discriminate against you or retaliate for exercising any of your CCPA/CPRA rights. Specifically, we will not do any of the following unless permitted by the CCPA/CPRA:

Deny you goods or services;
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
Provide you a different level or quality of goods or services;
Engage in any retaliatory employment practices; or
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA/CPRA that can result in different prices, rates, or quality levels. Any CCPA/CPRA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Do Not Sell or Share My Personal Information

We Sell Personal Information (as the term “Sale” is defined pursuant to the CCPA/CPRA), but not in exchange for monetary compensation. We do not Share Personal Information (as the term “Share” is defined pursuant to the CCPA/CPRA) for cross context behavioral advertising purposes.

As a California consumer, you have the right to opt out of the Sale or Sharing of your Personal Information to third parties.

In the twelve (12) months prior to the posting of this Policy, we have Sold to or Shared with third parties the categories of Personal Information about California residents set forth below, and for the purposes set forth below:

Categories of Personal Information Sold or Shared	Categories of Third Party to Which Personal Information Was Sold	Reason for Selling	Categories of Third Party with Whom Personal Information Was Shared	Reason for Sharing
A. Identifiers, including: name, postal address, phone number, IP address, email address, account name.	Our service providers, including: cookies and analytics; marketing agencies, and shipping/delivery vendors	To market our products and services To understand our audiences To improve our products and services For research and development To ship and deliver our products	None	N/A
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), including: name, postal address, phone number, IP address, email address, account name.	Our service providers, including: cookies and analytics; marketing agencies, and shipping/delivery vendors	To market our products and services To understand our audiences To improve our products and services For research and development To ship and deliver our products	None	N/A
C. Protected classification characteristics under California or federal law.	None	N/A	None	N/A
D. Commercial information, including products purchased, obtained, or considered.	Our service providers, including: cookies and analytics; marketing agencies, and shipping/delivery vendors	To market our products and services To understand our audiences To improve our products and services For research and development To ship and deliver our products	None	N/A
E. Biometric information.	None	N/A	None	N/A
F. Internet or other similar network activity, including: browsing history, search history, information on a user’s interaction with the Website or advertisements, and IP address.	Our service providers (including cookies and analytics)	To market our products and services To understand our audiences To improve our products and services For research and development	None	N/A
G. Geolocation data.	Our service providers (including cookies and analytics)	To market our products and services To understand our audiences To improve our products and services For research and development	None	N/A
H. Sensory data.	None	N/A	None	N/A
I. Professional or employment-related information	None	N/A	None	N/A
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	None	N/A	None	N/A
K. Inferences drawn from other Personal Information, including: product preferences and purchasing trends.	Our service providers (including cookies and analytics) Our marketing agencies and service providers	To market our products and services To understand our audiences To improve our products and services For research and development	None	N/A
L. Sensitive Personal Information.	None	N/A	None	N/A

We do not knowingly Sell or Share any Personal Information of children under the age of 16.

Data Disclosure

In the twelve (12) months prior to the posting of this Policy, we have disclosed for a business purpose the categories of Personal Information about California residents set forth below, for the reasons set forth below:

Category of Personal Information Disclosed for a Business Purpose	Category of Persons to Whom Personal Information Was Disclosed	Purpose for Disclosing for a Business Purpose
A. Identifiers, including: name, email address, phone number, postal address, IP address, and —for employees and job applicants—Social Security number and driver’s license number.	Our affiliates and subsidiaries Our service providers (including cookies and analytics) Our marketing agencies and service providers Business partners, including retailers and distributors Our insurance providers Our media partners	To provide our products and services and manage our business To improve our products and services To market our products and services To provide insurance and benefits, for background checks To manage our business To understand our audiences For research and development
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), including: name, email address, phone number, postal address, IP address, credit card number, and—for employees and job applicants—Social Security number and driver’s license number.	Our affiliates and subsidiaries Our service providers (including cookies and analytics) Our marketing agencies and service providers Business partners, including retailers and distributors Our insurance providers Our media partners	To provide our products and services and manage our business To improve our products and services To market our products and services To provide insurance and benefits, for background checks To manage our business To understand our audiences For research and development
C. Protected classification characteristics under California or federal law, including: including age, marital status, citizenship, immigration status, and gender.	Our service providers	To provide insurance and benefits, for background checks
D. Commercial information, including products purchased, obtained, or considered.	Our affiliates and subsidiaries Business partners, including retailers and distributors Our service providers (including cookies and analytics) Our marketing agencies Our media partners	To provide our products and services and manage our business To market our products and services To improve our products and services For research and development To maintain business relationship with partners To manage our business To understand our audiences
E. Biometric information.	None	None
F. Internet or other similar network activity including: browsing history, search history, information on a user’s interaction with the Website or advertisements, and IP address.	Our service providers (including cookies and analytics) Our marketing agencies Our media partners	To provide our products and services and manage our business To market our products and services To improve our products and services (e.g., usage pattern data) To drive sales To understand our audiences For research and development
G. Geolocation data.	Our service providers (including cookies and analytics)	To provide our products and services and manage our business For fraud prevention purposes To market our products and services To understand our audiences To improve our products and services For research and development
H. Sensory data.	None	None
I. Professional or employment-related information, including: —for employees and job applicants—current or past job history.	Our service providers	To administer employee benefits
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)), including: —for employees and job applicants—educational records, grades, and transcripts.	Our service providers	To administer employee benefits
K. Inferences drawn from other Personal Information, including: product preferences and purchasing trends.	Our affiliates and subsidiaries Our service providers (including cookies and analytics) Our marketing agencies Our media partners	To provide our products and services and manage our business To market our products and services To improve our products and services For research and development To understand our audiences
L. Sensitive Personal Information, including: customer’s login credentials and —for employees and job applicants—Social Security number, driver’s license number, citizenship, and immigration status.	Our service providers	To process payroll, and administer employee benefits To manage customer accounts and process orders

Sensitive Personal Information

As a part of our services, we may collect Sensitive Personal Information, as set forth above, and use it or disclose it for the purposes described above. You have the right to request that we limit our use and disclosure of your Sensitive Personal Information such that we use such information solely to provide you our services or process your transactions. To exercise this right, please contact us at privacy@ferragamo.com.

Data Retention

We store Personal Information as needed to accomplish the purposes identified in this privacy policy (e.g., to make our Website available, interact with you, provide products/services you request from us, manage your membership in our programs, provide you with access to our newsletter, etc.) and to meet legal requirements, including to comply with law, and for record retention, resolving disputes, and enforcing our agreements. We will not retain a consumer’s Personal Information or Sensitive Personal Information for longer than is reasonably necessary for the purposes disclosed above. Our retention of your Personal Information is governed by applicable law. This storage period may extend beyond the term of your relationship with us. For example: the chat history generated during your use of any “live chat” feature on our Website is retained for twelve (12) months after the generation of the message; data relating to your job applications or employment with us may be retained for up to seventy-two (72) months; data relating to purchases and surveys may be retained for up to seven (7) years; and any information provided through opt-in consent shall be retained until you object to such purpose or withdraw consent.

When we no longer need Personal Information, or in any event, after legal authority to retain it has expired, we will destroy Personal Information in accordance with local law and pursuant to our relevant procedures.

To the extent you interact with our service providers or other third-parties (e.g., social media platforms) in connection with us, such third-parties may retain your data in accordance with their own retention policies.

For more information on our data retention periods, you may contact us at privacy@ferragamo.com.

How to Exercise Your CCPA/CPRA Rights

You can exercise all of your rights granted to you pursuant to the CCPA/CPRA by clicking here or contacting us at 1-866-337-7242 or privacy@ferragamo.com.

California law requires us to verify your identity before processing your request. In order to make a request pursuant to the CCPA/CPRA, you must provide us with your: first and last name, email address associated with your account with us, and a transaction number and order details for a recent purchase that you made from us (if applicable). If you are requesting specific pieces of Personal Information that we have collected about you, you will also be required to email us at privacy@ferragamo.com a signed declaration under penalty of perjury that you are a California resident and that you are the consumer whose Personal Information is the subject of the request. Note that we will not process your request to disclose specific pieces of information we have about you until we receive this signed declaration, and your request will not be considered timely submitted until we have this document in our possession.

We will review the information you have provided against the information in our databases, and attempt to verify your identity. However, please note that under certain circumstances, we may require you to provide additional information in order to allow us to confirm your identity and your residency before we can process your requests. Also note that you are only entitled to make a Personal Information request up to twice in a 12-month period.

If you submit your CCPA/CPRA request by email, please include “California Privacy Rights” as the subject line. If you make a request to exercise your rights under the CCPA/CPRA by telephone, we may ask you to provide the request in writing so that we may verify your identity.

We will acknowledge your request within 10 days and respond to your request within 45 days or let you know if we need additional time or information to verify your identity (and if so, why).

Using an Authorized Agent

A California resident may use an authorized agent to submit a right to know request, a request to delete, a request to correct, a request for us to limit our processing of Sensitive Personal Information by contacting us at privacy@ferragamo.com, or a request to opt-out of the Sale or Sharing of Personal Information by clicking here. To use an authorized agent for these purposes, both the California resident and their agent will be required to verify their identities with us. For this purpose, the agent will be required to submit a request with their first and last name and email address, and the following information about the consumer on whose behalf they are making the request: first and last name, email address associated with their account with us, and a transaction number and order details for a recent purchase that they made from us (if applicable). In addition, the agent will be required to provide via email written authorization from the consumer to act on their behalf in making these requests. If we cannot authenticate the identity of the agent making the request, we may also require that the consumer confirm directly with us that they have in fact authorized their agent to act on their behalf. We may deny a request from an agent who cannot meet these requirements. If the agent has provided us with a validly executed power of attorney pursuant to Cal. Prob. Code Sections 4121 to 4130, then a separate verification that the consumer has authorized the agent to act on their behalf will not be necessary.

YOUR TEXAS PRIVACY RIGHTS

This section of the privacy policy applies solely to Texas residents.

We adopt this section of the privacy policy in order to comply with the Texas Data Privacy and Security Act (“TDPSA”).

The terms “biometric data”, “consumer”, “personal data”, “process”, “profiling”, “sale of personal data” (hereinafter “sale”), “sensitive data”, “targeted advertising”, and “third parties” used in this Texas-specific section of the privacy policy shall have the meanings ascribed to them in the TDPSA.

Below, please find a chart containing information about what categories of personal data of Texas consumers we process (including, if applicable, any sensitive data), the purpose for such processing, the categories of personal data that we share with third parties, and the categories of third parties with which we share personal data.

Categories Of Personal Data We Process	Purpose For Processing	Shared With Third Parties? (Yes/No)	Categories Of Third Parties With Which Personal Data Is Shared
Identifiers	To provide our products and services and manage our business To improve our products and services To identify potential customers To market our products and services	Yes	Our service providers (including cookies and analytics) Our marketing agencies and service providers Business partners, including retailers, distributors, and media partners
Sensitive Data	None	N/A	N/A
Financial Data	To provide our products and services and manage our business To process orders	Yes	Our service providers (including payment processors)
Commercial data	To provide our products and services and manage our business To market our products and services To improve our products and services For research and development	Yes	Business partners, including retailers, distributors, and media partners Our service providers (including cookies and analytics) Our marketing agencies
Internet or other electronic network activity data	To provide our products and services and manage our business To market our products and services To improve our products and services (e.g., usage pattern data) To drive sales	Yes	Our service providers (including cookies and analytics) Our marketing agencies Our media partners
Educational data	None	N/A	N/A
Employment data	None	N/A	N/A

Sale of Personal Data

We Sell Personal Information (as the term “Sale” is defined pursuant to TDPSA), but not in exchange for monetary compensation. You may exercise your rights as a Texas resident to opt-out of such sales, as described below.

We may process your personal data to predict your preferences or interests and advertise to you based on your activities on our Website; however, we do not engage in Targeted Advertising (as the term is defined pursuant to TDPSA).

Texas Residents’ Rights with Respect to Personal Data

Except where any such disclosures would require us to reveal a trade secret, Texas residents have the right to:

Confirm whether we process your personal data;
Access your personal data;
Correct inaccuracies in the personal data that we hold about you;
Request that we delete the personal data that we hold about you;
If the data is available in a digital format, obtain a copy of the personal data you provided to us in a reasonably portable format and, to the extent technically feasible, readily usable format that allows you to transmit the data;
Opt-out of our processing of your personal data for targeted advertising;
Opt-out of our sale of your personal data; and
Opt-out of our processing of your personal data for profiling in furtherance of a decision that produces a legal or similarly significant effect on you.
Non-discrimination for exercising any of these rights.

The foregoing requests may be exercised on behalf of a Texas resident by a parent or guardian of a child under the age of 13.

You may also designate an authorized agent to exercise your rights to opt out of the processing of your personal data for targeting advertising, sale of your personal data and profiling as described above, to the extent we engage in any of the foregoing activities.

To exercise your rights, you may contact us at 1-866-337-7242 or privacy@ferragamo.com.

Timing for Response

We will generally respond to your requests to exercise your rights no later than 45 days after receiving your request. However, there may be times when we may extend this period for up to an additional 45 days as permitted by law. If we do so, we will notify you of this extension within the initial 45 day period, and provide you an explanation as to why the extension of time is necessary.

We may also decline to take action on your request pursuant to applicable law. If your request is declined, you may appeal our decision by contacting us through the same methods that we offer for submitting a request.

If we do not comply with your request, and you disagree with our reasons after you appeal the decision, you may contact the Texas Attorney General and file a complaint by clicking here.