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PRIVACY STATEMENT

Prada S.p.A., with its registered office in Milan (Italy), the operating holding company of the PRADA Group (defined below) and site manager of www.bbfreebies.com, together with its subsidiary, PRADA USA Corp., with its registered office in New York (USA), (collectively, “PRADA”) is committed to protecting the Personal Data (defined below) that you share with us, and explaining how we collect, process, and share that information online. ?We collect your Personal Data on the Website (defined below) to enhance the services we offer you, maintain and improve the Website, protect the security of you and our Website, comply with legal obligations, and inform you about other services and products that may be available through us, our affiliated companies, and our marketing partners.?

1.???? Scope and information that this Privacy Statement covers and how we use and share it
This Privacy Statement applies to Personal Data collected on our websites, mobile applications, cloud-based services, or controlled widgets embedded in communication platforms, each with a link to this Privacy Statement (collectively, the “Website”). ?It covers how we collect, use, share, and otherwise process personal information as of the date that this Privacy Statement is posted. ?This Privacy Statement also applies to the Personal Information collected in stores operated by PRADA USA as well as Prada S.p.A and its subsidiaries and/or affiliates (collectively the “PRADA Group”). ?It does not apply to any other information collected by PRADA through any other means. ?By “Personal Data,” we mean information that identifies or can identify you personally.? By using this Website or voluntarily providing personal information to us, you consent to the terms of this Privacy Statement.? If you do not agree to the policy, please do not use the Website.
The Website may contains links to third-party websites, including websites of our business partners.? We do not own, operate or control the websites of those third-parties. Accordingly, this Privacy Statement does not apply to any websites maintained or operated by third-parties for the collection, use, storage, disclosure, or other processing of your Personal Information.? When you click on those links, you will go to a third-party website where you will be subject to that website’s privacy statement and we encourage you to read that policy statement.

Personal Data we may collect and purposes
The tables below explain the categories of information we may collect and purposes for which we may use them as well as, with respect to the California Consumer Privacy Act, the information we may have collected for the 12-month period prior to the date of this Privacy Statement, where we got it from and why it is needed. Further detail about each of the purposes is set out in the “Additional Information on Purposes of Use” below.

Categories of Personal Data Purposes for collection and use
Information you provide to us in the course of using or processing online services:
Identification and contact information: such as your name and surname, title, day and month of birth, location, User id (email address), password, postal address, email address, telephone numbers, or other contact details information you may provide to us To register to our Website and manage your online account profile;
to subscribe to our newsletter service;
to book an appointment or the service pick-up products at a PRADA Group store;
to send a request to/contact our Client Services;
to confirm your identity as registered member;
to inform you about other services and products that may be available through us, our affiliated companies, and our marketing partners;
to provide and deliver products and services requested;
to send you information related to products and services, including catalogs, invoices, technical notices, updates, security alerts, and support and administrative messages;
to communicate with you about new contests, promotions and rewards, upcoming events, and other news;
to respond to all your requests, to manage your relationship with the PRADA Group; and
to manage and administer our community features and member programs and services.
Purchase and order information: contact information, billing address, shipping address, together with purchase details (products, color, size, quantity, price), methods of payment and/or any communications we have received about your order or purchase To place your online orders;
to perform all management activities connected with your order, including administrative management of the contract, delivery of goods, payment processing, management of any claims and litigation, and fraud prevention, and to validate, confirm, verify, deliver, install, and track your order, including to arrange for shipping, handle returns and refunds, maintain a record of the purchases you make; to service products you purchased from us; and to provide you offers that may be of interest to you
Payment information: name, card issuer and card type, credit or debit card number, expiration date, CVV code and/or billing address To check that the right person is using the right card or account;
To meet the requirements of the card brands or account issuers; and
to make sure we are paid for what you buy
Information you provide about a third party: name, surname, address and contact details of recipient for delivery goods or services (such as sending a gift or virtual gift card), if different from yours To deliver to or communicate with the person at the address which you have requested.
Preference information: your account settings including preferred store, your wishlist, contact channel and types of services/offers that interest you To personalize your experience and to enhance the services we offer you
Other voluntary information: Other voluntary information: any voluntary information you may provide us with in the course of your interactions with us (such as by sending an e-mail through our Website and/or to the addresses indicated in our Website or by calling our Client Service or by responding to surveys or competitions) To handle your requests, and to contact you when necessary or requested, including to respond to your comments and questions and provide customer service; and
to know you better, make our communications with you more personal, learn and improve from your survey feedback, organize events, and/or pick competition winners.
Please note that we may record calls to our Client Service for quality assurance and internal training purposes
Information we may collect automatically from you and/or your device:
Device information: IP address, internet provider, operating system and browser used, domain names of the computers you use to visit our Website,? type of device, such as laptop or smart phone, log files, 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, and/or device cookie settings and other device details, such as MAC address and geolocation, if you permit it to obtain your precise geolocation To obtain anonymous statistical information on the use of our Website and to guarantee its correct operation, to make sure our Website works properly with your device and make sure you can see and use our intended website on the device you are using, and for analytical and demographic purposes and to provide offers that may be of interest to you.
We also will use this information to protect the security or integrity of the Website and our business, such as by protecting against and preventing fraud, unauthorized transactions, and managing risk exposure, including by identifying potential hackers and other unauthorized users.
Information automatically collected from your browser: when you use the Website, some data is automatically transferred from your browser to our server, including your browser type, operating system type or mobile device model, viewed webpages, links that are clicked, IP address, mobile device identifier or other unique identifier, sites or apps visited before coming to our Website, the amount of time you spend viewing or using the Website, the number of times you return, or other click-stream or site usage data, and emails we send that you open, forward, or click through to our Website

We will use this information in an aggregated non-specific format for analytical and demographic purposes.
To protect the security or integrity of the Website and our business, such as by protecting against and preventing fraud, unauthorized transactions, and managing risk exposure, including by identifying potential hackers and other unauthorized users

Information we may collect from third parties
Legal information: fraud checks or flags raised about your transactions, payment card refusals, suspected crimes, complaints and/or claims To protect you, other customers and our business against criminal activities and risks, and to make sure we understand and can meet our legal obligations to you and others and can defend ourselves
Social Media Information: if you interact with us through social media service or log in using social media credentials, depending on your social media settings, we may have access to your information from that social network such as your name, email address, age, gender, location To allow you to register to our Website through social login
to personalize your experience and to enhance the services we offer you
Information we mat collect offline at store
Identification and contact information: such as your name and surname, title, day and month of birth, location, postal address, email address, telephone numbers, or other contact details information you may provide to us To register into PRADA Group customer database by signing our Customer Card to be provided with exclusive services and benefits reserved to register member;
to inform you about other services and products that may be available through us, our affiliated companies, and our marketing partners;
to confirm your identity as registered member;
to send you information related to products and services, including catalogs, invoices, technical notices, updates, security alerts, and support and administrative messages;
to communicate with you about new contests, promotions and rewards, upcoming events, and other news;
to respond to all your requests, to manage your relationship with the PRADA Group; and
to manage and administer our community features and member programs and services

Additional Information on Purposes of Use

Registration to PRADA Group Customer Database
If you register to the PRADA Group customer database (as a result of your registration to the Website or your signing 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 stores globally, and may be processed, together with the details of your purchases online and/or in stores, for the following purposes:

(1) to confirm your identity as a registered PRADA Group customer and, consequently, to provide a customized global customer service and post-sales 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.);
(2) to perform individual or group studies, statistical and/or market research on your preferences for PRADA and the other brands, products and services of the PRADA Group, so that a personalized service can be offered and cultural and recreational activities may be promoted based on customers’ interests; and/or
(3) to contact you and/or send you (by post, telephone, e-mail and any other form of electronic communication or digital means including social network platforms and other instant messaging applications) information and promotions, including commercial information, newsletters, direct marketing material, advertising, catalogues and invitations to events concerning PRADA and other brands, products and services of the PRADA Group.

For the purpose referred to point (1) the Personal Data processing is necessary to provide you with the service requested. The data procession referred to points (2) and (3) is based on your prior consent.

2.???? Cookies
Our Website uses cookies, including third-party cookies, to ensure its efficient functioning and to improve our services, offer you a better experience and send our online advertising messages in line with your preferences.
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 recognized by those websites on your subsequent visits. ?For more information on cookies, on the types of cookies used on our Website, and on how to disable them or withhold your consent to their use, see our cookie policy.

3.???? Controlling Our Tracking Tools?
Your browser may give you the ability to control cookies. How you do so, however, depends on your browser and the type of cookie.? Certain browsers or browser plugins can be set to reject all browser cookies.? If you configure your computer to block all cookies, you may disrupt certain web page features, and limit the functionality we can provide when you visit or use our Website. ?(e.g., we will not be able to provide you with searches that you have asked us to save). ?You can change your cookie settings at any time.? Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked.? These browser features are still not uniform, so we are not currently set up to respond to those signals.

4.???? Controlling Online Interest-Based Ads.
We sometimes work with online advertising vendors to provide you with relevant and useful ads.? This may include ads served on or through our Website.? This may also include ads served on other companies’ websites.? These ads may be based on information collected by us or third parties.? For example, your postal code may be used to target an ad for people in your area.? These ads may also be based on your activities on our Website or on third-party websites.
For more information about our ad service provider and its cookies, including information about how to opt out of these technologies, you may visit http://optout.aboutads.info? In addition, users may prevent Google’s collection of data generated by your use of the Website (including your IP address) by downloading and installing a Browser Plugin available at https://tools.google.com/dlpage/gaoptout?hl=en.

5.???? Personal Data of minors
You must be at least 16 years old (depending on the state of residence) in order to provide us with Personal Data, and at least 18 years old to purchase products from our Website.

Under Age 13
PRADA complies with the Children’s Online Privacy Protection Act of 1998, which prohibits collecting personal information from children under the age of 13 without verifiable parental consent.? If it comes to our attention that we have unknowingly collected information from a child under the age of 13, we will take all reasonable measures to delete it as soon as possible and will not use such information for any purpose (except where necessary to protect the safety of the child or others as required or allowed by law).? If you become aware of any personally identifiable information we have collected from children under 13, please call us at 1-877-997-7232 or email us at privacy@prada.com

Under Age 18
Minors under 18 years of age may have the personal information that they provide to us deleted by sending an email to privacy@prada.com requesting deletion.? Please note that, while we make reasonable efforts to comply with such requests, deletion of your personal information does not ensure complete and comprehensive removal of that data from all systems.

6.???? Security of Your Personal Information
Your Personal Data will be processed by suitable electronic or automated means and computerized tools, or manually and on hard copy, exclusively for the purposes for which they have been collected and according to criteria of lawfulness and correctness and protecting the security and confidentiality of Personal Data through the adoption of appropriate measures to prevent loss, ?alteration, cancellation, destruction, unauthorized access or not allowed processing or not in accordance with the purpose of collection. ?Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.? In this regard, we urge you to take every precaution to protect your Personal Data while you are on the Internet.? At a minimum, we encourage you to make sure that you are using a secure browser as you surf the Internet.
Your Personal Data will be processed by the PRADA Group’s internal staff who are duly authorized to do so in accordance with their respective job duties. ?Your Personal Data may also be processed by third parties to the extent necessary and/or instrumental for the above purposes. ?These third parties will act on behalf of PRADA as data processors and are under a contractual obligation of confidentiality in respect of the relevant personal information.

7.???? Transfer and disclosure of data
Whenever necessary and/or instrumental to the above-mentioned purposes, your Personal Data may be processed on behalf of PRADA by other entities acting as data processor, including:

  • Related Companies: PRADA Group companies and franchisees that operate PRADA Group stores;
  • Service Providers: third party service providers, consultants, or firms ?engaged by PRADA to perform business purposes including website analytic services, hosting, transaction and payment processing, promotional campaign management, fraud prevention, shipping of goods, IT maintenance, etc.

As PRADA is part of an international network, your Personal Data may be transferred abroad in accordance with applicable legislation, including to countries outside the United States and the European Union, where PRADA pursues its interests, by adopting all appropriate security measures and safeguards to ensure an appropriate level of data protection and security.
Your Personal Data will not be used for third-party advertising purposes or for the promotion of products, services or initiatives by entities other than the PRADA Group, nor shall they be disclosed to unknown persons under any circumstances.

Communication of data to the other PRADA Group companies
Please also note that if you register on the PRADA Group customers database, your Personal Data will be automatically visible to, and shared with, all PRADA Group stores globally to provide you with the same level of service around the world. ?PRADA will take all appropriate security and confidentiality measures as required by applicable legislation to ensure an adequate standard of data protection.

In Connection with Business Transfers
In the event that a division or part or all of PRADA is bought, sold or otherwise transferred, or is in the process of a potential transaction, customer information will likely be shared for evaluation purposes and included among the transferred business assets.

To Comply with Laws
PRADA may also disclose specific information when such disclosure appears necessary to comply with the law, a subpoena or other litigation process or to protect the interests or safety of its visitors and customers, PRADA employees or others.

8.???? Retention period
Your Personal Data will be processed and stored for:? (a) as long as required to carry out the purposes for which the Personal Data were collected; (b) in accordance with the storage periods required by applicable laws; or (c) until you revoke your consent to the processing/storage of your Personal Data, if applicable.? After the conclusion of such period(s), 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.???? Your Rights
Please note that you may exercise the rights under the applicable privacy laws including the right to request information as to whether your Personal Data is being processed and as to the characteristics of the processing, the right to rectification and erasure of your Personal Data, and/or the right to have such Personal Data transmitted to another controller.
You also have the right to withdraw your consent for the collection and processing of your Personal Data by PRADA at any time, without charge. The withdrawal of your consent will not affect the lawfulness of processing based on your consent before its withdrawal.

If you have any requests regarding your Personal Data, have any inquiries regarding this Privacy Statement, or you would like to exercise your rights or receive any information about your rights, please contact (free of charge) the Data Controller or the Group Data Protection Officer (“DPO”) by writing to the addresses/email addresses listed above.

10.? Your California Privacy Rights (California residents only)
If you are a California resident, you may request information about our disclosure of personal information to third parties or affiliated companies for their direct marketing purposes.? To make such a request, please contact us as set forth below.? Please allow up to 30 days for us to process your request.? You may submit such a request once per year.
If you are a California resident, California law also provides you with the following rights with respect to your personal information:

When you exercise these rights and submit a request to us, we will verify your identity by asking you to provide us with additional information such us your email address, order numbers of previous orders of our products and services, or the last four digits of a credit or debit card used to make a purchase.? We also may use a third party verification provider to verify your identity.

Your exercise of these rights will have no adverse effect on the price and quality of our goods or services.

In addition and as set forth below, California law requires us to identify, for the 12-month period prior to the date of this Privacy Policy, what information we may have “sold” about you.? Please be assured that this does not mean that PRADA has received money in exchange for your personal information.? Instead, there are instances where PRADA has shared the following information about you, collected through cookies, in order to provide you with personalized services:?

  • Internet and other electronic network activity information, including browsing history, search history, areas of our Website that you visit and information regarding your interaction with the Website or any advertisements we display.
  • Device identifiers, including your Internet Protocol address, online identifier and location.
  • Your preferences and interests based on information collected when you browse our Website.

11.? Data controllers and Contacts
If you have any questions about this Privacy Statement or to request this Privacy Statement in another format, please contact us at:

PRADA USA Corp.
610 West 52nd Street, New York, New York 10019

Prada S.p.A.
Via Antonio Fogazzaro 28, Milan (Italy)

Group Data Protection Officer
e-mail address: privacy@prada.com

12.? Effective Date, Amendments
The Privacy Statement is currently in force is the one published on our Website. We may amend it from time to time, and if we make material changes, we will prominently post a revised version on the Website. ?Where required to do so by law, we may seek your prior consent to any material changes we make to this Privacy Statement.

Last updated: December 20, 2019

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