PRIVACY POLICY

Tecnica Group Spa and the other Tecnica Group’s companies (Tecnica Group) respect the privacy of information that identifies you or is identifiable to you (Personal Information). We want you to understand how Tecnica Group processes Personal Information, and how you can submit privacy rights requests to us. This Privacy Policy (Policy) applies to individuals (not employed by Tecnica Group) who reside in the United States or Canada (Individuals) and Tecnica Group’s activities in those countries, in compliance with the federal, state, and local laws and regulations of those countries applicable to Tecnica Group’s processing of Personal Information (Applicable Law).

1. Personal Information

Tecnica Group provides goods and services to Individuals related to alpine skiing, rollerblading, and certain other athletic and outdoor activities (Products). In the course of doing so, we receive, create, and otherwise processes Personal Information about Individuals, which may include the following: (1) identifiers, such as first and last name, email, physical address, and phone number; (2) information about how Individuals use and interact with Products, such as performance and preferences; (3) employment information, such as name of employer and job title and function (provided that this Policy does not apply to employees of Tecnica Group); and (4) financial information, such as credit and debit card information.

Depending on how Individuals interact with us, we may collect Personal Information when you visit our websites, complete or submit forms to us, purchase or otherwise receive Products from us, communicate with us directly or indirectly via phone, email or other methods, subscribe to our media distribution lists, newsletters, or other forms of communications, respond to surveys or communications form us, and otherwise interact with us.

Tecnica Group has processed Personal Information in the last twelve months pursuant to this Policy.

2. Sensitive Personal Information and Children

Except with respect to certain children, Tecnica Group generally does not receive, create or otherwise process Personal Information that is of a sensitive nature (Sensitive Personal Information). If and to the extent you provide Sensitive Personal Information to us, or we receive, create or otherwise process Sensitive Personal Information that is not necessary for us to provide Products to you, we reserve the right to delete such Sensitive Personal Information. For purposes of this Policy, Sensitive Personal Information is a category of Personal Information.

Tecnica Group provides Products to or for the use and benefit of certain Individuals who are minors in the jurisdictions in which they reside (Children). In the course of doing so, we receive, create and otherwise process Personal Information about Children, which qualifies as Sensitive Personal Information. If and to the extent we do so, we obtain consent for the processing of such Sensitive Personal Information from one or more of the parents or legal guardians of such Children.

3. Legal Bases for Processing Personal Information

Tecnica Group has contractual and other commercial, business, and legal relationships with and obligations to provide Products to Individuals. Tecnica Group also seeks and obtains consent for the use of Personal Information. Those are the legal bases for Tecnica Group to process Personal Information.

Tecnica Group may process Personal Information as necessary or appropriate to accomplish those legal purposes, including the following activities: (1) provide, develop, maintain, and enhance Products and our website; (2) communicate with Individuals about Products; (3) provide support for Products; (4) conduct internal business operations and processes; (5) process and complete transactions and send information related to such transactions; (5) personalize your experience with our website; (6) send you marketing communications; (7) maintain safety, security, and integrity of our company and website; (8) comply with legal and regulatory obligations; and (9) establish, enforce, and otherwise exercise our rights and defend against claims.

4. Disclosure of Personal Information

Except as necessary or appropriate to provide Products to Individuals and conduct our business operations and processes, Tecnica Group generally does not disclose Personal Information about you to other entities, individuals, or unaffiliated third parties, provided that we may disclose Personal Information for the following purposes and in the following circumstances.

• If directed to do so by the Individual from whom we received or for whom we collected the Personal Information.
• If directed to do so by the Individual about whom such Personal Information pertains or that Individual legal representative.
• If required to do so by Applicable Law, any other law or regulation, legal process or warrant, or order of any court or governmental agency or authority.
• To our agents and service providers necessary or appropriate to provide Products or conduct our business operations and processes.
• In connection with a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation of Tecnica Group.
• To entities that perform marketing, advertising, or market research on our behalf.
• If we determine that doing so would be in the public’s interest.
• For the protection of Tecnica Group or the public.

Tecnica Group may partner with certain third-parties and use third-party tools and cookies in the course of operating our website, including from Meta (e.g., Facebook and Instagram), Google, X (formerly Twitter), and LinkedIn. Those third-parties use Personal Information provided by you and collected about you during your use of our website, process that Personal Information to deliver targeted advertisements and marketing communications to you when you use those third-parties’ website and social media platforms, and monitor your activity on our website, your responses to such advertisements and marketing communications, and the effectiveness of them. Additionally, Tecnica Group’s website may contain links to websites and social media platforms of third-parties. Tecnica Group has no control over the policies and practices of any such third-parties. Please review the applicable third-party website’s policies for further information regarding their processing of your Personal Information. The manner in which these third parties collect and process Personal Information is governed by the policies promulgated by them.

5. Privacy Rights

Depending on the Personal Information that Tecnica Group has about you, and depending on the manner in which we process your Personal Information, you may have the following privacy rights related to our processing of your Personal Information.

• Be informed about how your Personal Information is being processed, the categories of Personal Information being processed, and the categories of sources from which your Personal Information has been collected.
• Be informed about whether and how your Personal Information is being sold, shared, traded, exchanged or brokered with unaffiliated third parties and which categories of your Personal Information are being sold, shared, traded, exchanged or brokered with unaffiliated third parties (if and to the extent we were ever to do so).
• Access or receive a copy of your Personal Information.
• Rectify, update, or correct inaccurate or incomplete Personal Information about you.
• Erasure or deletion of certain categories of your Personal Information.
• Limit, object, and opt-out of certain processing of your Sensitive Personal Information.
• Opt-out of the sale, sharing, trading, exchange, and brokering of your Personal Information with unaffiliated third parties (if and to the extent we were ever to do so).
• Portability of your Personal Information in a commonly used format.
• Withdrawal of your consent to our processing your Personal Information to the extent such processing is based on your consent, provided that such withdrawal will not affect the lawfulness of Tecnica Group’s use of your Personal Information before such withdrawal.
• Non-discrimination for exercising your privacy rights.

To make a request concerning these rights, please complete and submit the Privacy Rights Request Form on our website. We will confirm receipt of all such complete Privacy Rights Request Forms within 10 business days of receipt. We will substantively respond to all such requests within 45 calendar days, subject to any lawful extension of that period. Additionally, there may be a delay in processing a request while we verify that the request is valid and originates from you as opposed to an unauthorized person.

Please be aware there may be valid reasons to refuse or limit our response to a request, including legal and regulatory requirements that we retain and process certain information. Also, please be aware that certain privacy rights requests may limit or prevent us from providing Products to you. In those situations, we will notify you in writing within 45 calendar days. You may also contact our Data Privacy Officer to address those situations.

Tecnica Group will not discriminate against you if you exercise these rights or any other rights under Applicable Law, including not denying Products to you, providing a different level or quality of Products to you, or suggesting that you will receive a different level or quality of Products.

6. Sale, Sharing, Trading, Exchanging, and Brokering Personal Information

Except as otherwise explicitly provided in this Policy, Tecnica Group does not sell, share, trade, or exchange Personal Information (as those terms are defined and used in Applicable Law) for itself or any unaffiliated third party. If you want to opt-out of the sale, sharing, trading, or exchanging of your Personal Information, please complete and submit our Privacy Rights Request Form.

       7. Automated Decision Making

Tecnica Group does not use automated decision making or profiling (as those terms are defined and used in Applicable Law) in the processing of Personal Information, and does not make decisions that affect Individuals based on such automated decision making or profiling.

8. Duration of Retention

Because the Products that Tecnica Group provides to Individuals vary significantly, the duration we retain Personal Information varies significantly, depending on the types of Products that Tecnica Group provides to Individuals, the duration and depth of Tecnica Group’s relationship with Individuals, and the nature of such Personal Information. Tecnica Group endeavors to retain Personal Information for only as long as is necessary or appropriate under the circumstances.

8.1 Services offered by the Site

You can find below the description of the services offered by the Site. For each services are indicated: the purposes for which Data are processed, the legal basis for such processing, and the retention periods for the processed Data.

A) E-commerce

Through the Site you can make online purchases of Moon Boot brand products. In order to proceed with the purchase of such products you can:

• create your own account;
• select the various items and checkout as a “Guest”.

Purpose of processing: to provide e-commerce services for the online buying and selling of the Controller’s products and to carry out the shipping of the purchased products.

Legal basis for processing: performance of a contract to which the data subject is party or performance of pre- contractual measures taken at the request of the data subject.

Retention period: personal data will be retained for the entire contractual term and, after termination, for the ordinary limitation period.

B) “Returns” section

Within the Site there is a “Returns” section. The latter allows the user who has not created an account to make a return of a product purchased within the Site. For the purpose of providing this service, the user is necessarily required to provide an e- mail address and order number.

Purpose of processing: to provide the service of returning an order placed within the e-commerce of the site.

Legal basis for processing: performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Retention period: personal data will be retained for a period not exceeding 24 months from the time it is provided.

C) “Track Order” section

Within the Site there is a “Track Order” section. The latter allows the user who has not created an account to track the order placed and view its details. For the purpose of providing this service, the user is necessarily required to provide an e-mail address and order number.

Purpose of processing: to provide details about the order placed within the site's e-commerce as well as to be able to track the order itself.

Legal basis for processing: performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Retention period: personal data will be retained for a period not exceeding 24 months from the time it is provided.

D) “Contact us” section

Within the Site there is a “Contact us” section. The latter allows the user to submit to the Company their requests for information related to the product, shipping, return or other. For the purpose of providing this service, the user is necessarily required to provide the following personal data: first name, last name and e-mail address.

Purpose of processing: provide feedback to requests for information made by the user.

Legal basis for processing: performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Retention period: personal data will be retained for a period not exceeding 24 months from the time it is provided.

8.2 Additional purposes of processing

As part of the processing of personal data carried out by the Site, the Data Controller pursues the following additional specific purposes:

A) Fulfillment of legal obligations

The Data Controller, where necessary, processes the personal data of data subjects, collected through the Site, in order to ensure compliance with legal obligations, regulations and EU standards to which it is subject.

Legal basis for processing: processing is necessary for compliance with a legal obligation to which the controller is subject.

Retention period: personal data will be retained for the period strictly necessary to enable the Controller to fulfill the legal obligations to which the Controller is subject.

B) Establishment, exercise and defense of rights in court

The Data Controller, where necessary, processes the personal data of data subjects, collected through the Site, in order to establish, exercise or defend its own right in court or whenever the judicial authorities exercise their jurisdictional functions.

Legal basis for processing: processing is necessary for the pursuit of the legitimate interest of the controller.

Retention period: personal data will be retained for the period strictly limited to the duration of the litigation, until the time limit for appeal actions is exhausted.

C) Direct marketing activities

Your personal data, subject to your free and specific consent, will be processed by the Data Controllers to update you on promotional, commercial and advertising initiatives, events, initiatives. We inform you that these activities may be carried out by means of paper mail, telephone contact by operator (so-called “traditional modalities”), e-mail, sending of sms, push notifications and use of social networks (so-called “automated modalities”). In addition, we will process Your Data to perform analysis and reporting activities related to promotional communication systems. In the absence of your specific consent for this purpose, we will not be able to process your Personal Data for direct marketing purposes and will therefore not be able to inform you of new products and/or current promotions.

Legal basis for processing: Consent of the data subject.

Retention period: personal data will be retained until the user withdraws consent. Purchase data for marketing purposes will be retained for 24 months.

D) Profiling

Subject to your free, optional and specific consent, we will process your personal data for profiling purposes. In particular, through monitoring the products and services you purchase through the Site as well as your behaviors and interactions, we will assess your behavior in more detail and analyze your preferences, interests, and consumption habits. In the absence of your specific consent for this purpose, we will not be able to process your personal data for profiling purposes.

Legal basis for processing: Consent of the data subject.

Retention period: personal data will be retained until the user withdraws consent. Data from purchases for profiling purposes will be retained for 12 months.

9. Cookies

When you visit our website, Tecnica Group may place a cookie (a text file containing a randomly assigned number) on your device so that we have the ability to customize the look and feel of the website for you and share certain information with third-parties (as discussed above). Cookies remember information about you, your preferences, and your device for a better user experience when visiting the website and to provide such information to certain third-parties. Using cookies, we may also collect a variety of other information regarding your usage of the website, including your Internet protocol address, username, session identification, browser you are using, web pages you view and referring web pages, when you access the website, and general online behavior for performance and marketing purposes. You may decline to accept cookies by modifying your web browser settings. If you choose to do so, however, you may be unable to use some or all functions of our website or the websites and social media platforms of third-parties, or our website or those other websites or social media platforms may operate less efficiently.

10. Changes to Policy

Tecnica Group reserves the right to change or amend this Policy at any time and for any reasons, including to comply with Applicable Law.

11. Questions or Concerns

For questions or concerns, please contact us as follows.

The data controller is Tecnica Group S.p.A., via Fante d’Italia, 56 – 31040, Giavera del Montello (TV), Italy, C.F. e P.IVA 00195810262

E-mail address: privacy@tecnicagroup.com

 

Data Protection Officer (DPO)

The Data Protection Officer is PARTNERS4INNOVATION S.R.L., established at Viale Luigi Bodio 37 - 20158 - Milano (MI), Italy

And can be contacted at the following:

Phone: (+39) 02 9285 2707

Email: privacy@tecnicagroup.com

 

Last Updated: March 17, 2025