1. Our commitments
Everyone has the right to protection of his/her Personal Data. We respect users' right to be informed regarding the collection of and other operations involving their Personal Data. In using data that may directly or indirectly identify you personally, we will apply a principle of strict necessity. For this reason, we have designed the Website in such a way that the use of your Personal Data will be kept to a minimum and will not exceed the purposes for which your Personal Data was collected and/or processed; we do not process your Personal Data when we can provide you with services through the use of anonymous or traffic data (such as marketing research made for improving our services, browsing data processed to provide you with customised contents or offers adapted to your preferred language, your location, etc.) or by other means which allow us to identify you, apart from when it is strictly necessary or upon request by competent public authorities or the police (for example, in case of traffic data or your IP address).
For the purposes of the Data Protection Legislation (as defined below), ANTONIO PUIG SA. - a Spanish company with registered office at Plaza Europa 48-48, 08902 Hospitalet de Llobregat, Barcelone (Spain), incorporated with the register of trade and companies of Barcelona under number A08158289 and/or any companies of the PUIG Group that may need to have access to and process the Personal Data collected on the Website for one of the purposes listed below shall be considered as the controller of your Personal Data (hereinafter, jointly referred as to the “Company”).The Company hereby undertakes to treat any and all information provided online by a user as strictly confidential.
You must communicate to our Customer Service any changes to Personal Data in order to ensure that the information contained in our files is, at all times, up-to-date and accurate. You are responsible, in all cases, for the accuracy of the Personal Data provided, and we reserve the right to suspend or interrupt the provision of the requested services should you provide inaccurate Personal Data, without prejudice to any action allowed by law.
2. Applicable law
Any and all Personal Data sent to the Company through the Website will be collected and/or processed by the Company pursuant applicable data protection law, including the EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation or GDPR) ) without prejudice however to any applicable local mandatory laws benefitting to consumers, in accordance with EU Regulation 593/2008 (“ROME I”) of 17 June 2018, or any other conflict of laws rules applicable in the United Kingdom (together, “Data Protection Legislation”).
3. Who collects and processes Your Personal Data, how and for which purposes?
The Company may collect and process your Personal Data for a variety of different purposes.
Your Personal Data may be processed to provide the e-commerce services you subscribed to or reserved for registered users, notably to fulfill orders that you have placed for goods or services through the Website, to contact you in relation to any issues with your order or where we need to provide your Personal Data to our service providers in relation to your orders of products (herein the "Commercial Purposes"). The PUIG Group Company, which is acting as a seller, as the case might be, shall be considered as the controller of your Personal Data collected and processed on the Website for Commercial Purposes, as it will determine the purposes and means of processing Personal Data for such Commercial Purposes.
Your Personal Data may also be processed for marketing purposes, notably to send to users, also through newsletter, commercial communications, information and updates on our products, offers, exclusive sales, promotional campaigns and on events and similar initiatives organized by the Company and/or any companies of PUIG Group, or to facilitate your navigation on the Website (herein the "Marketing Purposes"). ANTONIO PUIG S.A. shall be considered as the controller of your Personal Data collected and processed on the Website for Marketing Purposes, as it determines the purposes and means of processing Personal Data for such Commercial Purposes.
For the Commercial Purposes only, the Company has appointed certain entities that will also process Personal Data relating to the Website’s Users (herein the "Processors").
The above-mentioned service providers and Processors have been chosen because of their experience in processing Personal Data and they provide sufficient guarantees regarding compliance with Data Protection Legislation (including the technical security measures governing the processing to be carried out). In processing the Personal Data for Commercial Purposes, the Processors shall act only under the instructions from the Company. We regularly check that our Processors comply with our instructions and that they continue to provide sufficient guarantees regarding their full compliance with Data Protection Legislation on Personal Data processing.
The Processors of your Personal Data for Commercial Purposes are:
• Queendom Customer Service, managed by Approche-sur-Mesure [ASM], for purposes related to shipping, delivering and returning products purchased on the Website and Customer Care services to the Website’s users
• Reseller Group Networks, S.L. for hosting of the website
• Adyen N.V. [Adyen] for payment services
• CEPL Barcelona S.L.U. [ID Logistics] and United Parcel Service España Ltd y Compañía S.R.C. [UPS] for shipment
• Projectes i gestions Serval ALH S.L. for order returns management
• Gigya for Customer Data management
• Neolane, ltd. for emailing communication
• Google Analytics for Web Analytic
Your Personal Data is mostly processed by electronic means and, in some circumstances, by paper-based means, such as when the processing of your Personal Data is required for preventing fraud on the Website. Your Personal Data shall be stored in a way which allows us to identify you for the period necessary for the purposes which the data was collected for and subsequently processed and, in any case, in accordance with Data Protection Legislation. Your Personal Data shall not be disclosed to third-parties other than us for purposes which are not permitted by law or without your consent.
Aside from the Processors appointed for Personal Data processing, your Personal Data will be made available also to third-parties, autonomous controllers, for purposes related to supplying services requested by Users (for example, for purchase transactions) or for purposes of third-parties. For more information on the matter, see section 5 (To Whom Your Personal Data Will Be Disclosed).
For the Marketing Purposes, we may process your Personal Data as well as browsing data ("Traffic data") resulting from the use of the Website and of our services by any User, in order to provide Users with customized contents and offers on our services or to deliver any newsletter they subscribed to, subject to their discretionary right to withdraw their subscription to such newsletter or to oppose or object to the receiving of any advertising or marketing content which we think is of interest to a specific User. For Marketing Purposes, Personal Data and Traffic data is mostly processed by electronic means and shall be stored for us in any case, in accordance with Data Protection Legislation and available to our Processors.
Moreover, your Personal Data may be disclosed to the police or to judicial authorities, according to applicable laws and upon a formal request by such entities, for example in the event we need to prevent fraud on the Site (anti-fraud services).
Data processors will also have access to your Personal Data as stated in section 3 for the specific purposes stated therein. In all the above circumstances, your consent for data processing is not required as Personal Data Processing would be necessary for the performance of Commercial Purposes.
The reasons for collecting Personal Data will be expressly listed in the information of privacy statement that we will present from time to time on the page asking the User to provide his or her Personal Data, be it for Commercial Purposes or for Marketing Purposes. We may have access to third-parties' Personal Data which was directly disclosed by its Users, for example when a User bought a product to be sent to a friend, when the User paying for the product is different from the recipient of the product, or when a User wishes to recommend to a friend a service of the Website or the sale of a particular product.
4. What Happens if You Do Not Disclose Your Personal Data to us?
Granting your Personal Data to us (in particular, your personal details, your e-mail address, your address, your Credit/Debit Card numbers and bank code and your telephone number) is necessary for processing your order for the purchase of products on the Website, supplying other services provided on the Website upon your request, or when your Personal Data is needed to fulfil obligations required by law or regulations. The refusal to provide us with some of your Personal Data necessary for performing the above purposes may consequently prevent us from processing your order for the purchase of products sold on the Website or fulfilling obligations required by law and other regulations. Therefore, failing to provide Personal Data may constitute, in some cases, a legitimate and justified reason for not processing your order for the purchase of products sold on the Website or not providing the Website’s services.
Disclosure of further Personal Data to us other than that required for fulfilling legal or contractual obligations and to be properly browse our services with necessary traffic data is, on the contrary, optional and does not have any effect on the use of the Website and of its services or on the purchase of products on the Website. We will inform you at every step whether disclosing your Personal Data to us is compulsory or optional by marking with an appropriate symbol (*) the information that is compulsory, or data needed for the purchase of products on the Website.
5. To whom your Personal Data will be disclosed?
Personal Data will be disclosed to third-party companies that provide, on behalf of the Company, specific services as data Processors or to other recipients of Personal Data collected by us that process your Personal Data only for the Commercial Purposes and, in any case, according to applicable laws and regulations.
Your Personal Data is also intended to the companies belonging to PUIG’s Group, with registered offices in EU countries or non-EU countries, for their own Marketing Purposes.
Notwithstanding the foregoing, Personal Data will not be disclosed to any other third-parties or disseminated or transferred without informing our Users of such disclosure/dissemination/transfer, and, in any case, in accordance with the applicable laws.
6. Security Measures and length of conservation
For the best possible protection of your Personal Data outside the limits of our control and management of the same, it is advisable that your computer be provided with software devices that protect network data transmission/receipt (such as updated antivirus systems) and that your Internet service provider take appropriate measures for the security of network data transmission (such as, for example, firewalls and anti-spam filtering).
We will only hold your Personal Data for so long as is necessary for us to fulfil the purposes set out in this Privacy Notice. Where we no longer need to process your Personal Data for the purposes set out in this Privacy Notice, then we will delete your Personal Data from our system.
7. Transfer of your Personal Data to other countries
The Personal Data we collect from you is currently held within the European Union (‘EU’). However, it is possible that in the future such Personal Data may be transferred, stored and/or processed outside the EU.
By submitting your Personal Data, you agree to this transfer, storing and/or processing. You should be aware that countries outside the EU may not offer the same level of data protection as the EU. However, we will take reasonable steps to ensure that your Personal Data is given equivalent protection in accordance with the Data Protection Legislation, in particular by implementing adequate contractual conditions in our agreements with business partners dealing with transfer of Personal Data to ensure that Personal Data are processed according to our instructions, and in such a way to maintain their integrity and security.
8. Your right in relation to your Personal Data
We set out below a summary of the rights available to you in connection with your Personal Data.
For your convenience, and without prejudice to certain formal requirements set out in the Data Protection Legislation, you can exercise any of these rights by contacting us at [email protected].
• Right to withdraw your consent:
You may at any time withdraw the consent you give to the Company for processing your Personal Data. Please note, however, that where you do withdraw your consent or otherwise object to our processing of your Personal Data then this may impact on our ability to provide you with goods and services or affect the functionality of our Website.
In addition, if you want to stop receiving future marketing messages, communications and materials at any time, you can do so alternatively by clicking the 'unsubscribe' link which is included in all of our email marketing messages.
• Right to access your Personal Data in our possession:
You are entitled to obtain, at any time, confirmation from us as to whether or not we are processing your Personal Data and, where that is the case, access such Personal Data.
Moreover, you are entitled to receive from us information on the source of your Personal Data; the purposes and way of processing your Personal Data; the logic involved in any electronic data processing; details of the data controller and of the data processors; the names of the entities and categories of entities to whom your Personal Data may be disclosed or who may access your Personal Data, for example, as a data controller or a party so appointed.
• Right to have inaccurate Personal Data rectified:
You have the right to obtain from us without undue delay the rectification of inaccurate Personal Data that we hold and which concerns you. The includes the right to request that incomplete Personal Data is completed.
• Right to erasure:
You have the right to obtain from us the erasure without undue delay of Personal Data that we hold and which concerns you, in the circumstances as provided by Data Protection Legislation.
• Right to restriction of processing:
You have the right to restrict the way we process your Personal Data in the circumstances as provided by Data Protection Legislation.
• Right to data portability:
You have the right to receive from us the Personal Data concerning you which you have provided to us, in a structured, commonly used and machine readable format and have the right to transmit those data to another controller without hindrance from us. This right shall include the right to require us to transmit the relevant Personal Data to another controller on your behalf, where technically feasible. This right only applies to personal data that: (i) we gain your consent to process; or (ii) we obtain in order to perform our contractual obligations to you, and in each case to the extent we process your Personal Data by automated means.
• Right to lodge a complaint about us:
You are entitled to exercise your right to lodge a complaint with a competent supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal data infringes Data Protection Legislation.
9. Opt-in/Opt out
Each time your consent is required, the Company will inform you in advance and will give you the option to either provide or refuse your consent for the use of your Personal Data, including your e-mail address, for the above purposes, by ticking the appropriate boxes.
We wish to inform you that we may process your Personal Data also without your consent in certain circumstances, such as when such processing is necessary for performing a legal obligation to which we are subject or when such processing is necessary for performing obligations undertaken in contracts with the users.
Last update: July 2019