Revised on 24/05/2018
COMPANY IN CHARGE
IN SITU, S.A.
To access, amend and delete data, as well as other rights, as explained in the extra information www.naelle.com/en/politica-privacidad
Extra and more detailed information on Data Protection can be found on our website www.naelle.com/en/politica-privacidad
In accordance with the General Data Protection Regulation (EU) 2016/679, we hereby inform you that the personal data you provide will be incorporated into a computerised file registered with the Data Protection Agency under the name of the company in charge of the data named below and created and used by the company for the purposes indicated below. The owner expressly authorises the company to transfer such data to third parties as described below, for the purposes indicated. You are hereby informed that you may exercise your rights to access, omit, limit the processing, portability, amend, contest and cancel your data by writing to the address stated in point 1.
WHO IS IN CHARGE OF PROCESSING YOUR DATA?
The company in charge of processing your data is IN SITU, S.A. with registered address at calle Valportillo Primera, nº 2 in Alcobendas (Madrid) and with tax code A78234747
You can contact us through our email address: firstname.lastname@example.org,or by writing to the address listed in the preceding paragraph or by telephoning 91 484 44 00
WHY DO WE PROCESS YOUR PERSONAL DATA?
Your data is processed for the following purposes:
a) To offer you our products, services and promotions when you subscribe to our Club Estilo loyalty programme at our establishments, by signing up for the newsletter on our website or by creating an account on our online sales platform.
In this case the data we process from individuals includes the following: Name and Surname, Address, ID number so we can identify you at our establishments if you wish without having to show your membership card, telephone number, email address and date of birth.
In this case the legal requirement for processing such data is to obtain the consent of the individuals and the data can be passed to other companies of the group of our company IN SITU, S.A. as well as to service providers dealing with data processing such as information technology providers (a platform provider for example, or a software provider), franchisees and suppliers in general in order to provide the service described at the beginning of this section (communications sending companies, profiling companies).
We retain the data as long as the data subject does not request its deletion.
With regards the website, browsing may be carried out completely anonymously and our web server will only keep a series of public and freely accessible data for strictly statistical purposes: the domain name or IP address of the Internet access provider, the date and time of access to our website and the Internet address from where the hyperlink to our website started. In certain areas of our website, the user is asked for a series of personal data. In all cases the user will always have the option of accepting or rejecting the legal terms and conditions under which they provide this data. If the user accepts the conditions, they will provide the data on a voluntary basis, after notification to that effect on the corresponding screen.
b) To process and execute the online purchases of customers on our website, from the management of orders, payment administration, shipping the orders as well as resolving any incident that may occur within this area.
We will also process the data of individuals to contact them if they saved items in their shopping basket or in their wish list without actually purchasing them, so we can inform them of the availability of a product if they have requested it.
In this case the following data will be processed: ID, username and password, purchase history, email, IP address, date of abandonment, date of registration on the website.
The legal basis for processing this data is the contractual relationship maintained with customers. In this case, the data subject must provide the data necessary for the execution of the contract. If the data subject does not provide this data, they will not be able to purchase items.
We retain data only for the time necessary to carry out the purchase process if the purchase is not completed via a user account. In the event that under the contract the customer makes their purchase via a user account as they are registered, we will keep the data as long as the data subject does not request its cancellation. In all cases, in accordance with the legal obligations with which we must comply at all times, we will keep the data relating to the sale.
The data may be passed to companies belonging to the same group as our company IN SITU, S.A. as well as to service providers dealing with data processing such as information technology providers (a platform provider for example, or a software provider), franchisees, transport companies, payment service providers and third parties in general in order to provide the service described at the beginning of this section (online purchase and sale).
c) Use of technical and functional applications such as cookies.
We may sometimes use a technology called cookies to provide a range of personalised contents and/or services. A 'cookie' is a small element of data that a website can send to the user’s web browser. In turn, this element can then be stored on the hard drive of the user’s computer so that we can recognise the user when they return to our website. The user will always have the option of specifying, in the preferences section of their browser, that they want to receive a warning before accepting any cookie. Each cookie will store the following data: the date and time of the user’s most recent visit to our website, the content design that the user chose on their first visit to our website and the security elements involved in controlling access to the restricted areas. To learn more, please read our Cookies Policy.
The legal basis for the use of such techniques is our legitimate interest in providing a secure website or platform that functions correctly. In all cases, we understand that if individuals use our services, it is because they accept the use of these cookies.
The personal data processed for this purpose will only be disclosed to providers of platform analysis and optimisation tools.
For this purpose we only retain the data as long as the data subjects do not delete the cookies by changing their computer settings as described here. https://naelle.com/en/politica-cookies If the cookies are deactivated, the user will not be able to enjoy all the characteristics of our website.
IN SITU, S.A., applies profiling techniques to data such as name and surname, gender, email, postal address, telephone number, date of birth, description of preferences, order details and purchase history and the information compiled during the navigation process…., to evaluate certain aspects of consumers to analyse or predict their purchasing preferences, their interests and location. Based on this assessment, we send consumers communications and/or content adapted to suit their interests. So, for example, based on the location of consumers, we may send invitations out for in-store events or specific promotions.
The legal basis for this profiling and other techniques used to produce statistics is our legitimate interest in knowing the purchase needs of consumers, their level of satisfaction and that this helps our company to improve the products we offer and also the sales service we provide.
We retain the data as long as the data subject does not object.
We do not make automated decisions based on the profiles compiled.
e) Customer service.
In order to respond to any request, incident or complaint raised by the consumer we process the following data: name and surnames, email, postal address, telephone number, payment history and information, ID, correspondence with consumers.
The legal basis for such processing is our legitimate interest in responding to such requests from the data subjects as well as our obligation to fulfil the contractual relationship with our customers’ customers (for example, if there is a problem with the order).
We will keep this data only for the period of time reasonably necessary to respond to the questions above or to resolve any problems that may arise in the event that the individual is not a member of our Club Estilo or does not have an account on our online platform. Otherwise, the data will be kept until the individual cancels their registration to the website, notwithstanding the fact that in accordance with the requirements of the applicable regulations, we will keep any data required by law or data which may be necessary for our legitimate interest to defend the company against any possible claims.
WHAT ARE THE LEGITIMATE REASONS FOR PROCESSING YOUR DATA?
As we have explained, we process your data for the following legitimate reasons:
- Execution of the contract for the purchase of our products.
- Compliance with legal obligations in relation to sales to customers
- Legitimate interest in the profiling procedures we carry out, applying techniques such as cookies or producing statistics.
- Consent to join the Club Estilo, for subscription to the newsletter, commercial communications, product availability alert service and to create accounts on our sales website.
TO WHOM WILL YOUR DATA BE SENT?
In response to this question, the personal data of individuals may be transferred and/or disclosed to:
- Companies of the IN SITU Group and franchisors of its brands.
- Public Entities when so required by any applicable regulation, whether fiscal, Social Security or any other in force.
- Data processors such as providers of any service provided to IN SITU for the purposes described above: software companies, communications sending companies, transport companies, payment services companies etc… In all cases these are trusted providers with whom we hold contracts. We only provide them with the data necessary for them to carry out the contracted service and they must not use the data for any other purpose.
We do not sell your personal data.
The rights of those concerned are:
- Right to access: the right to have us confirm to data subjects whether we process personal data relating to them and, if so, the right to know what data we hold by obtaining a copy.
- Right to information: the right to obtain clear and concise information about the way in which we process data subjects’ data.
- Right to amendment: the data subject has the right to have their data amended by us if it is incorrect or incomplete.
- Right to deletion: the right of data subjects to delete their data (right of omission)
- Right to opposition: the data subject may object to us processing their data unless we have overriding legitimate interests that prevail, or for our defence in any claims that may arise.
- Right to limitation: the data subject may request that the processing procedures that would apply in each case not be applied to their personal data.
- Right to portability: if the data subject so requests, their personal data can be transferred directly from one company to another, whenever this is technically possible.
- Right to complain: the data subject has the right to complain to the Spanish Data Protection Agency.
You can contact us through our email address: email@example.com, by writing to the address at calle Valportillo Primera, nº 2 in Alcobendas (Madrid) or by telephoning (+34) 91 484 44 00