PRIVACY AND COOKIES POLICY & TERMS OF USE

PERSONAL DATA INFORMATION

Last update: 10 May 2018.

WHO IS THE DATA CONTROLLER FOR THE PROCESSING OF YOUR DATA?

The data controller for the processing of the data is PUNTO FA, S.L. (“VERDA”), with Corporate Tax ID number 9240047914. The contact details of VERDA are as follows:

- Postal address: Meşrutiyet Mah. Şair Nigar Sokak No:49/5 Osmanbey-Şişli

- Telephone:+90 212 965 20 35

- e-mail: [email protected]

The interested party is informed that VERDA has appointed a Data Protection Officer to deal with any issue relating to the processing of your personal data. The interested party may contact the Data Protection Officer via the following contact details: [email protected], postal address: Meşrutiyet Mah. Şair Nigar Sokak No:49/5 Osmanbey-Şişli

WHAT TYPE OF PERSONAL INFORMATION DOES VERDA COLLECT?

VERDA may collect the following personal information from users of the VERDA website and/or VERDA mobile application (“WEB/APP”) through the corresponding forms: name, e-mail address, postal address, telephone number, date of birth, gender and credit card (PAN+CVV2) in compliance with PCI DSS standards or bank account number (provided by the customer in the case of refunds) when the user visits the WEB/APP, registers, places an online order, contacts VERDA or participates in VERDA promotions or questionnaires.

In addition, VERDA collects all the information relating to their browsing on the WEB/APP and their interaction with the brand.
All the personal data VERDA originate from the interested party, with the exception of contact details that may be provided to us by friends and family:

- To send any gift voucher or other gift.

- To share the Wishlist saved in the WEB/APP.

FOR WHAT PURPOSE DO WE PROCESS YOUR PERSONAL DATA?

The personal data of the interested party shall be processed for the following purpose, as applicable:

- To manage and execute the registration on the WEB/APP. The registration involves the drafting of user browsing profiles on the WEB/APP. Said profiling consists of the use of the customer’s personal data and information on their browsing, such as the products viewed or added to the shopping basket, the sections of the WEB/APP visited, the location in order to evaluate their personal preferences and/or interests to offer them WEB/APP content, offers, services and products adapted to their profile.

- To manage and execute online purchasing. We use the personal information of the customer to process and deliver their order, and inform them by e-mail and/or SMS of the status of their order.

- Manage and send information about exclusive promotions, latest news and personalized information adapted to the profile, interests and needs of the interested party as a client through email, SMS, postal mail or any other channel of communication and / or digital platforms. The sending of this information will involve the creation of user profiles consisting of using personal data, the history of your purchases if applicable, as well as the navigation information on the WEB / APP to evaluate certain aspects related to your personal preferences. The objective of offering commercial communications appropriate to your profile. If necessary, certain personal information of the client may be used to personalize communications in digital media.

- The content, products or services will be personalised to the customer in the communications, in accordance with their interests. To manage the notifications, consult the ‘Subscriptions’ section in My account.

- To respond to the exercise of data protection rights, queries and complaints.

- To manage the notification service for when a certain garment becomes available on the WEB/APP.

- To manage and issue accreditation of sale documents: e-receipt, sales or Tax Free invoice.

HOW LONG DO WE KEEP THE DATA?

VERDA will keep the personal data only for a period that is reasonably necessary given the requirements to respond to issues that are raised or to resolve problems, make improvements, activate its services and fulfil the requirements of the applicable legislation. This means that it may keep the personal data for a reasonable time, including after the interested party has stopped using the services of VERDA or has stopped using the WEB/APP. After this period, the personal data will be blocked on all VERDA systems.

WHAT AUTHORISES US TO PROCESS THE DATA?

VERDA has the following lawful bases to process personal data:

Execution of the agreement
The legal basis for processing the personal data of the interested party which is collected is the execution of the sale and purchase agreement. In this regard, the interested party is obliged to provide that data necessary for its execution. If we are not provided with this data, the sale and purchase cannot be executed.

Legal obligations
The management and issue of the sales invoice is based on the legal obligation of VERDA in its relationship with its customers.

Consent
In relation to the following purposes, the legal basis for the processing of the personal data of the interested party will be the consent of the same, in cases where it has been given:

- Management of the registration on the WEB/APP.

- Management of the sending of information on exclusive promotions, latest news and personalised information adapted to the profile of the interested party.

- To respond to the exercise of data protection rights, queries and complaints on the part of the interested party.

- Management of the garment availability notification service on the WEB/APP.

- Management and issue of the following accreditation of sale documents: e-receipt and Tax Free.

- Management of the WIFI service in VERDA stores.

The withdrawal of consent of said processing on the part of the interested party shall not affect the execution of the sale and purchase agreement entered into by the same and VERDA.

Legitimate interest
In relation to the following purposes, the legal basis of the processing of the personal data of the interested party will be the legitimate interest of VERDA:

- The drafting of profiles via the browsing on the WEB/APP on the part of a user registered on the same, in addition to all other users that have provided us with their data for any other purpose.

- The drafting of profiles for the sending of information on exclusive promotions, latest news and personalised information adapted to the profile of the interested party.

- The sending of satisfaction questionnaires on the products purchased or services used by VERDA customers in order to know their opinion and improve them.

Our legitimate interest consists of being able to guarantee that our WEB/APP remains secure, and to help VERDA understand the requirements, expectations and degree of satisfaction of the users and, consequently, improve the services, products and brands. All these actions will be performed to improve the degree of satisfaction of the customer and guarantee a unique browsing and shopping experience.

TO WHICH ADDRESSEES CAN WE COMMUNICATE THE DATA?

The personal data of the interested party may be transferred/communicated to the following addressees:

- VERDA Group companies.

- Public Administrations and Bodies whenever required by the tax, employment, Social Security or any other applicable legislation.

- Data processing companies, such as franchisees and suppliers that provide a service to VERDA (courier companies, communications companies, agencies, profiling companies, etc.).

International transfers of data may also occur in relation to the above transfers/communications for which VERDA shall use the Standard Contractual Clauses adapted by the European Commission and the EU-US Privacy Shield as a guarantee of transfers to European Commission non-compliant countries. In all cases, third parties sharing certain personal data will have previously accredited the adoption of suitable technical and organisational measures for the correct protection of the same.

VERDA does not under any circumstances sell customer data to third parties.

HOW DOES VERDA PROTECT PERSONAL DATA?

The WEB/APP uses data security technologies such as firewalls, access control procedures and cryptographic mechanisms to prevent any unauthorised access to data and guarantee data confidentiality. To achieve these aims, the user agrees that VERDA will obtain data for the purpose of the corresponding authentication of access controls.

In addition, any transaction performed via the WEB/APP will be executed via secure payment systems. The confidential data are transmitted directly and in an encrypted manner (SSL) to the corresponding entity.
VERDA declares that it has adopted all the technical and organisational measures necessary to guarantee the security and integrity of the personal data it processes, and to prevent the loss, alteration and/or access of the same by unauthorised third parties.

WHAT ARE YOUR RIGHTS IN RELATION TO PERSONAL DATA?

You have the following rights, which may be exercised via the e-mail address [email protected]:

Right of access	You have the right to obtain confirmation whether at VERDA we are processing personal data that concerns you, or not, in addition to how to access the personal data VERDA possesses about you.
Right of modification	You have the right to ask VERDA to rectify the personal data whenever they are inaccurate, or to complete them whenever they are incomplete. If you are registered on our WEB/APP, it may be easier for you to correct them directly by modifying the profile.
Right to erasure/right to be forgotten	You may ask us for your personal data to be erased whenever, among other reasons, the data are no longer necessary for the purposes they were collected for.
Right to restriction	You have the right to request the restriction of the processing of your data, in which case we will only keep them for the exercise or defence of complaints.
Right to data portability	You have right to receive the personal data in a structured, commonly-used and machine-readable, and to transmit them to another controller whenever the processing is based on consent or on a contract, and is carried out by automated means.
Right to object	You may object to the processing of personal data based on the public or legitimate interest pursued by VERDA, including profiling. In this case, VERDA will cease to process the data, except for compelling legal grounds or the exercise or defence of possible legal claims.
Automated individual decisions	You have the right not to be the object of a decision based solely on automated processing, including profiling, while produces a legal effect on you or significantly affects you in a similar manner. However, it will not be possible to exercise said right in cases where the decision is necessary for the formalisation or execution of a contract between you and VERDA; it is authorised by the law applicable to VERDA provided it establishes the appropriate measures to safeguard its rights, freedoms and legitimate interests; or where it is based on your explicit consent.
Right to lodge a complaint	You have the right to lodge a complain to the Spanish Data Protection Agency.

To make the application, we may ask you to accredit your identity.