- The information HAT FAERIE collects from you will include as followings:
- Identification Data: Name, Surname, Address, E-mail Address, Gender, Date of Birth.
- Economic & Transactions: Payment Method, Credit Card Number (truncated), information on your purchases, orders returns, and bank account number.
- Connection, Geolocation and/or Browsing: Information about the device you use to access our Platform or type of browser you are using. IP address from which payment is made.
- Commercial Information: Subscription to the newsletter
- Information about Your Tastes & Preferences: Preferences related to the historic purchase and browsing history, social networks ID
When we ask you to fill in your personal data to give you access to any functionality or service of the Platform, we will mark certain fields as compulsory, since this is information that we need to be able to provide the service or give you access to the functionality in question. Please take into account that, if you decide not to make such data available to us, you may be unable to complete your VIP registration or may not be able to enjoy those services or functionalities.
In specific cases, a third party may have provided us with information about you by using a feature or service on the Platform, for example by sending you a gift card or shipping an order to your address. In these cases, we only process your data where relevant to this feature or service, as stated in this Privacy and Cookies Policy
- DATA PROCESS
Information HAT FAERIE collected online to manage your registration as our VIP, to manage your purchases of products or services, to respond to your queries, and, if you wish, to send you our customized communications.
- To manage your registration as our VIP member
For you to be able to register as our VIP, we need to process your personal data, since we would otherwise be unable to manage your registration.
- Development, performance and making of the purchase or services contract
We process your data because their processing is necessary for us to make the purchase or services contract with you.
Certain processing of data related to the purchase process is activated only because you request or authorize it. In these cases, our processing of your data is supported by your own consent.
We consider that we have a legitimate interest to carry out the necessary verifications to detect and prevent potential fraud or fraudulent uses of the Platform, for example when you make a purchase or return. We understand that the processing of these data is positive for all the parties involved: for you, as it allows us to put in place measures to protect you against attempted fraud perpetrated by third parties; for Us, as it allows us to avoid unauthorized uses of the Platform; for all our customers and society, as it also protects their interest by ensuring that fraudulent activities are discouraged and detected when they do occur.
- Customer Support
We consider that we have legitimate interest in answering the requests or queries raised by you through the existing different contact channels. We understand that the processing of these data is also beneficial to you to the extent that it enables us to assist you adequately and answer to the queries raised.
When you get in touch with us, in particular, for the management of incidents related to your order or the product/service acquired through the Platform, the processing of your data is necessary to perform the purchase contract.
When your request is related to the exercise of your rights on which we inform you below, or to claims on our products or services, we are legally permitted to process your data for compliance with our legal obligations.
We are legally permitted to process your data for marketing purposes due to the consent that you give us, for example when you accept receiving customized information through multiple channels, when you accept receiving push notifications on your mobile device or configure your mobile device´s settings to allow personalized ads, or when accepting the legal terms and conditions to participate in a promotional action or to publish your pictures on the Platform or on our social networks' channels.
To offer you personalized services or to show you customized information, whether on our Platform or those of third parties, as well as to engage in data enrichment, we consider that we have a legitimate interest to conduct a profiling with the information that we have about you (such as your browsing, preferences or purchase history) and the personal data that you have provided us, such as the age range or language, since we understand that the data processing of these data is also beneficial to you because it allows you to improve your user experience and access the information in accordance with your preferences.
- Analysis of usability and quality
We consider that we have a legitimate interest in analyzing the Platform usability and the user's satisfaction degree, since we understand that the processing of these data is also beneficial for you because the purpose is to improve the user experience and provide a higher quality service.
- DATA STORAGE
- To manage your VIP registration
We will process your data for the time during which you remain a registered VIP.
- Development, performance and making of the purchase or services contract
We will process your data for the time necessary to manage the purchase of the products or services that you buy, including potential returns, complaints or claims related to the purchase of the product or service in question.
Sometimes, we will only process the data until the time when you decide, as is the case of payment (card) data that you requested us to store for future purchases (where this feature is available).
- Customer Support
We will process your data for the time necessary to meet your request or application.
We will process your data until you unsubscribe or cancel your subscription to the newsletter.
Likewise, we will show you personalized ads until you change your mobile or browser settings such that permission to do so is revoked.
If you participate in promotional actions, we will keep the data during a six (6) months period from the end of the action.
- Analysis of usability and quality
We will process your data occasionally for the time during which we proceed to carry out a specific quality action or survey or until we anonymize your browsing data.
Notwithstanding the fact that we will process your data for the time strictly necessary to achieve the purpose in question, we will subsequently keep them duly stored and protected for the time during which liability may arise for their processing, in compliance with legislation in force from time to time. Once each of the potential actions is time-barred we will proceed to delete the personal data.
- DO WE SHARE YOUR DATA WITH THIRD PARTIES?
To achieve the purposes mentioned in this Privacy and Cookies Policy, we must give access to your personal data to entities of the Inditex Group and to third parties that provide us with support in the services that we offer you, i.e.:
- Financial institutions (with these entities we may share identify data and economic and transaction data),
- Anti-fraud detection and prevention entities (with these entities we share identify data, economic and transaction data, and connection, geolocation and/or browsing data),
- Technological and analytical service providers (with these entities we may share identify data, economic and transaction data, connection, geolocation and/or browsing data, and commercial information),
- Providers and partners of services related to logistic, transport and delivery and/or their partner establishments(with these entities we may share identify data and economic and transaction data),
- Providers of customer support related services (with these entities we may share identify data, economic and transaction data, and commercial information),
- Service providers and collaborators related to marketing and publicity, such as social media sites, advertising agencies or advertising partners (with these entities we may share identify data, connection, geolocation and/or browsing data, commercial information and information about your tastes and preferences).
[Please, to understand which personal data are included under these categories, consult section I.]
Moreover, we hereby to inform you that we will transfer the above-mentioned data with adequate safeguards and always keeping your data safe.
- Transfer of control
We will not transfer the control of your personal data to any company, organization or individual, except in the following cases:
- Obtaining your explicit consent in advance;
- In accordance with the laws and regulations or mandatory administrative or judicial requirements;
- In the case of asset transfer, acquisitions, mergers, reorganization or liquidation, if the transfer of personal data is involved, we will inform you of the situation and require new companies and organizations holding your personal data to continue to be bound by this policy. If the purpose of the collection and use of your personal data is changed, we will require the new company and organization to regain your explicit consent.
- Public Disclose
In principle we will not disclose your personal data publicly. In the event of public disclosure, we will inform you of the purpose and type of the disclosure, and the sensitive information that may be involved, with your explicit consent.
- In accordance with the relevant laws, regulations and national standards, we may share, transfer or publicly disclose your personal data without obtaining your consent in the following cases:
- Directly related to national security and defense security;
- Directly related to public safety, public health and major public interests;
- Directly related to criminal investigation, prosecution, trial and execution of judgments;
- For the maintenance of your or other people's life, property and other important legitimate rights and interests, but it is difficult to get your own consent;
- The personal data collected is disclosed to the public by yourself;
- The personal data is collected from lawful and publicly disclosed information, such as: legal news reports, government information disclosure and other channels.
- YOUR RIGHTS OVER YOUR INFORMATION
We believe you should be able to access and control your personal information no matter where you live. You have the right to request access to, correct, amend, delete, restrict, or object to certain uses of your personal information (for example, direct marketing). We will not charge you more or provide you with a different level of service if you exercise any of these rights.
We undertake to keep your personal data confidential and to ensure that you may exercise your rights. Bearing that in mind, we have agreed that you may exercise your rights free of charge by writing us an e-mail to a single e-mail address (firstname.lastname@example.org), simply informing us of the reason for your request and the right that you wish to exercise. If we consider this necessary to be able to identify you, we may request you to provide a copy of a document evidencing your identity. In particular, notwithstanding the purpose or legal basis we use to process your data, you have the following rights:
- To request access to your personal data that we hold. We remind you that when you are our VIP.
- To request that we rectify the personal data that we hold. Please bear in mind that if you are a registered user on the Platform, you may also access the relevant personal data section of your online account to change or update your personal data. In any case, please take into account that, on actively making your personal data available to us through any procedure, you guarantee that they are true and accurate and you undertake to notify to us any change or modification of your data. You will be liable for any loss or damage caused to the Platform or to the person responsible for the Platform or to any third party by reporting erroneous, inaccurate or incomplete information in the registration forms. Please remember that, as a general rule, you must provide us only with your own data, not with those of third parties, other than to the extent otherwise permitted in this Privacy and Cookies Policy.
- To request that we erase your personal data to the extent that they are no longer necessary for the purpose for which we need to keep processing them, as we have explained above, or when we are no longer legally permitted to process them.
- To request that we cancel your VIP account, as a consequence of which, we will cease the offering of the VIP services to you and delete or anonymize your personal data according to applicable laws and regulations.
If you have given us your consent to process your data for any purpose, you also have the right to withdraw such consent at any time. Some of the circumstances in which you may withdraw your consent are detailed in section II where we explain for which purposes we process your data. For example, should you not wish us to send information to third parties to show you ads, you can send the unsubscribe message to our e-mail: email@example.com.
In addition, where the processing of your data is based on our legitimate interest, you will also have the right to object to the processing of your data.
- INFORMATION PROTECTION
We are committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. When we transmit highly confidential data (such as card number or password) over the Internet, we protect it through the use of encryption.
In the event of a personal information security incident, we will promptly inform you, as required by laws and regulations, of the basic situation and possible impacts of the security incident, the measures that we have taken or will take, the suggestions you may be able to prevent and mitigate the risks, and the remedies13 for your actions. We will timely inform you of the event through email, SMS and other channels. If it is difficult to inform the personal information subject individually, we will take a reasonable and effective way to publish the announcement. At the same time, we will take the initiative to report the disposal of information security incidents according to the requirements of local authorities.
If you are not satisfied with our reply, especially our processing of your data infringes your legitimate interest, you may complain or report to relevant regulatory authorities, or bring a lawsuit before the competent court.
In principle, we won’t charge you for your reasonable request. However, we will charge a certain amount of cost for repeated requests that exceed a reasonable limit. We may reject those requests that are duplicative, require excessive technical means (for example, developing new systems or fundamentally changing current practices), pose risks to the legitimate rights and interests of others, or are very unrealistic.
Notwithstanding the above agreement, we may not be able to respond your request in the following cases in accordance with the relevant laws, regulations and national standards:
(1) Directly related to national security and defense security;
(2) Directly related to public safety, public health and major public interests;
(3) Directly related to criminal investigation, prosecution, trial and enforcement of sentences;
(4) There is sufficient evidence that you may maliciously abuse your rights;
(5) Responding to your request will cause serious damage to the lawful rights and interests of other individuals and organizations;
(6) Involving business secrets.
- VII.THIRD-PARTY DATA
We offer functionalities or services that require us to process the personal data of a third party that you, as a user or as a customer, must provide us with, such as in the case of activation and sending of the Gift Card or the management of the application for the Gift Voucher (where these features are available). If you provide us with personal data of third parties or if it is necessary that we request them for a third party to collect an order in your name, you confirm that you informed them of the purposes and of the manner in which we need to process their personal data, and that you have obtained their relevant express consent.
If a third party has provided us with your data or you have provided them yourself as a result of a feature or service requested by one of our users, we will use them to manage the feature or service in question in each case, within the limits of the purposes listed in this Privacy and Cookies Policy, a link to which is always included in our communications.
- VIII.CHILDREN’S PERSONAL DATA
Our products, websites and services are mainly for adults. A child may not register as our VIP without the consent of the parent or guardian.
In cases where a child's personal data is collected with the consent of the parent or guardian, we will only use or disclose this information in a case where the law allows, the explicit consent of the parents or guardians has been obtained, or it is necessary to protect the children.
Although the laws in different countries or regions have different definitions for children, we treat anyone under the age of 14 as a child. If we find ourselves collecting the child's personal data without prior consent of the parent or guardian, we will try to delete the relevant data as soon as possible.
- CHANGES TO THE PRIVACY AND COOKIES POLICY
We may amend the information contained in this Privacy and Cookies Policy when we consider this appropriate. Should we do so, we will notify you by various procedures through the Platform (for example, through a banner, a pop-up or a push notification), or we may even send you a notice to your e-mail address when the change in question is relevant to your privacy, for you to be able to review the changes, assess them and, as the case may be, object or unsubscribe from ay service or functionality. In any case, we suggest you to review this Privacy and Cookies Policy from time to time in case minor changes are made or we make any interactive improvement, taking the opportunity that you will always find it as a permanent point of information on our Website and our App.
- INFORMATION ON COOKIES