INFORMATION PERSONAL DATA

WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR DATA?

The data controller is OTITRENDEE2021, SL (“CARMEN SAYS”), with NIF B05274485. The contact details of CARMEN SAYS are the following:

• Postal address: Camino de la Fou 25, 08640 Olesa de Montserrat, Barcelona, ​​Spain.
• Telephone: (+34) 639 834 418
• Email: hello@carmensays.com

The interested party is informed that CARMEN SAYS has appointed a Data Protection Delegate before whom they can raise any issue regarding the processing of their personal data. The interested party may contact the Data Protection Delegate through the following contact information: hello@carmensays.com, postal address: Camino de la Fou 25, 08640 Olesa de Montserrat, Barcelona, ​​Spain.

WHAT TYPE OF PERSONAL INFORMATION DOES CARMEN SAYS COLLECT?

CARMEN SAYS may collect the following personal information from users of the CARMEN SAYS website and/or CARMEN SAYS mobile application (“WEB/APP”) through the corresponding forms: name, email address, postal address , phone number, date of birth, gender and credit card.

In addition, CARMEN SAYS collects all the information related to your browsing on the WEB/APP and your interaction with the brand.

All the personal data that CARMEN SAYS collects comes from the interested party.

FOR WHAT PURPOSE DO WE PROCESS PERSONAL DATA?

The personal data of the interested party will be processed for the following purposes, as applicable:

• Management and development of registration on the WEB/APP. Registration will involve the creation of user browsing profiles on the WEB/APP. Said profiling consists of the use of the client's personal data and browsing information such as the products viewed or added to the cart, the sections of the WEB/APP visited, the location to assess their preferences and/or personal interests. with the aim of offering you the contents of the WEB/APP, the offers, the services and the products appropriate to your profile.
• Management and development of online shopping. We use the customer's personal information to process and deliver your order, to inform you by email and/or SMS of the status of your order, and to perform anti-fraud checks. In case of receiving the consent of the interested party, we will keep your credit card information for future purchases.
• Management and sending of information on 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 communication channel and/or digital platform. The sending of this information will involve the preparation of user profiles that consists of using personal data, the history of their purchases, if applicable, as well as the browsing information on the WEB/APP to evaluate certain aspects related to their personal preferences, with the aim of offering commercial communications appropriate to your profile. Where appropriate, certain customer personal information may be used to personalize communications in digital media.
• Personalization of communications sent to the client based on their interests.
• Commercial prospecting and promotional action.
• Response to the exercise of privacy rights (detailed below), as well as to queries and possible claims by the interested party.
• Management and issuance of supporting documents of sale: simplified electronic invoice, sales invoice or Tax Free.

HOW LONG WILL WE KEEP PERSONAL DATA?

CARMEN SAYS will keep personal data only for the period of time that is reasonably necessary, taking into account the needs to respond to questions that arise or solve problems, make improvements, activate its services and meet the requirements required by applicable legislation. This means that you can keep the personal data for a reasonable period of time even after the interested party has stopped using the CARMEN SAYS services or has stopped using the WEB/APP. After this period, personal data will be blocked from all CARMEN SAYS systems.

WHAT LEGITIMIZES US TO PROCESS THE DATA?

CARMEN SAYS has the following legitimate bases to process personal data:

Contract execution

The legal basis for the processing of the personal data of the interested party that is collected is the execution of the purchase contract. In this sense, the interested party is obliged to provide the data that is necessary for its execution. If you do not provide us with this information, it will not be possible to carry out the sale.

Compliance with a legal obligation

In relation to the following purposes, the legal basis for the processing of the personal data of the interested party will be compliance with a legal obligation:

• The management and issuance of the sales invoice
• Response to the exercise of privacy rights (detailed below), as well as queries and possible claims by the interested party.

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 interested party, if it has been provided:

• Management of registration on the WEB/APP.
• Management of sending information about exclusive promotions, latest news and personalized information adapted to the profile of the interested party.
• Preservation of payment card data for future purchases.

The withdrawal of the consent of these treatments by the interested party will not condition the execution of the purchase contract entered into between the interested party and CARMEN SAYS.

legitimate interest

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

• The elaboration of profiles by browsing the WEB/APP by a user registered in it, as well as by all those users who have provided us with their data for any other purpose.
• The preparation of profiles to send information about exclusive promotions, latest news and personalized information adapted to the profile of the interested party.
• Sending satisfaction surveys on products purchased or services used by customers to request their opinion and be able to offer improvements.

Our legitimate interest consists in being able to guarantee that our WEB/APP remains secure, as well as in helping CARMEN SAYS to understand the needs, expectations and level of user satisfaction and, therefore, improve services, products and brands. All these actions are carried out in order to improve the level of customer satisfaction and ensure a unique browsing and shopping experience.

TO WHICH RECIPIENTS CAN WE COMMUNICATE THE DATA?

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

• Companies of the CARMEN SAYS Group.
• Administrations and Public Organizations when required by tax, labor, Social Security or any other applicable regulations.
• Companies in charge of data processing (providers of fraud detection and prevention, technological services, customer service, advertising and marketing services, etc.) and, in general, third-party providers that are necessary for the provision of the services offered by CARMEN SAYS (providers of courier and transport services, etc.).

International transfers of data may also take place at the headquarters of the previous assignments/communications for which CARMEN SAYS will use the Standard Contractual Clauses adapted by the European Commission and the EU-US Privacy Shield. as a guarantee for those transfers made to countries that do not have an adequacy decision from the European Commission. In any case, the third parties with whom certain personal data is shared will have previously accredited the adoption of appropriate technical and organizational measures for the correct protection of the same.

CARMEN SAYS does not sell customer data to third parties in any case.

HOW DOES CARMEN SAYS PROTECT PERSONAL DATA?

The WEB/APP uses information security techniques such as firewalls, access control procedures and cryptographic mechanisms, all with the aim of preventing unauthorized access to data and guaranteeing their confidentiality. To achieve these purposes, the user accepts that CARMEN SAYS obtains data for the purpose of the corresponding authentication of access controls.

Additionally, any transaction made through the WEB/APP is carried out through secure payment systems. Confidential payment data is transmitted directly and encrypted (SSL) to the corresponding entity.

CARMEN SAYS declares that it has adopted all the necessary technical and organizational measures to guarantee the security and integrity of the personal data it processes, as well as to prevent its loss, alteration and/or access by unauthorized third parties.

WHAT ARE YOUR RIGHTS IN RELATION TO PERSONAL DATA?

You have the following privacy rights that can be exercised through the email address [hello@carmensays.com]:

Right of access You have the right to obtain confirmation as to whether or not at CARMEN SAYS we are processing personal data that concerns you, as well as to access the personal data that CARMEN SAYS has about you. Right of rectification You have the right to request that CARMEN SAYS rectify the data personal when inaccurate or complete when incomplete. If you are registered on our WEB/APP, it may be easier for you to correct them directly by modifying your profile. Right of deletion/right to be forgotten You can request that personal data be deleted when, among other reasons, the data is no longer necessary for the purposes for which they were collected.Right of limitationYou have the right to request the limitation of data processing, in which case we will only keep them for the exercise or defense of claims.Right of portabilityYou have the right to receive personal data in a structured format, of common use and mechanical reading, and transmit them to another person in charge when the treatment is based on consent or a contract, and is carried out by automated means Opposition right You can oppose that personal data is subject to treatment based on the public or legitimate interest pursued by CARMEN SAYS, including profiling. In this case, CARMEN SAYS will stop processing the data, except for compelling legitimate reasons or the exercise or defense of possible claims. Automated individual decisions You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects on you or significantly affects you in a similar way. However, it will not be possible to exercise said right in the event that the decision is necessary for the celebration or execution of a contract between you and CARMEN SAYS; is authorized by the law applicable to CARMEN SAYS provided that it establishes adequate measures to safeguard your rights, freedoms and legitimate interests; or is based on your explicit consent. Right to file a claim You have the right to file a claim with the Spanish Data Protection Agency or with the competent local Control Authority.

To process the request, we may ask you to prove your identity.

USE OF OUR WEBSITE

The user undertakes to make appropriate use of the contents of the Web, being obliged to (i) provide truthful and accurate information on the data requested in the registration or ordering form, and keep them updated, whenever they make use of the Website; (ii) not engage in illicit, illegal or contrary to good faith and public order activities; (iii) not disseminate content or propaganda of a racist, xenophobic, discriminatory nature based on race, sex, ideology, religion or that in any way violates morality, public order, fundamental rights, public liberties, honor, the privacy or image of third parties and in general current regulations; (iv) not cause damage to the physical and logical systems of the Web, CARMEN SAYS providers or third parties, nor introduce or spread computer viruses or any other physical or logical systems that are likely to cause damage. previously mentioned; (v) not use the contents of the Web and the information on it to send advertising, or send messages for any other commercial purpose, or to collect or store personal data of third parties; (vi) not try to access and, where appropriate, use the email accounts of other users and modify or manipulate their messages.

CARMEN SAYS reserves the right to make the modifications it deems appropriate on its website without prior notice, being able to change, delete or add both the contents and services provided through it and the way in which they are presented or located. on your portal.

INTELLECTUAL AND INDUSTRIAL PROPERTY

All intellectual and industrial property rights of the Web and its contents, including but not limited to images, sound, audio, video, designs, texts, graphics, logos, icons, color combinations, structure, buttons, as well as software , trade names, trademarks, works, illustrations, photographs or industrial drawings and any other signs susceptible to industrial and commercial use are the property and ownership of CARMEN SAYS or third party owners who have duly authorized their inclusion on the Web.

The reproduction, distribution and public communication, including the method of making them available, of all or part of the contents of the Web, for commercial purposes, in any medium and by any technical means, without the authorization of CARMEN SAYS.

The user undertakes to respect the intellectual and industrial property rights owned by CARMEN SAYS. The user may use the Web and its contents for personal and private use. Any other use is prohibited and will require the user to obtain the prior express and written authorization of CARMEN SAYS. The user must refrain from deleting, altering, evading or manipulating any protection device or security system that was installed on the Web.

RESPONSIBILITY DERIVED FROM THE USE OF THE WEB

CARMEN SAYS is not responsible, in any case, for damages of any nature that could cause, by way of example: errors or omissions in the contents, lack of availability of the portal or the transmission of viruses or malicious or harmful programs in the contents, despite having adopted all the necessary technological measures to avoid it.

From the client's website, it is possible to be redirected to content on third-party websites. Since the provider cannot always control the content entered by third parties on their websites, it does not assume any type of responsibility with respect to such content. In any case, the provider declares that it will proceed to the immediate withdrawal of any content that could contravene national or international legislation, morality or public order, proceeding to the immediate withdrawal of the redirection to said website, informing the competent authorities the content in question.

CARMEN SAYS is not responsible for the information and content stored, by way of example but not limitation, in forums, chats, blog generators, comments, social networks or any other means that allows third parties to publish content independently on the Web. However, CARMEN SAYS makes itself available to all users, authorities and security forces, and actively collaborates in the withdrawal or blocking of all content that could affect or contravene national or international legislation, rights of third parties or morality and public order. In the event that the user considers that there is any content on the Web that could be susceptible to this classification, please notify the Web administrator immediately.

The Web has been reviewed and tested so that it works correctly. In principle, correct operation can be guaranteed 24 hours a day, 7 days a week, all year round. However, CARMEN SAYS does not rule out the possibility that there are certain programming errors, or that force majeure, natural disasters, strikes, or similar circumstances occur that make access to the Web impossible.

The introduction of hyperlinks for commercial purposes on web pages outside of CARMEN SAYS that allow access to the Web is prohibited, without the prior consent of CARMEN SAYS.

CARMEN SAYS is not responsible for the use or content of third-party web pages that may link to CARMEN SAYS.com.