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Privacy Policy

WHO IS THE CONTROLLER OF YOUR DATA?

We are Carmens Imports S.L and we process your personal data as joint controllers. This means that we are jointly responsible for how we process and protect your data. Your data controller is CARMENS IMPORTS SL, company currently operating in EUROPE AND UNITED STATE with the sale of LE POMMIERE brand products:

Postal address: Ramon I Cajal 41 street, floor 4, door 2, Tarragona, 43001, Spain. E-mail of Data Protection Officer: info@lepommiere.com , lepommiere@gmail.com.

In other words, CARMENS IMPORTS S.L. is Controller of the data. This means that we have regulated and we are responsible for processing and protecting your personal data.

WHY WE PROCESS YOUR PERSONAL DATA?

We will use your data (collected online or in person), among other purposes, to manage your registration as a user, to manage your purchases of products or services, to respond to your queries, and, if you wish, to send you our customized communications.

Depending on the purpose for which we process your data from time to time, as explained above, we need to process one or other data, which will in general be, depending on each case, as follows:

      • Your identity data (for example, your name, surname, language and country from which you interact with us, contact data, );
      • Economic and transactions information (for example, your payment or card data, information on your purchases, orders, returns, );
      • Connection, geolocation and/or browsing data (if you interact with us from your mobile phone, for example);
      • Commercial information (for example, if you have subscribed to our newsletter),
      • Information about your tastes and preferences.

Remember that, 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 user registration or may not be able to enjoy those services or functionalities.

Depending on how you interact with our Platform, i.e., depending on the services, products or functionalities that you wish to enjoy, we will process your personal data for the following purposes:

1. To manage your registration as user of the Platform

If you decide to become a registered user of our Platform, we need to process your data to identify you as a user of the Platform and grant you access to its various functionalities, products and services available to you as a registered user. You may cancel your registered user account by contacting us through Customer Support.

2. For the development, performance and execution of the purchase or services contract that you executed with Us on the Platform

This purpose includes processing your data, mainly:

      • To contact you for updates or informative notices related to the contracted functionalities, products or services, including quality surveys and to be able to establish the degree of customer satisfaction with the provided service;
      • To manage payment of the products that you purchase, regardless of the payment procedure used. For example:
        • If on purchasing any of our products through the Website or the App, you opt to activate the functionality of save your card data for future purchases, we need to process the indicated data for activation and development of that functionality. Consent to the activation of this functionality enables your autocompleted payment data to appear in subsequent purchases so that you do not need to introduce them in each new process, and these data will be deemed valid and effective for subsequent purchases. You may change or cancel your cards at any time through the section on payment information, either of your Website registered user account.
        • If you use the Wallet functionality of the App to pay your face-to- face purchases, we need to process your data to activate it, so that you may start your purchases at the brick-and-mortar stores of LE POMMIERE enabled for  the purpose.
      • Activate the necessary arrangements in order to control and prevent potential fraud against you and against us during the purchase process. If we consider that the transaction can be fraudulent, this processing may cause the blocking of the transaction.
      • To manage potential returns after you have purchased and manage requests of availability information for articles, reservations of products through the Platform, depending on the availability of such options from time to
      • For invoicing purposes and to make available to you the tickets and invoices of the purchases you have made through the Platform.
      • To ensure that you are able to use other available functionalities or services, such as the purchase, management and use of the Gift Card or of the Gift Voucher, and to afford you access and use of the Wi-Fi that we make available to our customers at Brick-and-Mortar
      • If you are a user of the InWallet App of the Inditex Group (“InWallet”) and you have requested to link the account you have on this Platform to your InWallet account, you authorize us to share the information related to your orders and returns of online purchases. The information collected by the InWallet App is subject to its own terms and policies, which we suggest you to review

3. To meet requests or applications that you make through the Customer Support channels

We only process the personal data that are strictly necessary to manage or resolve your request or application.

If you decide to use WhatsApp as a channel to communicate with Customer Support, we will share your telephone number with WhatsApp Inc. to confirm that you are a user of this service. We recommend you to review your privacy settings and to read WhatsApp privacy policy to obtain more detailed information about the use that WhatsApp makes of the personal data of the users that use their services.

4. For marketing purposes.

This purpose includes the processing of your data, mainly, for:

      • If and when you subscribe to our Newsletter, we will process your personal data to manage your subscription, including to send customised information on our products or services through various means (such as e-mail or SMS). We may also make available to you this information through push notifications in case you have activated them in your mobile device.
        • Accordingly, please take into account that this data processing implies analysis of your user or customer profile to establish your preferences and therefore which products and services are most fit to your style when sending you information. For example, based on your purchases and browsing history (i.e., depending on the articles that you clicked), we will make you suggestions on products that we believe may interest you and, if you are a registered user, we will provide you with the “recover cart ” functionality.
        • Remember that you may unsubscribe from the Newsletter at any time without cost through the “Newsletter” section of the Platform, in addition to through the instructions that we provide you with in each notice. If you do not want to receive push notifications, you can deactivate this option in your mobile
      • To perform promotional actions (for example, for the organization of competitions or to send the list of items stored to the e-mail you designate). On participating in any promotional action, you authorise us to process the personal data that you have shared with us depending on the promotional action and disclose them through different media such as social networks or the Platform itself. In each promotional action in which you participate you will have available the terms and conditions where we will be providing more detailed information about the processing of your personal

To disseminate in the Platform or through our channels in the social networks photographs or pictures that you shared publicly, provided that you expressly give us your consent for the purpose.

5. Analysis of usability and quality to improve our services

If you access our Platform, we inform you that we will treat your browsing data for analytic and statistic purposes, i.e., to understand the manner in which users interact with our Platform and thus be capable of introducing improvements in the Platform.

In addition, we occasionally perform quality surveys and actions to know the degree of satisfaction of our customers and users and detect those areas in which we may improve.

HOW WE ARE LEGALLY PERMITTED TO PROCESS YOUR DATA?

The legal terms on which we are permitted to process your personal data also depends on the purpose for which we process them, as explained in the following lines:

1. To manage your Platform user registration

We process your data because this is necessary on the terms regulating the use of the Platform. In other words, for you to be able to register as a user on the Platform, we need to process your personal data, since we would otherwise be unable to manage your registration

2. 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 authorise it, as is the case of the storage of payment (card) data for future purchases or the processing of data necessary to scan the till receipts through the Wallet section of the App or to provide you with the Coming Soon / Back Soon functionalities. 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 when you make a purchase. We understand that the processing of these data is positive for all the participating parties when a purchase is paid and in particular for you, since this allows us to establish measures to protect you from fraud attempts by third parties

3. 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.

4. Marketing

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 authorizing the sending of push notifications in your mobile device 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.

In order to show you customized information. 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.

5. Analysis of usability and quality

We consider that we have a legitimate interest in analysing the Platform usability and the user’s satisfaction degree, since we understand that that the processing of these data is also beneficial for your because the purpose is to improve the user experience and provide a higher quality service

HOW LONG WILL WE KEEP YOUR DATA?

The time for which we will keep your data will depend on the purposes for which we process them, as explained below:

1. To manage your Platform user registration

We will process your data for the time during which you remain a registered user (meaning, until you decide to unsubscribe).

2. Development, performance and execution 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.

3. Customer Support

We will process your data for the time necessary to meet your request or application.

4. Marketing

We will process your data until you unsubscribe or cancel your subscription to the newsletter.

If you participate in promotional actions, we will keep the data during a six (6) months period from the end of the action.

5. 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 anonymise 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?

We do not share your data with any company or business partner. No one has access to your information for any type of activity, support or services, such as:

    • financial institutions,
    • anti-fraud detection and prevention entities,
    • technological service providers,
    • logistic, transport and delivery partners and service providers,
    • providers of customer support related services,
    • advertising and marketing related partners and service

WHAT    YOUR    RIGHTS    ARE    WHEN    MAKING    YOUR    DATA AVAILABLE TO US

We undertake to keep your personal data confidential and to ensure that you may exercise your rights. Bearing that in mind, we Joint Controllers have agreed that you may exercise your rights free of charge by writing us an e-mail to a single e-mail address (info@lepommiere.com , lepommiere@gmail.com), 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 where you are a Platform registered user you may also consult this information in the relevant section of your online account.
    • 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 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
    • To request that we cancel or limit the processing of your personal data, which entails that in certain cases you can request us to temporally suspend the processing of the data or that we keep them longer that necessary.

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 2 where we explain for which purposes we process your data.

When we are legally permitted to process your data due to your consent or to for the purposes of a contract, as explained in section 3, you will also have the right to request the portability of your personal data. This means that you will have the right to receive the personal data that you made available to us in a structured, commonly used and machine-legible format, to be able to transmit them to another entity directly without impediments on our part.

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.

Finally, we inform you that you have the right to file a claim before the responsible data protection

regulatory authority, in particular, before the:

 

WHAT HAPPENS WHEN YOU PROVIDE US WITH DATA OF THIRD PARTIES?

We offer functionalities or services that require us to process the personal data of a third party that you must provide, such as in the case of activation and sending of the Gift Voucher or the management of the application for the Gift Voucher. If you provide us with personal data of third parties, you confirm that you informed them of the purposes and of the manner in which we need to process their personal data.

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

We use cookies and similar devices to facilitate your browsing in the Platform, understand how you interact with us and, in certain cases, to be able to show you advertisements in accordance with your browsing habits. Please read our Cookies Policy to understand with greater detail the cookies and similar devices that we use, their purpose and other information of interest.

Information about Cookies

 What is a Cookie?

A Cookie is a small text file that a website stores on your PC, telephone or any other device, with information about your navigation on that website. Cookies are necessary to facilitate browsing and to make it more user-friendly, and they do not damage your computer.

While this Policy uses the general term “Cookies”, as they are the main method for storing information used by this website, the browser’s “Local Storage” space is also used for the same purposes as the Cookies. All the information included in this section is also applicable to this “Local Storage”.

What are Cookies used for on this website?

Cookies are an essential part of how our website works. The main purpose of our Cookies is to improve your browsing experience. For example, they are used to remember your preferences (language, country, etc.) while browsing and on future visits.

The information collected by the Cookies also enables us to improve the site by estimating numbers and patterns of use, the suitability of the website to the individual interests of the users, quicker searches, etc. On occasion, if we have obtained your informed consent in advance, we may use Cookies, tags or other similar devices to obtain information that enables us to show you, either from our own website or from third-party websites or any other means, advertising based on the analysis of your browsing habits.

What are Cookies NOT used for on this website?

We do not store sensitive personal information, such as your address, your password, your credit or debit card data, etc. in the Cookies we use.

Who uses the information stored in Cookies?

The information stored in the Cookies from our website is used exclusively by us, except for those identified below as “third-party cookies”, which are used and managed by external entities to provide services requested by us to improve our services and the experience of the user when browsing our website. The main services for which these “third-party cookies” are used are to obtain access statistics and to guarantee the payment transactions that are carried out.

How can I avoid using Cookies on this website?

If you prefer to avoid the use of Cookies on this page, taking into account the above-described limitations, you must first disable the use of Cookies in your browser and then delete the Cookies saved in your browser associated with this website.

You may use this option for preventing the use of Cookies at any time.

How do I disable and prevent the use of Cookies?

You may restrict, block or delete the Cookies from this website at any time by changing the configuration of your browser following the steps indicated below. While the settings are different in each browser, Cookies are normally configured in the “Preferences” or “Tools” menu. For further details on configuring Cookies in your browser, see the “Help” menu in the browser itself

Which particular Cookies does this website use and for what purpose?

The chart below shows the Cookies, tags and other similar devices used by this website, together with information on the purpose, duration and management (proprietary and by third parties) of each one of them.