PRIVACY POLICY

OUR PRIVACY POLICY AT A GLANCE

  1. ABOUT US? We are INTRATEGIA LIMITED (NO930779792 ) and we process your personal data as joint controllers . This means that we are jointly responsible for how to use and protect your data.
  2. WHAT DO WE USE YOUR DATA FOR? We will use your data (obtained online or in person), among other purposes, to manage your registration as a user, manage the purchase of products or services, answer your queries, as well as, if you wish, to send you our communications.
  3. WHY DO WE USE THEM? We are entitled to process your data for different reasons. The main thing is that we need to process it to execute the contract that you accept with us when you register and when you make a purchase or enjoy any of our services or functionalities. We also use your data for other reasons, for example, to respond to your queries or to send you newsletters that you have requested to receive.
  4. WITHWHO WE SHARE YOUR DATA? We will share your data with service providers that help or support us, whether they are companies within the Group itself or external collaborators with whom we have reached an agreement to subcontract/delegate marketing management services.
  5. YOUR RIGHTS. You have the right to access, rectify or delete your data In some cases, you also have other rights, for example, to object to our use of your data or to port it, as we explain in detail below.

We invite you to read our full Privacy and Cookies Policy below to understand in detail how we will use your personal data and the rights you have in relation to it.

BEFORE STARTING

  • In this Privacy and Cookies Policy you will find all the relevant information that applies to the use we make of the personal data of our clients and users, regardless of the channel or medium (online or in person) you use to interact with us.
  • If you want information about how we use cookies and other similar devices that may be installed on the terminals of our clients and users, we recommend that you consult the Privacy Policy.
  • We are transparent about what we do with your personal data, so that you understand the implications of the uses we carry out or the rights you have in relation to your data:
    • We permanently put at your disposal all the information in this Privacy and Cookies Policy that you can consult whenever you deem appropriate and also,
    • You will also find information about each processing of your personal data

as you interact with us .

  • Some names that we will use in this Privacy and Cookies Policy:
    • When we talk about our Platform , we will generally refer to any of the channels

or digital or in-person means that you have used to interact with us. The main ones are:

  • Our web .
  • Social networks.
  1. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR DATA?

Those responsible for processing your data:

  • INTRATEGIA LIMITED
    • Postal address: Oscar Gate 27 Oslo CP, 0352 Norway.
    • Email of the Data Protection Officer :trabajodatos@intrategia.net
  1. FOR WHAT PURPOSE DO WE PROCESS YOUR PERSONAL DATA?

Depending on the products, services or functionalities that you want to enjoy at any given time, we will need to process some data or others, which in general will be, depending on the case, the following:

  • your identifying data (for example, your name, surname, image, language and country from which you interact with us, contact information);
  • economic and transactional information (for example, your payment or card information, information about your purchases, orders, returns,);
  • connection, geolocation and browsing data (for example, location data, device identification number or advertising ID);
  • commercial information (for example, if you are subscribed to our newsletter ),
  • data 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 some fields as mandatory , since they are data that we need to be able to provide you with the service or give you access to the functionality in question. Please keep in mind that if you decide not to provide us with this data, you may not be able to complete your user registration or you may not be able to enjoy those services or functionalities.

In other cases, we may passively obtain information by using tracking tools, such as browser cookies or other similar technologies from our Platform or from communications we send to you. In certain cases, a third party may have provided us with information about you when using a feature or service of the Platform, for example, if they have sent you a gift card or if they send an order to your address.

In such cases, we will only process your data in relation to that functionality or service, in accordance with the provisions of this Privacy and Cookies Policy.

Depending on how you interact with our Platform, we will process your personal data for the following purposes:

 

PURPOSE : + info

  1. If you decide to register as a user on our Platform, we need to process your data to identify you as a user of it and give you access to its different functionalities, products and services that are at your disposal as a registered user. You can cancel your registered user account by contacting us through Customer Service.

We inform you that the data we collect about your activity, obtained through the different channels of the Platform, and which includes your purchases, will remain linked to your account so that all the information can be accessed at once.

  1. For the development, compliance and execution of the sales contract or services that you have contracted with Us on the Platform . This purpose includes the processing of your data to, mainly:
  • Contact you in relation to updates or informative communications related to the contracted functionalities, products or services , including sending quality surveys about the products or services provided.

Manage payment for the products you purchase, regardless of the payment method used. For example:

  • If when purchasing any of our products through the Website or the App, you choose to activate the functionality of saving your payment details and your shipping address for future purchases (if this functionality is available), we need to process the data indicated for the activation and development of said functionality. Consent to activate this functionality allows your auto-completed payment details to appear in subsequent purchases so that you do not have to re-enter them in each new process, and they will be considered valid and current for subsequent purchases. You can modify or delete your payment information at any time through the section corresponding to payment information, either in your registered user account on the Website or in the My Account section of the App.
  • If the functionality of the App to pay for your in-person purchases is available, and you decide to use it, we will need to process your data to activate it so that you can start making your purchases in the Physical Stores enabled for this purpose.
  • Activate the necessary mechanisms in order to prevent and detect improper use of the Platform, for example, during the purchase and return process , as well as potential fraud against you and/or against Us. If we consider that the operation may be fraudulent or we detect abnormal behavior with indications of fraudulent use of our functionalities, products and services, this treatment may have consequences such as blocking the transaction or canceling your user account.
  • Manage possible changes or returns once you have made a purchase and manage requests for information about the availability of garments , product reservations through the Platform, depending on how these options are available at all times.
  • For billing purposes and to make available to you the tickets and invoices for the purchases you have made on the Platform.
  • Guarantee the use of other functionalities or services to the extent they are available , such as the purchase, reception, management and use of the Gift Card or Gift Ticket , as well as to facilitate access and use of the Wifi that we make available to our customers. customers in Physical Store.

Intrategia Limited (” InWallet “) InWallet App and have requested to link the account you have on this Platform to your InWallet account , you authorize us to provide the information

related to your orders and returns of online purchases. The information collected by the InWallet App is subject to its own conditions and policies, so we recommend that you review them.

  • In order to offer you certain services through the App (such as the item search, fitting room reservation, etc.), available in some Physical Stores, we need to process your location and contact data.

 

  1. To respond to requests or requests that you make through the Customer Service channels . We only process personal data that is strictly necessary to manage or resolve your request or request.
  • If you use the telephone channel, the call may be recorded to attend to your request and guarantee its quality.
  • If available, and you decide to use WhatsApp as a channel to communicate with Customer Service, we will provide your phone number to WhatsApp Inc. (a company located in the USA) to verify that you are a user of this service. We recommend that you review your privacy settings and read WhatsApp’s privacy policy for more detailed information about WhatsApp’s use of the personal data of users who use its services.
  • If available, and you decide to contact Customer Service through the chat service of a social network or other partner, some of your data, such as your name or username, will be imported from your social network or partner account. . Likewise, you must bear in mind that the data you enter in this service will be available to your social network or collaborator and will be subject to their corresponding privacy policies. Therefore, we recommend that you review your privacy settings and read the privacy policy of the social network or partner to obtain detailed information about how they use your personal data when using their services.
  1. For marketing purposes : This purpose includes the processing of your data to, mainly:
  • Personalize the services we offer you and be able to make recommendations based on your interaction with us on the Platform and the analysis of your user profile (for example, based on your purchase and browsing history).
  • To the extent that you subscribe to our Newsletter , we will process your personal data to manage your subscription , including sending personalized information about our products or services through various means (such as email or SMS). Likewise, we may send you this information through push notifications if you have activated them on your device.
  • Therefore, keep in mind that this data processing involves the analysis of your user or customer profile to determine what your preferences are and therefore what products and services may be that best fit your style when sending you information. For example, based on your purchase and browsing history (namely, based on the items you have clicked on ) , we will make suggestions about products that we think may interest you and, if you are a registered user, we will provide you with the “cart recovery” functionality.
  • Remember that you can unsubscribe from the Newsletter at any time and free of charge through the “ Newsletter ” section of the Platform, in addition to through the instructions that we provide you in each communication. If you do not want to receive push notifications , you can disable this option on your device.
  • Show you advertising on the Internet that you can see when you browse websites and apps, for example, on social networks. The advertising you see may be displayed randomly, but on other occasions it is advertising that may be related to your purchase history, preferences and browsing.
  • If you are a user of social networks, we may provide those with whom we collaborate with certain information so that they can show you advertisements from our brand and, in general, offer you or other similar users, advertising taking into account your profile on said networks. social. If you want information about the use of your data and the operation of advertisements on these social networks, we recommend that you review the information about your privacy on the social networks in which you participate.
  • Additionally, we use your data to carry out measurement and segmentation analysis of the ads that we show to users on some partner platforms. To do this, we collaborate with these third parties who offer us the necessary technology (for example, through cookies, pixels, SDK) to use these services. Please note that, although we do not provide personal identifying data to these collaborators, we communicate some unique identifier (for example, the advertising identifier associated with the device, a cookie identifier, etc. ). If you want more information about this, please review our Cookies Policy. You can also reset your advertising identifier or disable ad personalization on your device by modifying your preferences in the settings section of your device.
  • Data enrichment: Where we obtain your personal data from various sources, we may combine it in certain circumstances in order to improve our understanding of your needs and preferences in relation to our products and services (including for the purposes of analysis, generation of usage profiles, marketing studies, quality surveys and improving interaction with our customers). We refer, for example, to the combination of information that we can do if you have a registered account and, with the same email address as the one linked to your account, you make purchases as a guest; or to information collected automatically (such as IP addresses, MAC addresses or metadata) that we can link with information that you have provided to us directly through your activity on the Platform or in any of our stores (for example, information related to your purchases, whether whether in physical stores or in the online store, your preferences).
  • Carry out promotional actions (for example, to develop contests or send your list of saved articles to the email address you indicate). By participating in any promotional action, you authorize us to process the data you provide us based on each promotional action and we can communicate it through various means such as social networks or on the Platform itself. In each promotional action in which you participate, you will have available the legal bases where we will provide you with more detailed information about the processing of your data.

Disseminate on the Platform or through our social media channels photographs or images that you have shared publicly, as long as you give us your consent to do so.

 

  1. Usability and quality analysis to improve our services If you access our Platform, we inform you that we will process your browsing data for analytical and statistical purposes , that is, to understand the way in which users interact with our platform. Platform and with the actions that we can carry out on other websites and apps and thus be able to introduce improvements.

Likewise, sometimes we carry out quality actions and surveys aimed at knowing the degree of satisfaction of our clients and users and detecting those areas in which we can improve.

  1. WHAT IS THE LEGITIMATION FOR THE PROCESSING OF YOUR DATA?

The legal basis that allows us to process your personal data also depends on the purpose for which we process it, as explained in the following table:

Purpose Legitimation:

  1. Manage your registration as a user of the Platform The processing of your data is necessary for the execution of the terms that regulate the use of the Platform. In other words, in order for you to register as a user on the Platform, we need to process your personal data, since otherwise we would not be able to manage your registration.

We consider that we have a legitimate interest to link your purchases and the data we collect about your activity through the different channels of the Platform to your account.

  1. Development, compliance and execution of the sales or services contract The processing of your data is necessary for the execution of the sales or services contract that links us to you.

It is possible that some data processing associated with the purchase process is activated only because you request it or authorize us, such as the storage of payment data for future purchases or the data processing necessary to scan purchase receipts through the Wallet section of the App or to inform you of the availability of our products (if this functionality is available). In these cases, the basis on which we process your data is your own consent . In addition, we process your location data when you give us your consent, to offer you specific services through the App when you visit some of our Physical Stores.

We consider that we have a legitimate interest to carry out the necessary checks to detect and prevent possible fraud or fraudulent use when you use the Platform, for example, when making a purchase or return. We understand that the processing of this data is positive for all parties: for you, as it allows us to put measures in place to protect you against fraud attempts by third parties; for Us, because it allows Us to prevent improper use of the Platform; for all our clients and society, because it also protects their interest in ensuring that fraudulent activities are discouraged and detected when they occur.

  1. Customer Service We consider that we have a legitimate interest in responding to the requests or queries that you submit to us through the various existing means of contact. We understand that the processing of this data is also beneficial for you as it allows us to serve you appropriately and resolve any queries raised.

When you contact us, in particular, to manage incidents related to your order or the product/service purchased through the Platform, the processing is necessary for the execution of the sales contract .

When your query is related to the exercise of the rights about which we inform you below, or to claims related to our products or services, what legitimizes us to process your data is compliance with legal obligations on our part.

  1. Marketing The legitimate basis for processing your data for marketing purposes is the consent you give us, for example: when you agree to receive personalized information through various means, when you authorize the sending of push notifications on your device, when you give your consent through the configuration of cookies or the privacy of your device, or when you accept the legal bases to participate in a promotional action or to publish your photographs on the Platform or on our social media channels.

To offer you personalized services or show you personalized information, whether on our Platform or that of third parties, as well as to carry out data enrichment, we consider that we have a legitimate interest to perform profiling with the information we have about you (such as the browsing you do, preferences or purchase history) and the personal data that you have provided us such as age range or language, since we understand that the processing of this data is also beneficial for you because it allows you to improve your experience as a user and access to information according to your preferences.

  1. Usability and quality analysis We consider that we have a legitimate interest in analyzing the usability of the Platform and the degree of user satisfaction since we understand that the processing of this data is also beneficial for you because the purpose is to improve the user experience. user and offer a higher quality service.
  2. HOW LONG WILL WE KEEP YOUR DATA?

The period of conservation of your data will depend on the purposes for which we process it, as explained below:

Purpose Conservation period:

  1. Manage your registration as a user of the Platform We will process your data for as long as you maintain your status as a registered user (that is, until you decide to unsubscribe).
  2. Development, compliance and execution of the purchase and sale contract or services We will process your data for the time necessary to manage the purchase of the products or services you have purchased, including possible returns, complaints or claims associated with the purchase of the particular product or service. .

On some occasions, we will only process the data until the time you decide, as is the case with payment data that you have asked us to store for possible future purchases (if this functionality is available).

  1. Customer Service We will process your data for as long as necessary to respond to your request or request.
  2. Marketing We will process your data until you unsubscribe or cancel your subscription to the newsletter .

We will also show you personalized ads until you change your device, browser or cookie settings, which will revoke your permission.

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

  1. Usability and quality analysis We will process your data promptly during the time in which we proceed to carry out a specific quality action or survey or until we anonymize your browsing data.

Regardless of whether we process your data for the time strictly necessary to fulfill the corresponding purpose, we will subsequently keep it duly stored and protected for the time in which responsibilities arising from the processing may arise, in compliance with the regulations in force at all times. Once the possible actions are prescribed in each case, we will proceed to delete the personal data.

  1. WILL WE SHARE YOUR DATA WITH THIRD PARTIES?

To fulfill the purposes indicated in this Privacy and Cookies Policy, it is necessary that we give access to your personal data to Intrategia Limitet entities. and to third parties that provide us with support in the services we offer you, namely:

  • financial entities ,
  • fraud detection and prevention entities ,
  • technology and analytics service providers ,
  • suppliers and collaborators of logistics , transportation and delivery services or their associated establishments,
  • service providers related to customer service,
  • suppliers and collaborators of services related to marketing and advertising , such as advertising agencies, advertising partners or social networks that, in certain cases, may act as controllers

For the efficiency of the service, some of the aforementioned providers are located in territories outside the European Economic Area that do not provide a level of data protection comparable to that of the European Union. In such cases, we inform you that we transfer your data with adequate guarantees and always maintaining the security of your data, since we use the most appropriate tools for international data transfer, such as Standard Contractual Clauses or any other relevant complementary measure. You can consult the content of the Standard Contractual Clauses at the following link: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer- personal-data-third-countries_en.

In the event that we sell or transfer all or part of our business or assets to another company whether or not owned by Intrategia Limited , or carry out any other business activity as a result of a corporate reorganisation, we may disclose your personal data to the potential recipient. of the business or assets. In the event of such a sale or transfer, we would make reasonable efforts to have the beneficiary process the personal information you have provided to us in accordance with our Privacy Policy. In this case, we consider that we have a legitimate interest based on the reorganization of our corporate structure.

Furthermore, if you decide to use the Platform in different markets (i.e., creating registered user accounts in different markets with the same email address), we may need to disclose or transfer information related to your account or your activity to the companies of the brand operating in such markets, to the extent that they are directly involved in achieving any of the objectives described in section 2. We consider this necessary to satisfy our mutual interests and preferences.

  1. WHAT ARE YOUR RIGHTS WHEN YOU PROVIDE US WITH YOUR DATA?

We are committed to respecting the confidentiality of your personal data and guaranteeing the exercise of your rights . The Joint Controllers have agreed that you can exercise them free of charge by writing us an email to a single email addresstrabajodatos@intrategia.net simply indicating the reason for your request and the right you want to exercise. If we consider it necessary to identify you, we may request a copy of a document proving your identity.

Likewise, we may offer you the possibility to exercise your rights and configure your privacy preferences when using some of our services or by making specific channels available to you within our Platform.

In particular, regardless of the purpose or legal basis under which we process your data, you have the right to:

  • Ask us for access to the data we have about you. We remind you that if you are a registered user on the Platform you can also consult this information in the section corresponding to your personal data.
  • Ask us to rectify the data we already have. Remember that if you are a registered user on the Platform, you can also access the section corresponding to your personal data in your account to modify or update your personal data. In any case, keep in mind that, by actively providing us with your personal data by any means, you guarantee that they are true and accurate and you agree to notify us of any changes or modifications thereof. Any loss or damage caused to the Platform or to the person responsible for the Platform or to any third party due to the communication of erroneous, inaccurate or incomplete information in the registration forms, will be the exclusive responsibility of the user. Please remember that as a general rule you should only provide us with your own personal data, not those of third parties, except as permitted in this Privacy and Cookies Policy.
  • Ask us to delete your data to the extent that it is no longer necessary for the purpose for which we need to process it as we have informed you above, or that we no longer have the legitimacy to
  • Ask us to limit the processing of your data, which means that in certain cases you can ask us to temporarily suspend the processing of the data or to keep it beyond the necessary time when you can

If you have provided us with your consent to process your data for any purpose, you also have the right to withdraw it at any time . Some of the ways in which you can withdraw your consent are explained in section 2 in which we explain the purposes for which we process your data.

If you do not want information to be sent to third parties to show you ads, you have several ways, such as changing preferences on the device, browser or cookie settings, reviewing the privacy policy and network settings. social networks in which you have a profile or send us an email with your request to the address mentioned above.

When our legitimacy for the processing of your data is your consent or the execution of the 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 have provided to us in a structured, commonly used and machine-readable format, in order to transmit it to another entity directly, whenever technically possible.

On the other hand, when 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 of your right to file a claim with the relevant data protection supervisory authority, in particular, with the Spanish Data Protection Agency ( https://www.agpd.es/portalwebAGPD/index -ides-idphp.php ).

  1. WHAT HAPPENS IF YOU PROVIDE US WITH THIRD PARTY DATA OR IF A THIRD PARTY HAS PROVIDED US WITH YOUR DATA?

We offer functionalities or services that require us to process the personal data of a third party that you as a user or client provide to us, such as for the activation and sending of the Gift Card or the management of the Gift Ticket request (if they are these functionalities are available), or when you authorize a third party to collect an order in our stores or collaborating establishments. If you provide us with Personal Data of third parties or if it is necessary for them to provide it to us due to a third party collecting an order on your behalf, you guarantee that you have informed them about the purposes and the way in which we need to process their personal data.

If a third party has provided us with your data or you have provided it yourself as a result of a functionality or service requested by one of our users, we will use it to manage the functionality or service that is being developed in each case, within the purposes set out in this Privacy and Cookies Policy, whose link we usually include in our communications.

  1. CHANGES TO THE PRIVACY AND COOKIE POLICY

We may modify the information contained in this Privacy and Cookies Policy when we deem it appropriate. If we do so, we will notify you in different ways through the Platform (for example, through a banner, a pop-up or a push notification ), or we will even communicate it to your email address when The change in question is significant for your privacy, so that you can review the changes, evaluate them and, where appropriate, oppose or unsubscribe from any service or functionality. In any case, we suggest that you review this Privacy and Cookies Policy from time to time in case there are minor changes or we introduce any interactive improvements, taking advantage of the fact that you will always find it as a permanent point of information on our Website and our App.

  1. INFORMATION ABOUT COOKIES

We use cookies and similar devices to facilitate your navigation on the Platform, understand how you interact with Us and, in certain cases, be able to show you advertising based on your browsing habits. Please read our Cookies Policy to learn more about the cookies and similar devices we use, their purpose and how to manage your preferences, as well as other information of interest.