- OUR COMPANY We are Oneseven Designs and we process your personal data as joint controllers. This means that we are responsible for how we process and protect your data.
- WHAT WILL BE YOUR DATA USED FOR – 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 customised communications.
- WHY WE NEED YOUR DATA – We have legal standing to process your data for various reasons. The main reason is that we need to process your data to perform 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 asked to receive from us.
- IS YOUR DATA SHARED? – We share your data with service providers who provide us with assistance or support and third party providers.
- WHAT ARE YOUR RIGHTS. You have the right to access, rectify or delete your personal data. In certain cases, you are also entitled to other rights, such as, for example, to object to us using your data, or to transferring your data, as explained in depth below.
BEFORE YOU START
1. WHO IS THE CONTROLLER OF YOUR DATA?
The data controllers are:
- In this Privacy and Cookies Policy, you will find all relevant information applicable to our use of our users’ and customers’ personal data, regardless of the channel or means (online ) that you use to interact with us.
- We are transparent about what we do with your personal data, to help you to understand the implications of the way in which we use your data, and the rights you are entitled to in relation to your data:
- We permanently make available for you all the information included in this Privacy and Cookies Policy, that you can check when you consider appropriate, and in addition,
- You will also find further information on how we use your data as you interact with us.
- These are some terms we regularly use in this Privacy and Cookies Policy:
- When we speak about our Platform, we refer, in general, to any of the channels or means, digitally you may have used to interact with us – Our Website.
- ONESEVEN DESIGNS who owns and maintains the brand One7 Store
- Postal address: 403-555 River Avenue,Winnipeg, Manitoba. R3L0E3 Canada.
- E-mail address : firstname.lastname@example.org
In other words, Oneseven Design is the data Controller of the data. This means that we are responsible for processing and protecting your personal data.
2. WHY DO WE PROCESS YOUR PERSONAL DATA?
Depending on the purpose for which we process your data from time to time, as explained below, 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, image, language and country from which you interact with us, contact data, etc.);
- economic and transactions information (for example, your payment or card data, information on your purchases, orders, returns, etc.);
- connection, geolocation and/or browsing data (for example, the location data, the device identification number or the advertising ID, etc.);
- 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.
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.
In other cases, we may collect information passively, as we may use tracking tools like browser cookies and other similar technology on our Platform and in communications we send you.
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:
I. 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 Service.
We hereby inform you that the data we gather regarding your activity, which have been collected through the different channels of the Platform and which include your purchases, shall remain linked to your account so that all the information can be accessed together.
II. 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 payment data and your shipment address for future purchases, where this functionality is available, 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 payment data at any time through the section on payment information, either of your Website registered user account.
- To activate the mechanisms necessary to prevent and detect unauthorised uses of the Platform (for example, during the purchase and returns process) as well as potential fraud being committed against you and/or against us. If we consider that the transaction may be fraudulent or we detect abnormal behaviour which indicates attempted fraudulent use of our features, products or services, this processing may result in consequences such as the blocking of the transaction or the deletion of your user account.
- To manage potential exchanges or 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 time.
- 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, receipt, 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 Stores.
III. To meet requests or applications that you make through the Customer Service channels:
We only process the personal data that are strictly necessary to manage or resolve your request or application.
If you contact us via telephone, the call may be recorded for quality purposes and so that we can respond to your request.
If it is available and you choose to communicate with Customer Support through the chat service of a social network or another collaborator, some of your personal data such as your name or user name, will be imported from your social network or collaborator account. Also, bear in mind that the data you submit on this service will be available to your social network or collaborator and subject to their privacy policies, therefore We recommend you to review your privacy settings and to read the social network or collaborator privacy policies to obtain more detailed information about the use they make of your personal data when using their services.
IV. For marketing purposes.
This purpose includes the processing of your data, mainly, for:
- Personalise the services we offer you and enable us to give you recommendations based on your interactions with us on the Platform and an analysis of your user profile (for example, based on your purchase and browsing history).
- 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 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 device.
- Show you ads on the Internet which you may see when visiting websites and apps, for example, on social media. The ads you see may be random, but on other occasions they may be ads related to your preferences or purchase and browsing history.
If you use social media, we may provide the companies with which we collaborate certain information so that they, as joint controllers,
can show you our brand ads and, in general, offer you and users like you advertisements which take into account your profile on said social media sites. If you want information about the use of your data and how advertising works on social media, we recommend you review the privacy policies of the social media sites on which you have profiles.
- We also use your data to carry out measurement and segment analyses on the ads which we show users on some of our collaborators’ platforms. To do this we collaborate with these third parties who offer us the necessary technology (for example, cookies, pixels, SDK) to use these services. Keep in mind that we may need to provide them with certain information or some form of identifier each time (for example, the advertising ID associated with the device, an identifier associated with a cookie, etc.) If you would like more information in this respect, please review our Cookies Policy. Likewise, you can reset your advertising ID or disable personalised ads on your device, adjusting your preferences in settings section of your device.
- Data enrichment: When we gather your personal data from a variety of sources, we may consolidate them under certain circumstances for the purpose of improving our understanding of your needs and preferences related to our products and services (including for the purposes of analyses, generating user profiles, marketing studies, quality surveys and improving our interactions with our customers). This refers, for example, to the way we may combine your information if you have a registered account and, using the same email linked to your account, you make a purchase as a guest, or to information which is automatically compiled (such as IP and MAC addresses or metadata) which we may link with the information you have provided us directly through your activity on the Platform or in any of our stores (for example, information related to your purchases, whether in brick- and-mortar stores or online, your preferences, etc.).
- 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 data.
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.
V. 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 with the actions we implement on other websites and apps, so we can improve our services.
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.
3. HOW ARE WE 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:
4. HOW LONG WILL WE KEEP YOUR DATA?
- 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.
We consider we have a legitimate interest to link to your account your purchases and the data collected through different channels of the Platform about your activity.
- 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 data for future purchases or the processing of data necessary to scan the till receipts through the Wallet section of the Website or to provide you with the Coming Soon / Back Soon functionalities, where these features are available. In these cases, our processing of your data is supported by your own consent. In addition to this, we process your location data when you provide us your consent in order to offer you specific services through the App when visiting some of our Brick and Mortar Stores.
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 unauthorised 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.
- 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 device, when you configure it in the privacy settings of your device, when you consent through the cookies settings 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 personalised services or to show you customised 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 analysing 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.
The time for which we will keep your data will depend on the purposes for which we process them, as explained below:
- 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).
- 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 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.
- Marketing:We will process your data until you unsubscribe or cancel your subscription to the newsletter.
Likewise, we will show you personalised ads until you change your device, browser and/or cookies settings so 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 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.
5. 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 your, i.e.:
- financial institutions,
- anti-fraud detection and prevention entities,
- technological and analytical service providers,
- providers and partners of services related to logistic, transport and delivery and/or their partner establishments,
- providers of customer support related services,
- service providers and collaborators related to marketing and publicity, such as advertising agencies, advertising partners or social media that in certain cases may act as joint controllers.
For service efficiency purposes, some of these providers are located in territories outside the European Economic Area that do not offer 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 safeguards and always keeping your data safe, using the most convenient international data transfer tools, in example the Standard Contractual Clauses and any relevant supplementary measures. You may consult the content of such Standard Contractual Clauses through 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 a portion of our business or assets to other company within or outside OneSeven Designs, or have any other business operation implemented as a consequence of corporate reorganizations, we may disclose your personal data to the prospective receptor of such business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with our Privacy and Cookies Policy. In this case, we consider that we have legitimate interest consisting on the reorganization of our corporate structure.
Furthermore, if you choose to use the Platform in different markets (i.e. by creating registered user accounts in different markets with the same e-mail address), We may need to disclose or transfer the information linked to your account or your activity to the companies of the brand operating in those markets, to the extent they are directly involved in the achievement of any of the purposes described in the section 2. We consider this is necessary in accordance with our mutual interests and preferences.
6. WHAT ARE YOUR RIGHTS WHEN MAKING YOUR DATA AVAILABLE TO US?
We undertake to keep your personal data confidential and to ensure that you may exercise your rights. You may exercise your rights free of charge by writing us an e-mail to our e-mail address (email@example.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 addition, we may offer you with the possibility to exercise your rights and setting your privacy preferences when using some of our services, or by making available specific channels within our Platform.
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 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 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 than 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.
Should you not wish us to send information to third parties to show you ads, you can do it through several means such as changing your preferences on your device changing your preferences on your device, browser and/or cookies settings, reviewing the privacy policies and settings of the social media sites on which you have profiles or sending us an email to the above mentioned email address informing us of your request.
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.
7. WHAT HAPPENS WHEN YOU PROVIDE US WITH DATA OF THIRD PARTIES 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 as a customer, must provide, such as in the case of activation and sending of the Gift Card, the management of the application for the Gift Voucher (where these features are available), or when you authorise a third party to collect an order in our stores or partner establishments. 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.
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.
8. 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.
INFORMATION ON COOKIES
BEFORE YOU START
INFORMATION ABOUT COOKIES
What is a Cookie?
A cookie is a small text file that a website, app or other platform stores on your computer, tablet, smartphone or any other similar device, with information on your browsing and use, like a tag that identifies your device. Cookies are necessary, for example, to facilitate browsing and understand how users interact with platforms so they can be improved. They are also useful to provide advertising according to user preferences, as well as for other purposes detailed below. Cookies do not damage your computer or device.
By “Cookies” we are also referring to other, similar technologies used to install and/or collect information on or from your device such as flash cookies, web beacons or bugs, pixels, HTML5 (local storage), and SDK technologies for apps. The term Cookies also applies to the use of fingerprinting, in other words, techniques used to combine information that help us identify your device. These technologies sometimes run alongside cookies to collect and store information, either to provide you with certain features or services on our Platform, or to display third-party advertising according to your browsing.
This explanation is a general overview of what Cookies means and is for informational purposes only. The specific Cookies we use are detailed in the cookies settings panel on our Platform.
What type of Cookies are there?
Please check this section which provides an overview of the type of Cookies that can be used in an online environment.
Cookies can be classified as follows, depending on the owner:
- First-party cookies: Are sent to the user’s computer or device from a computer or domain managed by the editor, and which provides the platform or service requested by the user.
- Third-party cookies: Are sent to the user’s computer or device from a computer or domain not managed by the editor, but rather by another entity that processes data obtained from the cookies.
Cookies can be classified as follows, depending on the purpose:
- Strictly necessary cookies (technical): The cookies that allow the user to browse a website, platform or app, and use the various options or services on it. For example, control traffic, identify data or session, access restricted access sections or content, remember the elements of an order, complete an order purchase process, manage payment, control fraud related to service security, use security elements during browsing, complete an application to register or participate in an event, store content for publishing videos and audio,
enable dynamic content (for example, loading animation of a text or image) and share content on social media. As they are strictly necessary, technical cookies are downloaded by default when they are needed to display the platform or provide the service requested by the user.
- Functionality or customisation cookies: These cookies are needed to remember information so that the user can access the service or platform with specific characteristics that can differentiate their experience from that of other users. For example, language, number of results displayed when the user runs a search, appearance or content of the service based on the type of browser used, or the region from where the service is accessed, etc. Not accepting cookies may cause slow website performance or poorly adapted recommendations.
- Analysis cookies: These cookies can quantify the number of users, sections visited on the platform and how users interact with it to carry out statistical measurement and analysis on use, in order to implement improvements based on the analysis of data on how users use the platform or service.
- Behavioural advertising cookies: Are those which store information on user behaviour obtained from continuous observation of their browsing habits, which allows us to develop a specific profile for displaying advertising adapted to these habits. These cookies allow for the most effective management possible of any advertising space the editor has included directly or in collaboration with third parties.
What are Cookies used for on our Platform?
Cookies are an essential part of our how Platform works. The main goal of our Cookies is to make your browsing experience as easy and efficient as possible. For example, they are used to remember your preferences (language, country, etc.) when browsing and during future visits. We also use our Cookies to continuously improve our services and Platform, and to offer customised advertising according to your browsing habits.
Information collected on Cookies also allows us to improve our Platform by making estimates on statistical data and patterns of use (number of visits, most visited sections, visit time, etc.), gain a statistical understanding of how users interact with the Platform so as to improve our services, and to adapt the Platform to your individual interests, accelerate searches, etc.
In any case, the Cookies we use never store sensitive information such as passwords, credit or debit card details, etc.
Please remember that both managing the Cookies settings panel and opting to reject Cookies is specific to each browser you are using. Therefore, if you configure Cookies one way on one device and want your option to apply equally to another device, you must enable the same option on the other device.
Additionally, regarding third-party Cookies used to provide advertising based on your interests, please note that certain third parties may be members of some of the following self-regulatory programmes for online behavioural advertising, with the relevant voluntary exclusion options:
Who uses the information stored on Cookies?
The information stored on our Platform Cookies is only used by us, except those identified in section 2 as “Third- party cookies”, which are used and managed by external entities to provide us services aimed at improving our services and the user experience when browsing on our Platform. More information in the Cookies settings panel available at all times on our Platform.