WE RECOMMEND THAT YOU READ AND UNDERSTAND OUR PRIVACY POLICY BEFORE PROVIDING US WITH YOUR PERSONAL DATA AND GRANT US CONSENT FOR IT TO BE PROCESSED

1. - Who controls your data?

Identity: ECOALF RECYCLED FABRICS, S.L.

Tax ID: B85910610

Telephone No.: 91 319 68 01

Email: gdpr@ecoalf.com

General Director: Ms María Luisa Selfa Ortega.

2. - What data of yours do we process?

2.1 Data that has been provided to us when you registered at the online store (www.ecoalf.com) and which corresponds to the following personal data: name, surname, email address, postal address, postal code, city, county, ID number/Foreigner’s ID number/Passport number and telephone number.

2.2 Request for Newsletters, and which corresponds to the following personal data: email address.

2.3 Customer Service, and which corresponds to the following personal data: email address.

2.4 Data that has been provided to us when you registered at the store and which corresponds to the following personal data: name, surname, gender, date of birth, email address and mobile number.

Please take into account that if you choose not to provide us with this data, there is the chance that you might not be able to complete your registration as a user and take advantage of the requested service.

3. - What is the purpose for processing your personal data and what is the legal basis?

We keep your data with the following purposes, legal basis and retention periods as stated below

3.1. Online store client registration

Purpose: The main purpose is to handle your registration as a user at the online store, for the performance, compliance and implementation of the purchase agreement. The additional purpose is for creating profiles and marketing.

Legal basis: Main purpose (the agreement) and additional purpose (legitimate interest).

Retention periods: The personal data that you provide shall be retained for a 6-year period from the date of the last purchase, blocking this data until there is a requirement for any potential liability actions.

3.2. Newsletter

Purpose: The main purpose is for sending personalised electronic notifications about our products via email. The additional purpose is for creating profiles and marketing.

Legal basis: Main purpose (consent) and additional purpose (legitimate interest), with the aim of sending notifications suitable to your interests.

Retention periods: The personal data will be retained until you request to be delisted, given that up until that moment we will have the understanding that you are still interested in receiving our notifications.

With regard to creating profiles and marketing, we believe that we have legitimate interest for creating a profile with the information that we have about you (like the browsing you do and/or purchase history) and the personal data that you have provided because we understand that processing this data is also beneficial to you as it allows you to improve your experience as a user and to access the information in accordance with your preferences. To that end, ECOALF has deliberated the interests and rights of the interested parties, and the measures adopted by the controller to fulfil the general conditions in terms of commensurability and transparency, and they have drawn the conclusion that:

1. - The impact on fundamental rights and public freedoms of the people is lower;

2. - The processing may be reasonably intended by the interested party;

3. - The data processing with the previous purposes does not give rise to the exemption, discrimination, defamation, or situations that could put the reputation of the interested party and/or their negotiation power at risk.

3.3. Customer service.

Purpose: The purpose is to handle or resolve your application or request.

Legal basis: Agreement and legitimate interest.

Retention periods: We will process your data for the time necessary to deal with your application or request, blocking it until there is a requirement for potential liability actions.

3.4. Store client registration

Main purpose: Sending personalised marketing notifications via email (Newsletter, advertising information and updates about the brand, advertising and exclusive offers, invitations to exclusive events, competitions and prize draws).

The additional purpose is for creating profiles and marketingwith the aim of sending notifications suitable to your interests.

Legal basis: Main purpose (consent) and additional purpose (legitimate interest).

Retention periods: The personal data provided will be retained until you request to be delisted, given that up until that moment we will have the understanding that you are still interested in receiving our notifications.

3.5. Accepting cookies on the www.ecoalf.com websites. You will find more information in our Cookies Policy.

4. - Who is the recipient of your data?

4.1. Data communication

a)       The processed personal data will only be communicated to third parties, in compliance with legal obligations.

b)      Instant Credit deferred payment service.

In accordance with what is set forth in (EU) Regulation 2016/679 dated 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”), you are hereby informed that in the event that you choose the Instant Credit deferred payment service, the personal data shown as follows will be passed on to LSP Finance, S.L. (“Instant Credit”), a company with registered address in Barcelona at Avenida Diagonal 407 4º 1ª and Tax ID number B-66681602.

Data that is passed on: Client’s name and surname, Invoicing and delivery addresses, Email address, Purchase history and Gender.

Purpose: Your data will be processed for the sole and exclusive purpose of INSTANT CREDIT being able to analyse, assess and handle the credit that you as a user are requesting.

Legitimacy: the legal basis for the processing is article 6.1 b) of the European Data Protection Regulation.

Recipients: LSP Finance, S.L. will act as the data assignee.

Retention period: The personal data passed on to LSP Finance, S.L will be retained by the company in accordance with what is set forth in its Privacy Policy: https://www.instantcredit.net/politica-de-privacidad.

Rights: We also inform you of your rights of access, rectification, withdrawal, restriction to the processing, transfer, right not to subject oneself to automatic decisions and to oppose the processing, as per the terms stipulated in the General Data Protection Regulation and the Law on Personal Data Protection

In order to exercise these rights before the processing assignee, you may send an email to the address: gdpr@instantcredit.net.

Likewise, you may also submit a complaint to the Spanish Data Protection Agency, especially when you are not satisfied with how your rights have been obtained. For more information, visit the https://www.agpd.es website.

4.2. Data Processors.

ECOALF will have collaboration from third-party service providers who will have access to your personal data and will process said data in name and representation of the company as a result of their service provision. ECOALF follows very strict criteria when selecting its service providers with the aim of fulfilling its obligations in terms of data protection, and it is committed to subscribing to the corresponding data protection agreement with them.

More specifically, ECOALF will contract the service provision from third party providers that are active, including but not limited to, in the following sectors: logistics services, legal guidance, provider accreditation, multi-disciplinary professional service companies, companies related to maintenance, companies providing technology services, companies providing IT services, physical security companies, instant messaging service providers, infrastructural maintenance and management companies and call centre service companies.

5. - What are your rights when you provide us with your data?

The rights that you have for personal data processing with reference to ECOALF are:

·         The right to request access to your personal data

·         The right to request its rectification or withdrawal

·         The right to request a processing restriction

·         The right to data transfer

·         The right to oppose processing

·         The right not to subject oneself to automatic decisions, including profiles

6. - What does the right of access consist of?

You will have the right to obtain conformation regarding whether or not your personal data is being processed, and to obtain the following information: the processing purposes; the categories of the data that is being processed; the recipients or the categories of recipients that have been sent it or will be sent it; where possible, the expected time frame for retaining the personal data, or where it is not possible, the criteria used to determine this time frame.

In such cases, we will provide you with a copy of the personal data that is being processed. Further to this, when you make the request electronically, the information will be provided in a usable digital format.

You will be able to exercise this right every six months, unless there is a legitimate reason for requesting it more than once within this six month period, and we will inform you about the follow-up from your request within one month.

To exercise your right of access, send an email to: gdpr@ecoalf.com or a letter to the Department of to Calle HORTALEZA 116, 28004, MADRID.

7. - What does the right to rectification consist of?

You will have the right to rectify any incorrect personal data that concerns you and to do so; you will have to submit, where necessary, the documentation justifying the incorrectness or incomplete nature of the data being processed.

To exercise your right to rectification, send an email to: gdpr@ecoalf.com or a letter to the Department of to Calle HORTALEZA 116, 28004, MADRID.

8. - What does the right to withdrawal consist of?

You will have the right to withdraw any personal data that concerns you when one of the following circumstances is applicable: when it is not necessary for the purposes that it was gathered or processed; when you withdraw consent and the processing has no further legal basis; when you oppose the processing and there are no further legitimate reasons for the processing; when it has been processed illegally.

To exercise your right to removal, send an email to: gdpr@ecoalf.com or a letter to the Department of to Calle HORTALEZA 116, 28004, MADRID.

9. - What does the right to the process limitation consist of?

You will have the right to limit your data from being processed when one of the following conditions is fulfilled:

a)       when you have contested the accuracy of your personal data during the time frame which will allow the file controller to verify its accuracy;

b)      in the event that you consider the processing to be illegal and the file controller opposes the withdrawal of the personal data and requests that its use is instead limited;

c)       when the file controller no longer needs the personal data for the processing purposes, but you need it in order to formulate, exercise or defend complaints;

d)      in the event that you have opposed the processing, whilst a check is being made on whether the file controller’s legitimate reasons prevail over your own.

When you have obtained the processing restriction in accordance with this section, you will be informed of it by the person responsible for the file.

To exercise your right to processing restriction, send an email to: gdpr@ecoalf.com or a letter to Calle HORTALEZA 116, 28004, MADRID.

10. - What does the right to data transfer consist of?

You will have the right to receive the personal data that concerns you that you provided to the data controller in a structured, usable and readable format, and the right to send it to another data controller when: the processing is based on consent, and it is done automatically.

On exercising your right to the data transfer, you will have the right to have your personal data sent directly from controller to controller where it is technically possible.

The right to transfer will not be extended to data that the file controller may have inferred from data resulting directly from the use by said controller of the provided services.

To exercise your right to data transfer, send an email to: gdpr@ecoalf.com or a letter to the Department of Calle HORTALEZA 116, 28004, MADRID.

11. - What does the right of opposition consist of?

You will have the right to oppose your data being processed at any time. If you choose to exercise this right, the file controller will stop processing your personal data, unless we can demonstrate compelling legitimate reasons for the processing to prevail over your interests, rights and freedoms, or to formulate, exercise or defend complaints.

To exercise your right of opposition, send an email to: gdpr@ecoalf.com or a letter to the Department of to Calle HORTALEZA 116, 28004, MADRID.

12. - What does the right to not subject oneself to automatic decisions, including profiles consist of?

You will have the right not to be subjected to a decision that is solely based on automatic processing, including the creation of profiles which may give rise to (said decisions) legal effects or which may affect you in a similar way; unless:

- said decision is necessary for entering into or implementing an agreement,

- is authorised by a law or

- is based on consent.

To exercise your right not to subject oneself to automatic decisions, send an email to: gdpr@ecoalf.com or a letter to the Department of to Calle HORTALEZA 116, 28004, MADRID.

We also inform you that you may approach the Spanish Data Protection Agency to obtain more information about your rights.

Furthermore, in the event that you have granted your consent for a specific purpose, you have the right to withdraw your consent at any time without this affecting the legality of the processing based on the consent given prior to its withdrawal.

Likewise, we inform you that you may submit a complaint to the competent Data Protection Supervisory Authority, the Spanish Data Protection Agency (https://www.aepd.es), especially when you are not satisfied with how your rights have been obtained.

 

 

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