The purpose of this Privacy Policy is to set out all relevant information regarding our use of our customers' and users' personal data. We want to be as transparent as possible about what we do with your personal data so that you understand the implications of how we use it and the rights you have in relation to your data.
1. WHO IS RESPONSIBLE FOR THE HANDLING OF YOUR DATA?
In compliance with the information provision duty set forth in Article 10 of Spanish Law 34/2002 (11th July) on E-Commerce and Information Society Services, the data below corresponds to the owning body of this website.
- Commercial Name: INTERNACIONAL COMERCIO TRADING, S. L.
- Object: INTERNACIONAL COMERCIO TRADING, S. L. is engaged in the sale of fashion textiles, accessories and related items.
- Commercial Address: Rd. Bilbao – Plencia nº17, P.A.E Asuaran, Archanda Building, Block 2B, 48950 Asua-Erandio (Vizcaya), Spain.
- Registry Entry: INTERNACIONAL COMERCIO TRADING, S.L. is registered in the Companies Register of Bilbao, Volume:3217, Page:150, Section 8º, Sheet: BI-13777, with Tax ID: B48753461.
- Email: info@henryarroway.com
2. WHAT TYPE OF PERSONAL INFORMATION DOES HENRY ARROWAY STORE?
The nature of the personal information that HENRY ARROWAY collects from users may vary depending on the products, services or functionalities that you want to enjoy at any given time:
- Your identification data such as, name, surname, language, address, telephone number, etc.
- Economic and transactional information such as, payment or card details, information on orders, returns, etc.
- Connection, geolocation and navigation data (in case you interact with us from your mobile phone, for example).
- Commercial information (for example, if you are subscribed to our newsletter).
Also, HENRY ARROWAY collects information related to your web browsing and interaction with the brand.
All personal data collected by HENRY ARROWAY originates from and is provided by the data subject.
3. WHY DO WE PROCESS YOUR PERSONAL DATA?
The subject's personal data is processed for one of the following purposes:
- To manage and develop registration on our website www.henryarroway.com. Registration will involve profiling of users' browsing on the website. This profiling consists of using the customer's personal data and browsing information, such as products viewed or added to basket, sections of the website visited, their location to assess preferences and/or personal interests, with the aim of providing them with the website content, offers, services and products suited to their profile.
- To manage and develop online shopping. We use the customer's personal information to process and deliver their order and to inform them of its status by email and/or SMS.
- To manage and send information via email, SMS or post related to exclusive promotions, latest releases and personalised information to suit the user's profile, interests and needs.
- Personalisation of communication directed towards the customer in terms of content, products and services based on their interests.
- Activation of the alerts service for when an item becomes available once again on the website.
- Management and issuing of sales receipts or invoices.
4. HOW LONG DO WE STORE YOUR DATA FOR?
The length of time we keep your data varies depending on the purposes for which we process it. Independently of the aforementioned, HENRY ARROWAY will only store personal data for the length of time which is strictly necessary. This considers the need to respond to queries or resolve problems, make improvements, activate services and fulfill the requirements set forth by the relevant legislation. This information will subsequently be duly stored and protected for a period during which responsibilities from its processing may arise, in compliance with the regulations in force at any given time. Once no further action can take place, personal data will be blocked from all the HENRY ARROWAY systems.
5. WHAT GIVES US THE RIGHT TO PROCESS YOUR DATA?
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Purpose |
Legitimation |
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1. Managing registration as a user of the website
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Processing your data is necessary to make website user registration effective. Otherwise we would not be able to manage your registration. The user's own consent is the legal basis upon which personal data is processed.
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2. Developing and fulfilling the sales contract
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The processing of your data is necessary to fulfill the sales contract which ties us together. As such, the customer is obliged to provide the necessary information for its fulfilment. If this information is not provided, the contract of sale cannot be undertaken.
Furthermore, there is a legitimate interest on our part to carry out the necessary checks to detect and prevent any fraud at the time of purchase.
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3. Customer Service |
There is a legitimate interest to respond to queries or information requests received through our contact form. We understand that the processing of this data is just as beneficial for you in that it allows us to respond to you appropriately and resolve any queries.
In situations where your query is related to the exercising of rights we inform you about below, or to claims related to our products, we are authorised to process your data on the grounds of fulfilling legal obligations on our part.
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4. Marketing |
Processing your data for marketing purposes is based on consent you give us. For example, when you accept to receive personalised information through the newsletter or when you accept the legalities to participate in a promotional event or for your photos to be published on our website or social media channels.
Furthermore, there is a legitimate interest to create profiles based on the information we have about you (such as your browsing, preferences or purchase history) and other personal data provided by yourself (such as age or language) for the purpose of showing you custom content. We understand that the processing of this data is also beneficial to you by improving your user experience and allowing you to access information in alignment with your preferences.
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5. Usability and quality analysis |
We consider there to be a legitimate interest for us to analyse the website's usability and user satisfaction ratings. We understand the processing of this data to be beneficial for you too because the objective is to improve overall user experience and to offer a better quality service.
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6. ACCESS TO THE DATA BY THIRD PARTIES.
The user is informed and expressly consents to the transfer of their data to third parties that INTERNACIONAL COMERCIO TRADING S.L. deems necessary for the provision of its services. The user's personal data can be communicated to the following recipients:
- Public Administrations and Bodies when so required by tax, labour, Social Security or any other applicable regulations.
- Suppliers that provide services to HENRY ARROWAY: transport companies which handle shipments, companies which manage our advertising offers, financial institutions, debt collection companies, etc..
In every instance, access to this data by these organisations will be regulated in a contract which complies with the LOPD (Spain's Organic Law on the Protection of Personal Data) Article 12 stipulations. Data communicated will exclusively be that which is deemed adequate, relevant and not excessive.
INTERNACIONAL COMERCIO TRADING, S.L. does not in any circumstance sell customer data to third parties.
7. HOW DOES HENRY ARROWAY PROTECT PERSONAL DATA?
Under no circumstance will INTERNACIONAL COMERCIO TRADING, S.L. make use of user data for purposes different from those outlined above, and the organisation is committed to maintaining due professional confidentiality and establishing the necessary technical and organisational measures to safeguard the information in accordance with the requirements established by Royal Decree 1720/2007 of the LOPD (Spain's Organic Law on the Protection of Personal Data).
The security measures employed by INTERNACIONAL COMERCIO TRADING, S.L. include information security techniques such as firewalls, access control procedures and cryptographic mechanisms. In addition, any transaction carried out via the website is done through secure payment systems. Confidential payment data is encrypted (SSL) and directly transmitted to the appropriate entity.
INTERNACIONAL COMERCIO TRADING, S.L. declares that it has adopted all the technical and organisational measures necessary to guarantee the security and integrity of the personal data it processes, and to prevent its loss, alteration and/or access by unauthorised third parties.
8. MINORS PROTECTION POLICY.
Access to and use of the portal is prohibited from those who are underage. INTERNACIONAL COMERCIO TRADING S.L. reminds users of legal age who are in charge of a minor, that it is their sole responsibility if a minor enters data to request any product or service. It also informs them of IT resources to limit browsing through filtering or the blocking of certain content.
9. WHAT ARE YOUR RIGHTS IN RELATION TO PERSONAL DATA?
In accordance with the provisions of the General Data Protection Regulation, any user may exercise their rights of access and to rectification, erasure, restriction, portability and opposition, in accordance with the provisions of the aforementioned law, by sending a written and signed request, including their name, surname and a photocopy of their ID card or other official document that identifies them, to INTERNACIONAL COMERCIO TRADING, S.L. with main offices at P.A.E Asuaran, Archanda Building, Block 2B, 48950 Asua-Erandio (Vizcaya), Spain, or by sending an e-mail to: henryarroway@henryarroway.com
Below are listed the rights that can be exercised by emailing: henryarroway@henryarroway.com:
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Right of access |
You have the right to obtain a confirmation of whether or not HENRY ARROWAY is handling personal data related to you and, if so, how to access it. As a registered user, you are able to view this information yourself by going to your personal area. |
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Right to rectification |
You have the right to request that HENRY ARROWAY rectify any inaccurate or incomplete personal data. As a registered user, you are able to view this information yourself by going to your personal area. |
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Right to erasure |
You have the right to request that HENRY ARROWAY erases data when, among other reasons, it is no longer necessary in relation to the purposes for which they were collected. |
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Right to restriction |
You have the right to request that HENRY ARROWAY restricts the use of the data. In this case, this data will only conserved for the exercise or defense of legal claims. |
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Right to portability |
You have the right to request to receive your data. For this, the personal data will be received in a structured, commonly used and machine-readable format so that it can be transmitted to another controller where the process is based on consent or on a contract and is carried out by automated means. |
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Right to object |
You have the right to object to the processing of your data. In this case, HENRY ARROWAY shall no longer process the data, except for on compelling legitimate grounds or for the exercise or defence of possible legal claims. |
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Right to present a legal claim |
You have the right to present a legal claim before the Spanish Agency for Data Protection (https://www.agpd.es). |
10. CHANGES TO THE PRIVACY POLICY.
It is possible that the information contained in this Privacy Policy will undergo modifications when we deem it appropriate. In this case, said modification will be communicated to the data subject via different means. When the change in question is significant in terms of your privacy, it will be communicated to you via email so you can review the changes and, if required, object or withdraw from a service or functionality
Regardless, we suggest that you review this Privacy Policy every now and again in case any minor changes or improvements have been made. The present document will always be accessible and available to you on our website.
11. CERTIFICATE OF ADAPTATION TO CURRENT PERSONAL DATA PROTECTION REGULATIONS.
GDPR - General Data Protection Regulation.
LOPD - Spanish Organic Law on Data Protection.
The objective of the present certificate is to accredit INTERNACIONAL COMERCIO TRADING, S.L.'s adaptation to current personal data protection regulations.
INTERNACIONAL COMERCIO TRADING, S.L. has analysed the risk of its processing, created the Processing Activities Register, finalised a contract with those responsible for the processing, prepared the informative clauses and obtained the consent of the data subjects.
INTERNACIONAL COMERCIO TRADING, S.L. implemented the necessary technical and organizational security measures to ensure the security of personal data stored in its information systems, in accordance with the provisions of the current regulations on Data Protection, in the General Data Protection Regulation (GDPR) EU Regulation 2016/679, as well as the provisions of the Organic Law 3/2018 of December 5, 2018, on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDDD).
INTERNACIONAL COMERCIO TRADING, S.L. is committed to complying with the provisions of the aforementioned current regulations related to Data Protection, as well as ensuring that its staff who process personal data comply with the organisational and technical security measures in place in order to avoid the loss, alteration and non-authorised access to said data.
Said personnel are subject to the same obligation to secrecy and confidentiality with respect to the data they process as INTERNACIONAL COMERCIO TRADING, S.L.
Date: 25-05-2018