AREA OF APPLICATION

The Management of JANKOS MARBELLA S.L. (OUTLET DE LUX), onwards, the person responsible to the treatment, assumes the maximum responsibility and commitment with the establishment, implementation and maintenance of this Data Protection Policy, guaranteeing the continuous improvement of the person responsible for the treatment in order to achieve the excellence in relation to compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free movement of these data and by which Directive 95/46 / CE (General Data Protection Regulation) (DOUE L 119/1, 04-05-2016), and the Spanish regulations for the protection of personal data (Organic Law, specific sectorial legislation and its implementing regulations).

The Data Protection Policy of JANKOS MARBELLA S.L. (OUTLET DE LUX) rests on the principle of proactive responsibility, according to which the person responsible for the treatment is responsible for compliance with the regulatory and jurisprudential framework that governs said Policy, and is capable of demonstrating it before the competent control authorities.

In this sense, the person responsible for the treatment will be governed by the following principles that should serve all its personnel as a guide and frame of reference in the processing of personal data:

  • Data protection from the design: the data controller will apply, both when determining the means of treatment and at the time of the treatment itself, appropriate technical and organizational measures, such as pseudonymisation, designed to effectively apply the principles of data protection, such as data minimization, and integrate the necessary guarantees in the treatment.
  • Data protection by default: the data controller will apply the appropriate technical and organizational measures in order to guarantee that, by default, only the personal data that are necessary for each of the specific purposes of the treatment are processed.
  • Data protection in the information life cycle: the measures that guarantee the protection of personal data will be applicable during the complete life cycle of the information.
  • Legality, loyalty and transparency: personal data will be processed in a lawful, loyal and transparent manner in relation to the interested party.
  • Purpose limitation: personal data will be collected for specific, explicit and legitimate purposes, and will not be further processed in a manner incompatible with those purposes.
  • Minimization of data: personal data will be adequate, pertinent and limited to what is necessary in relation to the purposes for which they are processed.
  • Accuracy: the personal data will be exact and, if necessary, updated; All reasonable measures will be taken so that personal data that are inaccurate with respect to the purposes for which they are processed are deleted or rectified without delay.
  • Limitation of the conservation period: the personal data will be kept in a way that allows the identification of the interested parties for no longer than necessary for the purposes of the processing of personal data.
  • Integrity and confidentiality: personal data will be treated in such a way as to guarantee adequate security of personal data, including protection against unauthorized or illegal treatment and against its loss, destruction or accidental damage, through the application of technical measures or appropriate organizational arrangements.
  • Information and training: one of the keys to guaranteeing the protection of personal data is the training and information that is provided to the personnel involved in their processing. During the life cycle of the information, all personnel with access to the data will be properly trained and informed about their obligations in relation to compliance with data protection regulations.


WHAT INFORMATION WE COLLECT

This privacy policy will apply to any collection and processing of personal data carried out:

  • When you interact with the website https://www.outletdelux.es (online store) operated by JANKOS MARBELLA S.L. (OUTLET DE LUX), Plaza Antonio Banderas, 22, 29660, Marbella, Málaga, Spain.
  • When you buy a product or request other services from OUTLET DE LUX, either online in our online store or in our stores, even when you contact our customer service to request after-sales customer services or ask questions or requests specific.
  • When we communicate with you as part of our marketing activities.
  • By accessing and using this website or by providing us with your personal data (for example, by visiting our stores or by contacting our customer service), you confirm that you have read and understand how we collect, process, use and disclose your personal data as described in this Privacy Policy.


About specific processing activities are concerned, we need to obtain your consent to collect and process your personal data. When we need your consent, we will ask you, before you send personal data or use the corresponding sections of the online store, to confirm electronically that you accept the processing activity in question, as described in this Privacy Policy, by checking specific checkboxes. Your affirmative action by checking the appropriate checkbox and your use of this website means that you consent to the processing activity in question as described in this Privacy Policy. The records of your acceptance of this Privacy Policy, the dates and all future modifications made to it will be considered conclusive and written evidence of your consent.

You will also be informed about this Privacy Policy -and when a specific processing activity requires your consent, you will be asked to give it -when you contact our customer service or when you provide us with your personal data at our stores (or through the online store).

Automatic collection of information on this website:

The processing of your personal data when you simply visit and consult the online store is limited to so-called browsing data; that is, the data whose transmission to the website is implicit in the operation of the systems in charge of managing the website and in the communication protocols of the internet. Navigation data is, for example, the IP addresses of the devices you use to connect to the website and other parameters related to your device and operating system.

In principle, we collect and process navigation data, such as those specified above and, for example, the number of visits and the time spent in the online store, exclusively for statistical purposes and in an aggregated way in order to measure and improve the operation of the online store. Due to the very nature of browsing data, these data can lead to the identification of users if they are associated with data held by third parties. However, we do not collect browsing data to associate with identified users, except when such data can be used to assess possible liability in the event of information crimes carried out against the website or through the website whenever permitted by law.

In addition, some information is collected in this online store through cookies and other tracking technologies as described in our Cookies Policy available in the Cookies Policy section. By actively closing the cookie banner on the website and setting your cookie preferences through our tool and in your browser, you agree to our use of cookies and related technologies. If you do not accept our use of cookies in this way, you will need to set your cookie preferences. You can always withdraw your consent and change your cookie preferences at any time. If you disable the cookies we use, your user experience in this online store may be affected. See our Cookies Policy for more details.

Information that you voluntarily provide us, we collect and process: personal data that you provide when you interact with the functionalities of the online store; for example, when you open an account or upload user-generated content to the website. This personal information may include:

  • Your name, email address, and phone number.
  • Your username and password.


Personal data that you provide when you participate / subscribe to our marketing activities (either through our website or on our social networks); for example, when you subscribe to our newsletter (s) or mailing list (s) or participate in promotions and other initiatives such as loyalty programs, contests and sweepstakes, etc. This personal data may include:

  • Your name, email address, and phone number.
  • The history of your purchases.
  • Your gender.
  • Your preferences and interests.


Personal data that you provide when you buy products from us (either online or in our stores). This personal information may include:

  • Your name, email address, and phone number.
  • The history of the products you buy.
  • Details about your transaction.
  • Postal address.


Personal data that you provide when you interact with our customer service; For example, when you submit a question about a product, give us feedback, contact our customer service center for assistance, or request specific assistance or services from our customer service. This personal information may include:

  • Your name, email address, and phone number.
  • The history of the products you buy.
  • Information about the reasons why you contacted customer service.


When you have provided us with personal data about another person (for example, when using the email-to-friend function, gift card functionalities or other purposes) to the extent permitted by applicable laws, you confirm that you have the right to communicate said personal data and that you have informed said person about -and, when necessary, you have obtained their consent for- the processing of their personal data for the purposes established in this Privacy Policy.

WHAT WE USE YOUR INFORMATION FOR

We collect and process your personal data for the following purposes:

JANKOS MARBELLA S.L. (OUTLET DE LUX), as controller, processes your personal data for the following purposes:

  • Operate and manage the online store, including: to provide you with the services or functionalities that you request on the website. To create your account and manage your subscription on the website. To improve your browsing experience and perfect the online store.
  • Carry out marketing activities for JANKOS MARBELLA S.L. (OUTLET DE LUX), including: for direct marketing purposes; to manage your subscription to our newsletter (s) or mailing list (s) or loyalty program (s). To allow participation in promotions and other initiatives, such as contests and sweepstakes. To send you (by virtue of your consent, which is optional), also via email or other electronic means of communication such as instant messaging, etc., promotional information and material about our products and services, about special initiatives related to prices and promotions and on initiatives such as loyalty programs, events, exhibitions and fairs organized by or in which JANKOS MARBELLA SL participates (OUTLET DE LUX).
  • For survey purposes (by virtue of your consent, this is optional).
  • For profiling purposes (based on your consent, this is optional).
  • To improve our products and services.
  • For other purposes: for fraud prevention purposes.
  • To accomplish with our obligations under applicable laws, regulations and community legislation, and to assess and defend a legal right.


JANKOS MARBELLA S.L. (OUTLET DE LUX), as controller, processes your personal data for the following purposes:

- Manage your product purchases online: this includes all activities related to the purchase of products, such as product delivery, billing, product return and exchange, receipt of refunds, purchase and use of gift cards and gift cards electronic, as applicable, payment-related activities, including coupon use.

Provide you with our customer service, including:

  • To provide you with after-sales services.
  • To respond to your request (s) for information, question (s), communication / communications or comments.
  • To the purposes of internal training and improvement of our customer service.


To accomplish with our obligations under applicable laws, regulations and community legislation, and to assess and defend a legal right.

Our customer service is managed by the team at the online store JANKOS MARBELLA S.L. (OUTLET DE LUX), with registered office at Plaza Antonio Banderas, 22, 29660, Puerto Banús, Marbella, Málaga, Spain, which interacts with you and provides services on behalf of the online store from which you purchased the products. We will process your personal data when you contact our customer service and call center, who will be able to contact you by email, instant message and / or telephone. The call center will record your phone number for callback and administrative services purposes to provide you with the requested information and support. In some cases, for internal training, quality control and verification purposes, the call may be recorded and emails may be saved as long as it is not prohibited by applicable law. You will always be informed in advance of the recording of the communication, and you will have the opportunity to object to such recording, save it when necessary for verification purposes in relation to your purchase or other reasons, as permitted by applicable laws.

HOW LONG DO WE KEEP YOUR INFORMATION

Personal data is not retained for longer than is necessary to achieve the specific data processing purposes described in this document, unless shorter or longer retention periods apply in accordance with applicable laws. We can do this up to 10 years after the end of the contractual relationship (the statute of limitations for legal claims in most EU countries), unless a shorter or longer retention period applies according to the protection laws of applicable data.

NECESSARY INFORMATION vs. OPTIONAL

Except for browsing data, providing your personal data may be a necessary requirement to enter into or execute a contract, including for the provision of certain services and functionalities offered by the online store, such as subscription or customer file, subscription to our(s) newsletter(s), purchase of products through the online store or in our physical store, management of participation in loyalty programs, promotions and other initiatives communicated through the online store or in our store, responding and managing the request for information, questions, communication or comments. In such circumstances, the refusal to provide your personal data would make it impossible for us to perform the contract or provide the requested services, products or information as specified above.

Providing your personal data for the purposes of surveys, marketing and the creation of other profiles as specified above is optional; refusal to do so for these purposes will have no impact on the conclusion or performance of the contract. When requested under data protection laws, we will obtain your prior consent before processing your personal data for these purposes.

The website may contain links to other sites, as well as to objects or elements controlled by third parties.

An example is plug-ins that can connect our site to social networks such as Facebook or Instagram ("social plug-in") and which are normally identified by the logo of the corresponding social network. If you interact with a social plug-in in our online store, your browser may send certain data related to your social network, such as your user ID, information in our online store, date and time, and other information related to the browser. Such information will be processed by social networks, owned and operated by third parties, in accordance with their privacy policies.

We do not have access to or control over elements, objects, plug-ins, cookies, web interceptors and other articles or tracking technologies owned and operated by third parties, available on our Site or on third party websites, to which users can access in or from the online store, nor on the methods of processing personal data through said elements or sites. Therefore, we do not assume any responsibility for such websites.

You should check the privacy policy of third-party websites and the elements that you access from the website to know the conditions applicable to the processing of personal data, since this Privacy Policy applies only to this website.

RIGHTS

You have the right at all times to enforce the rights available under applicable data protection laws, including, but not limited to, the right of access, rectification, restriction, cancellation, opposition (including objection, at any time and free of charge, to the processing of your personal data for direct marketing purposes), the right to portability, as well as the right to withdraw your consent. You also have the right to file a claim with the competent supervisory authority.

To get a summary of what the aforementioned rights imply and how you can exercise them, see Appendix I of this Privacy Policy.

Any query or request related to the processing of personal data by JANKOS MARBELLA S.L. (OUTLET DE LUX) and to enforce the rights under data protection laws, you can contact our Privacy Office at hola@outletdelux.es.

Can we make changes to this Privacy Policy?

We reserve the right to update and modify all or part of this Privacy Policy, at any time, to the maximum extent permitted by applicable law. The version published on the website / online store is the version actually in force. If we alter this Privacy Policy, we will notify you of such changes by posting a link on the home page of the online store to the modified Privacy Policy that would read "Updated Privacy Policy" and / or notifying you in any other way (such as by email when appropriate or required by law and to the extent that we have your email address).


Appendix 1 - Data Subject's Rights



As an individual whose personal data is processed as described in this Privacy Policy, you have a number of rights which are summarized below. Please note that exercising these rights is subject to certain requirements and conditions as set forth in applicable law.

Right of access: subject to applicable law, you have the right to obtain confirmation from us as to whether or not personal data that concerns you is processed, and, if so, to request access to such personal data including, without limitation, the categories of personal data concerned, the purposes of the processing and the recipients or categories of recipients. However, we do have to take into account the rights and freedoms of others, so this is not an absolute right. If you request more than one copy of the personal data undergoing processing, we may charge a reasonable fee based on administrative costs.

Right to rectification: you have the right to request from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you also have the right to request that incomplete personal data be completed, including by means of providing a supplementary statement.

Right to erasure ('right to be forgotten’): you have the right to request from us the erasure of personal data concerning you in certain circumstances as defined under applicable law. When your request falls within one of those circumstances, we will erase your personal data without undue delay. If, for technical and organisational reasons, we were not able to erase your personal data, we will ensure that it is fully and irreversibly anonymized so that we will not longer be holding such personal data about you.

Right to restriction of processing: in certain circumstances as defined under applicable law, you have the right to request the restriction of processing of your personal data. In such case, your personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest.

Right to data portability: in certain circumstances as defined under applicable law, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit that data to another controller or to have such personal data transmitted directly from us to another controller, where technically feasible.

Right to object: in certain circumstances as defined under applicable law, you have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data by us and we can be required to no longer process your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. This notably applies in case of processing of your personal data based on our legitimate interests or for statistical purposes.

Right to object to direct marketing: where your personal data are processed for direct marketing purposes, you have the right to object at any time to processing for such direct marketing (including profiling related to such direct marketing).

Right not to be subject to a decision based solely on automated processing: subject to certain restrictions, you have the right not to be subject to a decision based solely on automated processed, including profiling, which produces legal effects on you similarly significantly affects you.

Right to withdraw consent: if you have declared your consent for any personal data processing activities as described in this Privacy Policy, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to withdrawal of the consent.

If you wish to access such personal data or exercise any of the rights listed above, you should apply in writing, providing evidence of your identity to our Privacy Office at hola@outletdelux.es .

Any communication from us in relation to your rights as detailed above will be provided free of charge. However, in case of requests that are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or refuse to act on the request.

In case you have a complaint about the processing of your personal data, you have the right to lodge a complaint with a competent supervisory authority.

RESPONSIBILITY

The controller of the personal data that is collected when you use this website (for a purpose other than to buy products from us), and that is collected for our marketing and profiling activities is: JANKOS MARBELLA S.L. (OUTLET DE LUX). For more information and to contact us, see "Contact us" in the menu of the online store.

JANKOS MARBELLA S.L. (OUTLET DE LUX), with registered office at Plaza Antonio Banderas, 22, 29660, Puerto Banús, Marbella, Málaga, Spain, C.I.F. B93167534 acts as a representative for compliance with the protection of personal data in the European Union.

You can contact the Data Protection Officer of JANKOS MARBELLA S.L. (OUTLET DE LUX) through our Privacy and Customer Service Office at hola@outletdelux.es.

We are committed to protecting the security and confidentiality of your personal data. We adopt - and require that any third party service provider and / or processor that processes personal data on our behalf and in accordance with our instructions take - appropriate technical and organizational measures to prevent the loss and destruction, even accidental, of data, unauthorized access to data and the illegal or unfair use of data. In addition, information systems and software programs are configured so that personal and identifying data are used only when necessary to achieve the specific processing objective that is sought from time to time.

We implement a variety of advanced security technologies and procedures to help protect personal data from the risks described above. For example, personal data provided by users is stored on secure servers located in controlled locations. Furthermore, for the transmission of some data over the internet, encryption techniques such as the Secure Socket Layer (SSL) protocol are implemented.

However, keep in mind that no electronic transmission or storage of information is 100% secure. Therefore, despite the security measures we have implemented to protect your personal data, we cannot guarantee that the loss, misuse or alteration of the data will never occur.

The aforementioned recipients may be located in countries other than the country in which the personal data was originally collected, bearing in mind that your personal data will, in principle, only be transferred within the European Economic Area or other countries recognized by the Commission. That have an adequate level of personal data protection.

In the event that any of the above recipients is established in a country outside the EU that is not covered by an adequacy decision of the European Commission and, therefore, does not provide the same level of protection for your personal data as in the EU, we will implement appropriate safeguards, including but not limited to relevant data transfer agreements based on the European Commission's standard contractual clauses for the transfer of data to third countries (Article 46, paragraph 2, letter c) of the GDPR , as of May 25, 2018) or binding corporate rules (article 47 of the RGPD, as of May 25, 2018). You can obtain a copy of these appropriate guarantees by contacting our Privacy Office at hola@outletdelux.es.

The Data Protection Policy of JANKOS MARBELLA S.L. (OUTLET DE LUX) is communicated to all the personnel of the person responsible for the treatment and made available to all interested parties.

Consequently, this Data Protection Policy involves all the personnel of the person responsible for the treatment, who must know and assume it, considering it as their own, with each member being responsible for applying it and verifying the data protection regulations applicable to their activity , as well as identifying and providing the opportunities for improvement that it deems appropriate in order to achieve excellence in relation to compliance.

This Policy will be reviewed by the Management of JANKOS MARBELLA S.L. (OUTLET DE LUX), as many times as deemed necessary, to adapt, at all times, to the current provisions on the protection of personal data.

In case you understand that your rights have been neglected, where can you make a complaint?

In case you understand that your rights have been disregarded by our entity, you can file a claim with the Spanish Agency for Data Protection, through any of the following means:

Electronic office: www.agpd.es
Postal address: Agencia Española de Protección de Datos (Spanish Agency for Data Protection), C / Jorge Juan, 6, 28001, Madrid
By telephone: Tel. 901 100 099 · Tel. 91 266 35 17

Filing a claim with the Agencia Española de Protección de Datos (Spanish Data Protection Agency) does not entail any cost and the assistance of a lawyer or solicitor is not necessary.

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