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Privacy policy

Before you start...

In this Privacy 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 or in person) of that you use to
interact with us.

If you would like information about how we use cookies and similar devices that may be installed on the
terminals of our customers and users, we recommend you consult the Cookies Policy.

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 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 Policy:

  • When we speak about our Platform, we refer, in general, to any of the channels or means, digital
    or in person, you may have used to interact with us. The main ones are:
  • Our Website.
  • Our App, this is, including both the mobile application you installed on your device and
    others we may use in our Platform.
  • In person, in any of our Brick-and-Mortar Stores.

1.Who is the controller of your data?

Your data controller is:

ALCONER S.L.
Av. Diagonal, 534, entlo. (BARCELONA)
info@sanndi.com

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.
  • special categories of data may be necessary (e.g. health data in cases where it is necessary to manage
    certain incidents such as those related to cosmetic products).

Remember that, when we ask you to provide your personal data to give you access to any functionality or service
of the Platform, we will indicate you that certain fields are 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 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:

PURPOSE +INFO
1. To manage your registration
and identification 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.


You have the possibility to use the login or sign in through a social network
or another collaborator that enables this service (social login) when it is
available on our login/sign in screen, either to link the social login to your
account or by registering a new one. In that case, your login credentials, as
well as your name and email / phone number (you might need to authorize
it), will be imported from your social network or collaborator account. By using
this login option, these third parties may send us certain additional information
about your public profile, such as: your name, gender, approximate age or
profile photograph, according to the terms of use from the social network /collaborator, which we recommend you read carefully. Unless you give us your authorization, we will not retain this additional data. Likewise, the use of this functionality may imply that you provide certain information about your activity to the social network or the collaborator. In any case, we recommend that you review your privacy settings and the privacy policies of the collaborator or social network to learn how these third parties process your data.


For your identification in our Platform several methods may be available for
which it may be necessary that you go through a process that verifies that
you are the owner of the contact data you are using.
2. 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, 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, or of the My
    Account section of the App.
  • 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 Brickand-Mortar Stores.
  • To be able to offer you specific personalized services (such as item
    finder, reserve a fitting room, etc.) available in some Brick-and-Mortar
    Stores, we may process your location and contact data.
  • Finally, we may process your data for the fulfilment of any legal
    obligations that may be applicable.
3. 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 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.
4. 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.
  • 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 or
    telephone number 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.
5. Analysis of usability and
quality to improve our services
  • If you access our Platform, we inform you that we will treat your 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 table:

Purpose Legal standing
1. To manage your Platform
user registration and
identification
  • We process your data because this is necessary on the terms regulating
    the use of the Website and App. 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.
  • If you opt to use the access or login through a social network, we are legally
    permitted to process your data given the consent that you give when
    authorising the assignment of your data from the social network.
2. 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. This includes the contact data
    we process to provide you with electronic tickets of your purchases at the
    Brick-and-Mortar Stores and to make it easier for you to operate with these
    tickets.
  • 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 App or to inform you about the
    availability of our products, 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 or to analyze the
    efficiency of several services included in the Platform, such as for example,
    the Size Recommender tool. 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.
3. 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.
  • In some cases, related to product claims, it may be necessary for the
    processing of data to be carried out to ensure the public interest in public
    health.
4. 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.
5. 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.

4. How long will keep your data?

The time for which we will keep your data will depend on the purposes for which we process them, as explained
below:

Purpose Time for which the data are kept
1. To manage your Platform
user registration and
identification		 We will process your data for the time during which you remain a registered
user (meaning, until you decide to unsubscribe).
2. 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 the services, 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).
3. Customer Support We will process your data for the time necessary to meet your request or
application, as well as for the time established in the regulations that may
apply in each case.
4. 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.
5. 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 timebarred 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 Policy, we must give access to your personal data

 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.
  • public authorities

For service efficiency purposes, some of these providers are located in territories that do not offer a level of data protection comparable to that of our jurisdiction. In such cases, we inform you that we transfer your data with adequate safeguards, always keeping your data safe, using the most appropriate international data transfer mechanisms, such as the Standard Contractual Clauses and any relevant supplementary measures.

In addition, we inform you that we need to share your data with our parent company, ALCONER S.L., for compliance with the obligations of the parent company.

In the event that we sell or transfer all or a portion of our business or assets to another company, whether within or outside the ALCONER S.L. corporate group, or if any other business operation is implemented as a consequence of corporate reorganizations, we may disclose your personal data to the prospective recipient of such business or assets. Should such a sale or transfer occur, we will use reasonable efforts to ensure that the transferee uses the personal information you have provided to us in a manner that is consistent with our Privacy Policy. In this case, we consider that we have a legitimate interest consisting of 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 that they are directly involved in the achievement of any of the purposes described in section 2. We consider this processing necessary for such purposes.

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. Bearing that in mind, we Joint Controllers have agreed that you may exercise your rights free of charge by writing us an email to a single e-mail address (info@sanndi.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 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, in particular, before:


▪ The Spanish Data Protection Agency:
https://www.agpd.es/portalwebAGPD/index-ides-idphp.php
▪ The authority of the country in which the country retail company is located:
https://ico.org.uk/

7. What happens when you provide us with data or 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 Voucher or 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 Policy, a link to which is always included in our communications.

8. Changes to the privacy policy 

We may amend the information contained in this Privacy 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 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 and our App.

9. Information on cookies

We use cookies and similar devices to facilitate your browsing in the Platform, understand how you interact with us
and, in certain cases, to be able to show you advertisements in accordance with your browsing habits. Please read
our Cookies Policy to understand with greater detail the cookies and similar devices that we use, their purpose, how
to manage your preferences, as well as other information of interest.

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