1. BACKGROUND

 

• The purpose of this Privacy Policy is to explain how POLO CLUB EUROPE SL will use the personal data of customers of POLO CLUB EUROPE SL (hereinafter, “User(s)” or “you”)
  
  
• POLO CLUB EUROPE SL (hereinafter, “we” or “us”) acts as data controller in respect of your personal data and is registered with the Information Commissioner’s Office under data Protection Registration Number ZB809459.

 

• If you would like to contact us about any of the information contained within this Privacy Notice, you can contact us at rgpd@poloclub.com or via post at Ptda. Jubalcoi Polígono 1, Nº 90, 03295 Elche (Alicante), Spain.

 

 

2. PERSONAL DATA WE COLLECT ABOUT YOU AND HOW WE USE IT

 

• The table at the Annex to this Privacy Notice sets out the categories of personal data we collect about you and how we use that information. The table also lists the legal basis which we rely on to process the personal data. If you would like more information from us with respect to the legal basis which we rely on to process the personal data, please contact us using the details provided at paragraph 1.3 above.

 

• We will let you know when the personal data requested from you is necessary in order to provide the services you have requested. Failing to provide the required personal data or doing in part only may limit our ability to deal with the requests or services required by you.

 

• In the event that you provide data of third parties to us, it is your responsibility to inform such third parties of this Privacy Policy and, if necessary, obtained the necessary consent of those third parties to our processing of their personal data.

 

3. WE MAY SHARE YOUR PERSONAL DATA WITH THIRD PARTIES

 

• We will not share any personal data you provide to us unless we are authorised by you to do so, or unless we are under a legal or regulatory obligation to do so. The third parties we share your personal data with will have access to your personal data only to perform the obligations we have engaged them to perform. They are not permitted to disclose or use your personal data for any other purpose.
  
  
• In order to provide our services to you, we may engage third parties to provide certain services on our behalf. For example, we may need to share your personal data with courier services who will deliver your order.
  
  
• If you choose Klarna flexible payments, you will need to enter your personal data via the Klarna form on our Website in order for Klarna to carry out credit assessments and to adapt the payment methods available for you. Klarna will be responsible for the personal data you provide. Personal data which you share with Klarna will be processed according to their privacy policy, which you can find here. You can learn more about Klarna and the flexible payments here.
  
  
• When you choose to return a product to us, you will be required to provide your email via the following link. Outvio will process the return of the product or products. In addition, Outvio may send you surveys to measure customer satisfaction in relation to the return. You can find out more about Outvio and its privacy management here.

 

4. WE MAY TRANSFER YOUR PERSONAL DATA OUTSIDE OF THE UK

 

We use service providers based outside of the UK in order to process and store your personal data. However, in doing so, we take the necessary steps to ensure that your data is processed securely and in accordance with this Privacy Policy.

We will not transfer your personal data to organisations or countries located outside the UK, unless those countries  are recognised by the UK Information Commissioner’s Office as countries which provide an adequate level of protection for personal data or appropriate safeguards are implemented with respect to the transfer of such personal data, such as the standard contractual clauses adopted by the UK government and sufficient guarantees are offered by the relevant processor as to the security of the personal data and enforceability of your data subject rights (see below).

 

5. DATA STORAGE

 

• We will store the personal data we collect about you for no longer than necessary for the purposes set out in the table in the Annex to this Privacy Policy in accordance with our legal obligations and legitimate business interests. When we have no ongoing legitimate business need or legal obligation to process your personal data, we will either delete or anonymise it or, if this is not possible at the time (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.
  
  
• To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, as well as the applicable legal, regulatory, tax, accounting, or other requirements. In some cases, how long we retain your personal data will also depend on whether you consent to our processing of your personal data. 

• In particular:

1. purchase history and transaction data is generally kept for a period of 5 years.
   
   
2. Account information is kept until you decide to end your account with us.
   
   
3. The data provided and collected as a member of our Loyalty Programme will be kept until you decide to end your membership of our Loyalty Programme or until you decide to end your account with us.
   
   
4. The data of the friends referred by members of the Loyalty Programme will be processed only to send them two communications to inform them of the discount offered and will be stored for a month.
   
   
5. The personal details for the delivery of commercial communications by email or SMS will be used for this purpose until you notify us you do not want to continue receiving such communications.
   
   
6. The data for receiving our newsletter will be held as long as you continue to subscribe.

 

6. NOTIFICATIONS AND COOKIES

 

• If you do not wish to receive push notifications, you can opt not to receive push notifications by clicking the prompt which will appear on your screen when you first access our Website. Alternatively, you may disable this option from the settings panel of your browser. This process may vary depending on the browser you use. The links below contain instructions as to how to disable push notifications from different browsers:

 

• Chrome
• Safari
• Mozilla Firefox
• Microsoft Edge

 

• Our website also uses cookies and similar technologies to distinguish you from other users of our services. Please refer to our Cookie Policy for more information as to the way in which we use cookies on our services.

 

7. YOUR RIGHTS

 

• In accordance with aplicable privacy law, you have the following rights in respect of the personal data that we process:
  
  

1.  Right of access. You have the right to obtain access to your personal data.
   
   
2. Right of portability. You have the right, in certain circumstances, to receive a copy of the personal data you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
   
   
3. Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal data we hold about you without undue delay.
   
   
4. Right to erasure. You have the right, in some circumstances, to require us to erase your personal data without undue delay if the continued processing of that personal data is not justified.
   
   
5. Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal data if the continued processing of the personal data in this way is not justified, such as where the accuracy of the personal data is contested by you.
   
   
6. Right to withdraw consent. If you have provided consent to any processing of your personal data, you have a right to withdraw that consent (without affecting the lawfulness of our processing prior to you having withdrawn your consent).
   
   
7. Right to object: you also have the right, in certain circumstances, to object to any processing based on our legitimate interests in certain circumstances. You can also object to our direct marketing activities for any reason by clicking the "unsubscribe" link set out in any marketing communication you receive. See paragraph 7 for further details. 

 

• Please note that the above rights are not absolute, and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply.

 

• If you wish to exercise one of these rights, please contact us by sending an email to rgpd@poloclub.com, stating in the subject ‘EXERCISE OF RIGHTS’.

 

• In the event that we have reasonable doubts regarding the identity of the person making the request, we may request you to provide the additional information necessary to confirm your identity.

 

• Occasionally, the request will result in the storage, limitation or deletion of personal data, as appropriate, to give effect to such rights.

 

• Where we rely on consent to process your personal data, you have the right to withdraw your consent at any time. However, any such withdrawal will not affect the legality of the processing conducted by us on the basis of consent prior to your request to withdraw such consent.

 

• You may also, at any time, object to or revoke any consent which you previously gave to us with respect to receiving marketing communications from us by either: 

1. making this request to us using the email address provided in section 7.3 above.
   
   
2. clicking the relevant link to unsubscribe in any marketing emails received from us; or
   
   
3. if you are a registered User of our Website, via the option enabled for that purpose in your profile.

 

• You also have the right to lodge a complaint to your national data protection authority. If you are in the UK, information on how to contact the Information Commissioner is available at www.ico.org.uk.

 

8. SECURITY OF YOUR PERSONAL DATA

 

• We aim to ensure the security of your personal data. We implement appropriate technical and organisational measures to protect your personal data against its alteration, loss, r unauthorised access or damage, in view of the state of the technology, the nature of the stored data and the risks to which they are exposed. Where personal data is carrried out on our behalf by a third party, we take steps to ensure that appropriate security measures are in place to prevent unauthorised disclosure of personal data.

 

• Despite our precautions, however, we cannot guarantee the security of personal data transmitted over the internet and will not be responsible for any loss or manipulation of data that is not authorised by us or due to malicious attacks by third parties.

 

9. LINKS TO OTHER WEBSITES

 

• Our Website may contain links to other websites not managed by us. By clicking on a third-party link, you will be redirected to this third party's site. We have no control or take no responsibility with respect to the privacy policies or practices of third-party sites or services.

 

• We strongly recommend that you review the privacy policy for all third party sites you visit.

 

10. CHILDREN (18 and under)

 

• Our service is not intended for use by anyone under the age of 18. 

• No one under the age of 18 may provide personal data through our services. If you are a parent or guardian and are aware that your child or ward has provided ss with personal data, please contact us. If we learn we have collected or received personal data relating to anyone under the age of 18, we will promptly delete that information and reserve the right not to provide our services to that person.

 

11. THE ACCURACY OF YOUR INFORMATION

 

You must ensure the accuracy of the personal data which you share with us when using this Website. Any false or inaccurate communication resulting from the personal data we have received from you will be your sole responsibility.

  

12. CHANGES TO THIS PRIVACY POLICY

 

We may update this Privacy Policy at any time so you should check it from time to time. We will inform you of any material amendments to this Privacy Policy so that you are aware of such changes and can exercise your rights under this Privacy Policy if you do not agree with our suggested changes.

 

Annex

 

TYPE OF DATA COLLECTED	HOW WE USE IT	LEGAL BASIS FOR PROCESSING
When you make a purchase or return, we will collect:   -     your contact details (such as your name, address, telephone number and e-mail address); -     details about your account to be refunded (for example, details of the card used to make your purchase); and -     information such as your gender and age in connection with any surveys we ask you to participate in.	· To manage the purchase and shipment of products.  · To manage orders and returns. · To inform you occasionally about news/promotions related to our products (via indirect marketing). · To send you surveys via Hubspot and other channels such as Outvio, to receive your feedback in connection with the purchase you have made or with our returns process.	Such processing is necessary in order to enable us to perform our contract with you.   We rely on your implicit consent to receive marketing materials from us – by virtue of you having bought similar products from us previously.   You will always be given the option to unsubscribe from any promotional or marketing emails from us by clicking on the “unsubscribe” button at the bottom of each promotional or marketing email which you receive from us.  You may also contact us via rgpd@poloclub.com in order to request that we stop sending marketing materials to you.   It is in our legitimate interests to collect information from surveys to understand whether you are happy with your purchase and our returns process and identify any improvements.
When you register as a customer on our website, we will collect:       -     your contact details (such as your name, address, telephone number and e-mail address); -     details about your account to be refunded (for example, details of the card used to make your purchase); -  details of your  product preferences (where you opt to provide this information to us); and - information about your gender or age (where you opt to provide this information to us).	· To manage your user profile. · To manage direct access to order status and you order history. · To notify you of any changes to our service. .To notify you of new promotions/giveaways by email or SMS.	Such processing is necessary in order to enable us to perform our contract with you.   We rely on your implicit consent to receive marketing materials from us – by virtue of you having bought similar products from us previously.   You will always be given the option to unsubscribe from any promotional or marketing emails from us by clicking on the “unsubscribe” button at the bottom of each promotional or marketing email which you receive from us. You may also contact us via rgpd@poloclub.com in order to request that we stop sending emails or SMS messages to you.
When you sign up to our loyalty programme, we collect:   - your contact details (such as your name, address, telephone number and e-mail address); - you may also opt to share with us your date of birth; and -        your order history.	. To manage your profile as a member of the loyalty programme; . to record against your account the points earned by you in respect of  purchases you have made; .to apply your discounts according to the points membership points earned by you; and . to send communications to you which relate to our loyalty programme.	Such processing is necessary in order to enable us to perform our contract with you.
When a member of the loyalty programme invites a friend to participate in the programme, we collect:   -the friend’s email address	. To send two communications to offer a discount to your friend for their next purchase with us.	It is in our legitimate interests to do so, having received confirmation from you that your friend consents to our processing of their personal data in order to sign up to our loyalty programme.
When you contact us either via our email or our Website, we collect:       - your contact details (such as your name, address, telephone number and e-mail address); and - any other personal data you may share with us in connection with questions you ask us.	. To assist you when you ask us questions; . To exchange communications by email; and . To send satisfaction surveys about the operation of our customer service.	It may be necessary to collect this information in order to perform our contract with you.   It may also be in our legitimate interests to collect this information in order to provide our service to you.
When you apply to a role which we are hiring for, we collect:          - your contact details (such as your name, address, telephone number and e-mail address);          -         we may also collect data about your personal characteristics, such as: your gender, date and place of birth, age, nationality, and ID; -         Professional and educational details and experience.	. To manage the application to apply for a job selection process; and . To manage and process your request for accessing a selection process, the information provided may be verified against third-party sources	It may be necessary to collect this information in order to perform a contract with you with respect to your employment.   It is in our legitimate interests to collect this information in order to assess your suitability for the role.
When you request for us to let you know when a product comes back in stock, we collect: the email address you provide to us.	· To inform you of the availability of the products requested	We rely on your consent.
When you ask us to send newsletters or push notifications, we collect:   - the e-mail you provide us with to send you communications about offers and products of your interest; - information about your product preferences (optional); and - your IP, in the case of sending push notifications.	· To keep you informed about our news and offers; and · To take into account your product preferences, to send a newsletter that fits your interests.	We rely on your consent to receive marketing materials from us.   You will always be given the option to unsubscribe from any promotional or marketing emails from us by clicking on the “unsubscribe” button at the bottom of each promotional or marketing email which you receive from us.  You may also contact us via rgpd@poloclub.com in order to request that we stop sending marketing materials to you.
When you navigate our website, we use cookies to collect the following information about you:   - technical information, such as your IP address, access data, browser and version, operating system; and / or - information regarding your visits to our Website, including the Uniform Resource Locator (URL), the services viewed or searched and the pages you visit, the response time of the site, download errors, the time and date of the visit, the time spent on those pages, information about interaction on the site (for example, clicks and/or mouse movements), the methods used to leave the site, unique device identifiers, and other diagnostic data; and/or - Information collected through the use of cookies. You can learn more about the use of cookies and how to manage them in our Cookie Policy	· To allow you to participate in interactive features of our Website when you choose to do so. · To collect statistical analysis, research and profiles for navigation and content interest, or other valuable information that will enable Us to improve our Website and service. · To detect, avoid and address technical problems.	We obtain your express consent.
When you defer payment, we collect:        - your contact details (such as your name, address, telephone number and e-mail address); and -     details about your account to be charged (for example, details of the card used to make your purchase);	· To defer payments as requested by you. · To communicate the data to the company that finances the payments.	Such processing is necessary in order to enable us to perform our contract with you.
When you include a suggestion or complaint in the web experience area, we collect:   - your email; and - any other personal data which you choose to share with us in connection with a complaint or suggestion made by you.	·    To be able to learn about the experience of Users and verify by entering their email that the opinion is real. ·    We may contact those Users who did not have a good experience at the email provided.	We rely on your consent.
When you enter a giveaway or contest, we collect:   - your contact details (such as your name, address, telephone number and e-mail address); and - your age.	·    To manage the participation of Users in the contest/giveaway set out in the Terms. ·    To inform the winner of the contest/giveaway. ·    To send or deliver the prize(s) to you.	We rely on your consent. We must also collect this personal data in order to perform our contract with you by reference to the terms governing the giveaway / contest.