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DATA PROTECTION POLICY

APPOINTMENT BOOKING FORM

Version 28 of April 2020

 

1. DATA CONTROLLER

By completing this form we inform you that your personal data will be processed by SAN PATRICK, S.L.U., a company located in Barcelona, Calle Om, 16, Polígono Industrial Mas Mateu, S/N, and CIF B-63523609 (hereinafter, PRONOVIAS).

SAN PATRICK is part of the international corporate group Pronovias Group, which includes all those affiliated companies under its various brands, among others: “St. Patrick", "White One", "Pronovias", and "La Sposa", companies that you can consult at any time at [see link]. Your data will be processed by SAN PATRICK as the management company for all the Pronovias Group's products and brands.

 

2. PURPOSES AND LEGAL BASIS

The data will be processed for the purpose of handling your request for an appointment at the store you select, and for contacting you, both PRONOVIAS and the store where you have the appointment, for anything necessary in relation to the said appointment (e.g. confirmation of the appointment or change of date or time), by any means including electronic means such as email, telephone, SMS or any others suited to such purposes (including instant messaging applications).

Your data will also be used to create a Pronovias Customer account, or to update the data if you already have one, with which we can offer you personalised attention and services by gathering and processing the information you supply to us, such as future events, tastes or preferences, as set out in the Preparation of Profiles section below.

The legal basis for processing your data for making an appointment is based on our legitimate interest in being able adequately to supply the service you request of us. This legitimate interest also covers the sending of your personal identification and contact data to the store where you make the appointment, which will in turn process it to provide the service, i.e. in the performance of the store's personalised service.

The creation of a Pronovias Customer account is also done on the basis of our legitimate commercial interest in being able to offer you the best possible services on the basis of your needs and preferences, and to keep a historical record of our relations with you. You can obtain further information on how we handle the Customer Account in section three (3) below on Preparation of Profiles.

And if you visit our stores we will be able to send you satisfaction surveys both on the quality of the service received and on our products, based on our legitimate interest in knowing your opinion and whether you are satisfied with the attention received during the appointment, and drawing up improvement plans for customer service. This helps us to improve on a day-by- day basis. These satisfaction surveys may be sent to you electronically, even if you have not agreed to receive commercial mailings, as it is not advertising, but rather the best way of ensuring we have supplied you with the best possible service at the store in line with the quality standards of the Pronovias Group, and we therefore have a legitimate interest in processing your contact and mailing data for these purposes. If you think the service was not properly provided we may contact you by telephone or any other means of communication you have indicated to deal with any incident which may have occurred during your visit to the store.

If PRONOVIAS does not offer the service of booking your appointment free of charge, PRONOVIAS will gather all information and personal data related to the method of payment you choose, bank details (gathered directly by the Adyen. secure payment platform. For more information go to https://www.adyen.com), contact details, billing information, etc. in order to handle the booking, the payment made and monitor fraudulent operations.

We may also process your data for the following purposes, provided you have given your consent by marking the box provided in the form:

  • Sending you a PRONOVIAS newsletter, which will be personalised and adapted to your interests.

  • Sending you additional information relating to PRONOVIAS such as opinion surveys, invitations to events, etc.

All newsletters or commercial mailings will be sent by SAN PATRICK, S.L.U., including those of other companies of the PRONOVIAS Group, this being the company in charge of the Group's advertising and communication.

These mailings may be adapted and personalised according to the interests of users, based either on the products and services ordered or any data we are able to deduce or obtain from your browsing habits, interest in particular content or reaction to our communications among other data sources, as set out in section four (4) below on Commercial Mailings.

 

3. PREPARATION OF PROFILES

As stated above at Pronovias we prepare profiles of the Customers who interact with us, creating a user or customer account containing all of the information gathered using the various data gathering channels both physical and online. The profile may be complete or incomplete depending on the type of interaction. We prepare these profiles on the basis of our legitimate business interests, which include knowing our customers and improving our services on the basis of their preferences and needs.

We set out below the various profile options depending on your relationship with us and any options you have selected:

3.1 Profile in store or customer service: We may ask you in our stores or by way of our telephone customer service to supply us with personal data, for reasons including maintaining a commercial relationship, providing personalised attention or handling bookings for appointments. For this we create a Customer file where we store all relevant information such as for example preferred styles of clothing, colours, whether you are interested in a wedding dress or a party dress, etc. This information helps us to adapt the service we provide and keep you informed of news or events in the stores you have visited (e.g. arrival of new collections or new colours, trunk shows or private sales, etc.), the store continuing direct mailing in addition to any information we send from Pronovias (e.g. by email if you have consented to this).

And if you visit our stores we may send you satisfaction surveys both on the quality of the service received and on our products. This helps us to improve on a day-by-day basis. These satisfaction surveys may be sent electronically even if you have not agreed to receive commercial mailings, as it is not advertising, it is the best way we have of ensuring we have given you the best in-store service in line with the quality standards of the Pronovias Group, and we thus have a legitimate interest in processing your contact and mailing data for these purposes. If you think the service was inadequate we may contact you by telephone or any other means of mailing you have indicated to deal with any incident which may have occurred during your visit to the store.

3.2 Online profile: The new technologies allow us to prepare much more precise profiles analysing not just the preferences you expressed in our stores but also the following:

  • Information provided on booking an appointment, e.g. the date of an event, including your wedding; the type of environment in which the event or your weddding will be held; your preferences on the shape or neckline of the dress; your budget for the dress;

  • Information provided at the time of creating a user account, e.g. identification or contact data or your address;

  • Purchases you have made by way of our online store, by which we can deduce your style and preferences;

  • Behaviour in the web site (content you access, type of dresses visited, favourite colours, how often you vist the website ...), which helps us to understand what you like;

  • Behaviour in relation to our newsletter (what type of content makes you click or open the newsletter; how often you open our communications);

  • Relevant information based on the dresses you include in the “My favourites” section (type of dress, colours, and other characteristics which help us to understand your preferences in our products).

These profiles may be combined when you contact Pronovias either by physical channels (visiting a store or customer service) or online via the website, app, social networks, etc.

3.3 Use of the information generated in user profiles: Any information we gather on our customers is used for various purposes which may be put in two main groups, (i) purposes relating to a personalised service adapted to our customers, and (ii) purely advertising purposes.

As regards personalised service knowing your preferences means that all of our Pronovias stores can anticipate your needs and hence offer added value in our services. For example knowing your dress preferences means staff can not just show you dresses which match those preferences (e.g. long or short party dresses, with a particular neckline or colour, etc.), if you have booked an appointment they can make a prior selection of all the dresses or products which might match, including available sizes and colours.

If you have a coming event, particularly in the case of your wedding, knowing the date means we can see the dresses available for fittings and the availability of sizes and types of dress.

The generating of these profiles also allows us to improve our advertising as we can personalise and adapt the content of our advertising to your interests, the type of advertsing we send you or the regularity with which we send it.

For example if we know of your interest in our new collections we will inform you each time they are presented and put on sale. And if you have shown an interest in our events, for example the presentation of new collections, we can invite you to them also taking into account your location and where the presentation is being held.

All contacts can be made both electronically, as stated above, and by telephone, both directly from Pronovias by way of Customer Service and directly from the store, in order to inform you of the arrival of new dresses, confirm future visits or bookings or generally preserve our ties with you.

Personalisation of the content means we can ensure we send information which will be of interest to you. For example if we know you have a preference for long dresses we will prioritise news or promotions of this type of dress.

And depending on your interaction with us we can offer you special promotions, competitions or participation in events exclusively for customers.

In the following section on Mailings you can obtain further information on how we send mailings, the channels used and the platforms we work with to improve our advertising capacity.

All of the information contained in the Customer account, and therefore all information on your profile and preferences, is accessible by Pronovias stores, which use it to improve the personalised service at the store. All data is at all times the property of San Patrick, S.L.U., although the store, particularly in the case of franchises, may ask you for additional data for its own use during your visit to the store.

 

4. TRANSACTIONAL SMS

Transactional SMS will be send for the purpose of handling your request for an appointment at the store you select, and for contacting you, for anything necessary in relation to the said appointment (e.g. confirmation of the appointment or change of date or time).

  • You can cancel this service at any time. Just text "STOP" to 78142. After you send the message "STOP" to us, we will send you a reply message to confirm that you have been unsubscribed. After this, you will no longer receive messages from us.

  • If you want to join again, please send us an email to privacy@pronovias.com and we will start sending messages to you again.

  • If at any time you need assistance, just text "HELP" to 78142. After you send the message "HELP" to us, we will respond with instructions on how to use our service as well as how to unsubscribe.

Participating carriers: AT&T, Verizon Wireless, Sprint, T-Mobile, U.S. Cellular, Boost Mobile, MetroPCS, Virgin Mobile, Alaska Communications Systems (ACS), Appalachian Wireless (EKN), Bluegrass Cellular, Cellular One of East Central, IL (ECIT), Cellular One of Northeast Pennsylvania, Cricket, Coral Wireless (Mobi PCS), COX, Cross, Element Mobile (Flat Wireless), Epic Touch (Elkhart Telephone), GCI, Golden State, Hawkeye (Chat Mobility), Hawkeye (NW Missouri), Illinois Valley Cellular, Inland Cellular, iWireless (Iowa Wireless), Keystone Wireless (Immix Wireless/PC Man), Mosaic (Consolidated or CTC Telecom), Nex-Tech Wireless, NTelos, Panhandle Communications, Pioneer, Plateau (Texas RSA 3 Ltd), Revol, RINA, Simmetry (TMP Corporation), Thumb Cellular, Union Wireless, United Wireless, Viaero Wireless, and West Central (WCC or 5 Star Wireless).

T-Mobile is not liable for delayed or undelivered messages.

As always, message and data rates may apply for any messages sent to you from us and to us from you. If you have any questions about your text plan or data plan, it is best to contact your wireless provider.

For all questions about the services provided by this short code, you can send an email to privacy@pronovias.com.

 

5. COMMERCIAL MAILINGS

At Pronovias we will process the data you supply us with in order to send you commercial mailings where we have obtained your prior consent for this. If you give your consent we will send you information, advertising, surveys, invitations to events or promotions concerning products or services relating to the activity of Pronovias. At the moment of data being gathered you may as a Customer decide whether or not you wish to receive this type of mailing from us, and you may always withdraw your consent at any time.

If you agree to us sending you commercial mailings electronically (email, SMS, instant messaging or social networks among others), you must bear in mind that all mailings sent by Pronovias may be adapted and personalised according to your interests, either on the basis of the products and services you have ordered or for example any data we can deduce or obtain from your browsing habits, interest in particular content or reaction to our mailings, as explained in the section above “Preparation of Profiles”.

This personalisation is partially automated in the sense that Pronovias determines the parameters of the personalisation but it is the technological platform which generates the Customer profile. As a general rule we do not send general mailings not segmented by way of this process as we think it is in the interests of both Pronovias and our Customers to send and receive information which is relevant, and because not segmenting would not alter the number of mailings received, only their content. In this regard if you do not wish to be segmented for advertising purposes we would ask you not to subscribe to Pronovias mailings or the Newsletter.

All newsletters and commercial mailings will be sent by SAN PATRICK, S.L.U., including on behalf of other companies of the PRONOVIAS Group, as the company in charge of the Group's advertising and communications.

The commercial mailings sent electronically referred to above may be sent by the following channels:

  • Mailings by email, SMS or MMS o direct messaging (whatsapp, telegram, Facebook Messenger, direct messages in forum or social network applications, etc):

    If we have the relevant information (email, mobile telephone number, etc.) we can send you commercial mailings by these means. As a general rule the channel of communication will be just email, wherever possible, although some messages may be sent by another of the means indicated (e.g. the sending of reminders, events or surveys).

  • Commercial mailings in third party platforms (e.g. social networks):

    Some third party platforms (i.e. websites, communities or applications, for example) allow other advertisers, such as Pronovias, to use the platforms to advertise directly to Pronovias customers who also have a user account in the platform.

    For this the platform may require the advertiser (Pronovias) to prove the identity of its Customers, providing basic identification data such as for example an email address or a telephone number in an encrypted form protected by way of tools provided by the platform itself.

    Once the identity of the Customer and the existence of a user account in the platform have been established Pronovias can create what is commonly known as a “personalised public” with those customers who have agreed to receive advertsing in the platform, with Pronovias advertising appearing directly in the user profile.

    For example in social networks this type of activity can be found in Facebook (Custom Audience), Twitter (Personalised audiences) or Google (Customer Match).

    The purpose of this activity is essentially one of advertising and hence your data is only used if you have agreed to receive our mailings.

    These third party platforms may also allow advertisers such as Pronovias to use their tools to identify users who, within their platform, have a “similar profile” to Pronovias customers.

    The procedure for identifying and proving the identity of customers is the same as above.

    For example in social networks this type of activity can be found in Facebook (Lookalike Audience), Twitter (Personalised audiences) or in Google (Similar Audiences).

    In this case, as the data is not used directly for advertising to our Customers, being aimed at persons who are not customers but have a profile similar to our customers, we will use the basic data of all of our Customers (and not just those who have agreed to receive advertising) to identify potential customers in the platform. In this way the advertising will be sent only to those potential customers who have given their consent to the platform in question for the sending of advertising. This processing is carried out on the basis of our legitimate interest in expanding our customer base, but you may object to your data being processed for these purposes at any time.

    As stated above these services only ask for basic identification data, i.e. we do not supply all of your personal data, or any preferences we are aware of, we merely provide an email account or telephone number which is shared in encrypted form and protected by tools provided by the platforms themselves, sufficient for the social network to identify you in its database.

    Secure communication techniques are also used, including the encryption of data before uploading it, to ensure the confidentiality and security of the information.

    Finally we do not obtain data about you directly from these third party platforms, i.e. we may obtain anonymous and statistical information but never precise information on your interests or whether you have seen a particular advertisement, unless you interact with us or the particular advertisement.

    If you do not wish us to use your data for advertising purposes in third party platforms you may contact us at the email and postal addresses given below. If we are already using it in these platforms we will erase it in the following update of the data supplied.

You may withdraw your consent to the sending of electronic commercial mailings at any time simply by following the instructions given at the foot of all electronic mailings sent by Pronovias or by sending an email to the address privacy@pronovias.com or writing to Polígono Industrial Mas Mateu, s/n., 08820 El Prat de Llobregat (Barcelona) enclosing in both cases a copy of your identity document or passport and indicating “Ref. Data protection” on the envelope (if you are using post) or in the reference field (if you are using email) and stating that you wish to withdraw your consent to the sending of electronic commercial mailings.

 

6. COMMUNICATION OF DATA

Your data will not be assigned, sold, hired out or in any other way made available to any third party, except for service providers of PRONOVIAS who provide certain services for us (for example the sending of the newsletter, marketing or customer service suppliers, data and database storage or handling, etc.), but not for their own purposes.

Without prejudice to the above, any data you supply in booking an appointment (including given and family names, contact details, preferences or date of event) may be communicated or assigned to the stores where you book an appointment, which may be operated by companies of the Pronovias Group (see link) in the case of own stores or by other companies (e.g. in the case of franchises or wholesalers managed by third parties). You will have the basic information on these third parties in the form. The third parties will process your data only in order to handle your appointment, but when you visit the store they may ask for your consent for additional processing

 

7. INTERNATIONAL TRANSFERS

As San Patrick is part of an international corporate group with stores and distributors around the world, your data may be processed outside the European Union or the European Economic Area (EU and EEA, respectively), for example, in our own stores or those of third party distributors located in the United States, among others, or to international suppliers that may provide their services from outside the EU.

We ensure that such transfers of data are always protected with the appropriate safeguards and by way of the mechanisms provided for by regulations, which may include:

  • Standard clauses approved by the EU: These are contracts approved by the European regulator and which provide sufficient guarantees that the processing complies with the requirements laid down in the European Data Protection Regulation. 

  • Third party certificates: For example the Privacy Shield, a framework agreement between the EU and the United States which provides a standardised framework for data processing in accordance with the requirements of the European Data Protection Regulation.

You can request further information at any time on the safeguards adopted in each case.

 

8. DURATION OF PROCESSING AND PRESERVATION OF INFORMATION

We preserve the data in the Customer account, and hence all of the data concerning your interaction with us, including appointments booked, events you have attended, preferences and tastes in dresses, for a period of five (5) years from your last interaction with us, which includes use of our website, reading our electronic mailings or visiting any of our stores.

If you have subscribed to our newsletter we will also process your data until we conclude, by the methods technologically available at any given time, that you no longer have an interest in our products (for example you do not use your Customer password to browse the website or you do not open our emails). You can also cancel your subscription to the newsletter at any time.

At the end of the period referred to in the first paragraph of this section seven (7), or when any of the circumstances referred to occurs, we will preserve your data in blocked form for the period of time necessary to comply with our legal obligations (for example the Consumer Protection Act and commercial or tax laws may oblige us to preserve certain data for a specific period). We also wherever possible preserve it in anonymous form for statistical or market research purposes.

 

9. EXERCISING YOUR RIGHTS

You may opt out of any of the above processes at any time without any consequences for your status as a Customer or contact of Saint Patrick.

Please note that if during your visit to any store you have provided additional data to another company that is not part of the PRONOVIAS GROUP (see link), you must exercise your rights before that company, in accordance with the information that, in compliance with the regulations, must be provided at the time your data is acquired.

You can also exercise your rights of access, rectification, erasure, restriction or portability in relation to any data you have provided to any company of the PRONOVIAS GROUP (see link) by writing to PRONOVIAS at PRONOVIAS, Calle Om, 16, Polígono Industrial Mas Mateu, S/N, 08820 Barcelona (Spain) or sending an email to privacy@pronovias.com.

You can also make submissions to the Data Protection Committee of PRONOVIAS if you consider Pronovias or Pronovias Online has processed your data in breach of this General Privacy Policy and any other related regulations currently in force, by electronic communication to gdprcommittee@pronovias.com and, if you do not receive a reply or you do not agree with the information received, you can contact the relevant supervisory authority.

We may ask you for documentation proving your identity to carry out your request if this is required by local regulations.

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