Privacy Policy and Data Protection

Privacy Policy

 

1. Introduction

1.1 We are committed to safeguarding the privacy of visitors to our website and users of our service.

1.2 This policy applies when we act as data controllers with respect to the personal data of visitors to our website and users of the service; in other words, where we determine the purposes and means of processing those personal data.

1.3 We use cookies on our website. To the extent that those cookies are not strictly necessary for the provision of our website and services, we will request your consent for the use of cookies when you first visit our website.

1.4 In this policy, "we", "us" and "our" refer to Skirmshop Spain SL. [For more information about us, see Section 13.]

 

2. Basis

This document was created using a template from SEQ Legal (https://seqlegal.com).

You must retain the above credit. Use of this document without the credit constitutes a copyright infringement. However, you may purchase from us an equivalent document that does not include the credit. 

 

3. How we use your personal data 

3.1 In this Section we have set out:

(a) The general categories of personal data that we may process.

(b) Where personal data has not been obtained directly from you, the source and specific categories of such data.

(c) The purposes for which we may process personal data.

(d) The legal bases for processing. 

3.2 We may process data regarding your use of our website and services ("usage data"). Usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytical tracking system. These usage data may be processed for the purpose of analyzing the use of the website and services. The legal basis for this processing is consent OR our legitimate interests, namely monitoring and improving our website and our services. 

3.3 We may process data relating to your account ("account data"). Account data may include your name and email address. The source of the account data is you. Account data may be processed for the purpose of operating our website, providing our services, ensuring the security of our website and services, maintaining backups of our databases, and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and our business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. 

3.4 We may process information included in your personal profile on our website ("profile data"). Profile data may include your name, address, phone number, email address, date of birth, and DNI. Profile data may be processed for the purpose of enabling and monitoring your use of our website and services. The legal basis for this processing is consent OR [our legitimate interests, namely the proper administration of our website and our business OR the performance of a contract between you and us and/or taking the measures you request to enter into such a contract.]

3.5 We may process your personal data provided in the course of using our services ("service data"). Service data may include data defined in the clause as "profile data". The source of the service data is you. Service data may be processed for the purpose of operating our website, providing our services, ensuring the security of our website and services, maintaining backups of our databases, and communicating with you. The legal basis for this processing is consent and our legitimate interests, namely the proper administration of our website and our business.

3.6 We may process information contained in any inquiry you send to us regarding goods and/or services ("enquiry data"). Enquiry data may be processed for the purpose of offering, marketing, and selling to you relevant goods and/or services. The legal basis for this processing is consent. 

3.7 We may process information relating to transactions, including purchases of goods and services, that you make with us and/or through our website ("transaction data"). Transaction data may include your contact details, your card details, and transaction details.] Transaction data may be processed for the purpose of supplying the purchased goods and services and maintaining proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and our business. 

3.8 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). Notification data may be processed for the purpose of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

3.9 We may process information contained in or related to any communication you send to us ("correspondence data"). Correspondence data may include the content of the communication and the metadata associated with the communication. Our website will generate the metadata associated with communications made via the website's contact forms. Correspondence data may be processed for the purpose of communicating with you and maintaining records. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users. 

3.10 We may process any of your personal data identified in this policy when necessary for the establishment, exercise, or defense of legal claims, whether in judicial proceedings or in an administrative or extrajudicial procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights, and the legal rights of others. 

3.11 We may process any of your personal data identified in this policy when necessary for the purpose of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the adequate protection of our business against risks. 

3.12 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data when such processing is necessary to comply with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person. 

3.13 Do not provide us with the personal data of any other person unless we request it.

 

4. Providing your personal data to others

 4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company, and all its subsidiaries) to the extent reasonably necessary for the purposes and legal bases set out in this policy. [You can find information about our group of companies at https://www.skirmshop.co.uk/service/about/.]

 4.2 We may disclose your personal data to our insurers and/or professional advisors to the extent reasonably necessary for the purpose of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or extrajudicial procedure.

4.3 Financial transactions related to our website and services are or may be handled by our payment service providers, [identify PSP]. We will share transaction data with our payment service providers only to the extent necessary for the purposes of processing your payments, refunding such payments, and addressing complaints and inquiries related to such payments and refunds. You can find information about the privacy policies and practices of payment service providers at [URLs].

4.4 We may disclose your enquiry data to one or more of those third-party providers of goods and services identified on our website for the purpose of enabling them to contact you so that they may offer, market, and sell to you relevant goods and/or services. Each of these third parties will act as a data controller in relation to the enquiry data we provide to you; and when contacting you, each third party will provide you with a copy of their own privacy policy, which will govern the use of your personal data by that third party.

4.5 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data when such disclosure is necessary to comply with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data when such disclosure is necessary for the establishment, exercise, or defense of legal claims, whether in judicial proceedings or in an administrative or extrajudicial procedure.

 

5. International transfers of your personal data 

5.1 In this Section, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA). 

5.2 We and the other companies in our group have offices and facilities in several countries. The European Commission has taken an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which may be obtained from [source]] OR [the use of binding corporate rules, a copy of which may be obtained from [source]] OR [[specify appropriate safeguards and means to obtain a copy]].] 

5.3 The hosting facilities for our website are located in [specify countries]. [The European Commission has taken an "adequacy decision" with respect to [the data protection laws of each of these countries].] [Transfers to [each of these countries] will be protected by appropriate safeguards, namely [the use of standard data protection clauses adopted or approved by the European Commission, a copy of which may be obtained from [source]] OR [[specify appropriate safeguards and means to obtain a copy]].] 

5.4 [Specify category or categories of provider or subcontractor] [is] OR [is] located in [specify countries]. [The European Commission has taken an "adequacy decision" with respect to [the data protection laws of each of these countries].] [Transfers to [each of these countries] will be protected by appropriate safeguards, namely [the use of standard data protection clauses adopted or approved by the European Commission, a copy of which may be obtained from [source]] OR [[specify appropriate safeguards and means to obtain a copy]].] 

5.5 You acknowledge that [personal data you send for publication via our website or services] may be available, via the Internet, worldwide. We cannot prevent the use (or misuse) of such personal data by third parties.

 

6. Retention and deletion of personal data 

6.1 This Section sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations regarding the retention and deletion of personal data. 

6.2 Personal data that we process for any purpose or purposes will not be kept longer than necessary for that purpose or those purposes. 

6.3 We will retain your personal data as follows:

a) category or categories of personal data will be retained for a minimum period necessary to process your orders, and for a maximum period of [period] following [date].    

6.4 In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the retention period based on the following criteria: 

a) the retention period of [category of personal data] will be determined based on [specify criteria]. [additional list items] 

6.5 Without prejudice to the other provisions of this Section 6, we may retain your personal data when such retention is necessary to comply with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person. 

 

7. Amendments 

7.1 We may update this policy from time to time by publishing a new version on our website. 

7.2 You should check this page from time to time to ensure that you are satisfied with any changes to this policy. 

7.3 We may notify you of significant changes to this policy by email or via the private messaging system on our website.

 

8. Your rights

8.1 In this Section, we have summarized the rights you have under data protection law. Some of these rights are complex and not all details have been included in our summaries. Consequently, you should read the relevant laws and guidance from regulatory authorities for a complete explanation of these rights.

8.2 Your principal rights under data protection law are:

(a) the right of access.

(b) the right of rectification.

(c) the right to erasure.

(d) the right to restrict processing.

(e) the right to object to processing.

(f) the right to data portability.

(g) the right to lodge a complaint with a supervisory authority.

(h) the right to withdraw consent.

8.3 You have the right to be confirmed whether or not we process your personal data and, when we do, to access your personal data, together with certain additional information. That additional information includes details of the purposes of processing, the categories of personal data concerned, and the recipients of the personal data. Where the rights and freedoms of others are not affected, we will provide you with a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. [You may access your personal data by visiting your account page when logged in to our website].

8.4 You have the right to have any inaccurate personal data concerning you rectified and, taking into account the purposes of the processing, to have any incomplete personal data concerning you completed.

8.5 In certain circumstances, you have the right to have your personal data erased without undue delay. Those circumstances include: the personal data is no longer necessary in relation to the purposes for which it was collected or processed; you withdraw your consent for processing based on consent; you object to processing under certain rules of the applicable data protection law; the processing is for direct marketing purposes; and the personal data has been processed unlawfully. However, there are exceptions to the right to erasure. General exceptions include where processing is necessary: to exercise the right to freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise, or defense of legal claims.

8.6 In certain circumstances, you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; the processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you need it for the establishment, exercise, or defense of legal claims; and you have objected to processing, pending verification of such objection. When processing has been restricted on this basis, we may continue to store your personal data. However, we will only process it otherwise: with your consent; for the establishment, exercise, or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest. 

8.7 You have the right to object to our processing of your personal data for reasons relating to your particular situation, but only to the extent that the legal basis for processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority conferred on us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease processing the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing is for the establishment, exercise, or defense of legal claims. 

8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease processing your personal data for this purpose. 

8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes for reasons relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

8.10 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used, and machine-readable format. However, this right does not apply where it adversely affects the rights and freedoms of others. 

8.11 If you consider that our processing of your personal information infringes data protection laws, you have the legal right to lodge a complaint with a data protection supervisory authority. You may do so in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement. 

8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. The withdrawal will not affect the lawfulness of processing before the withdrawal. 

8.13 You may exercise any of your rights in relation to your personal data by written notice, in addition to the other methods specified in this Section 8]. 

 

9. About cookies

9.1 A cookie is a file containing an identifier (a string of letters and numbers) that a web server sends to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2 Cookies may be "persistent" cookies or "session" cookies: a web browser will store a persistent cookie and it will remain valid until the set expiry date, unless the user deletes it before the expiry date; a session cookie, on the other hand, will expire at the end of the user's session, when the web browser is closed.

9.3 Cookies usually do not contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored and obtained from cookies.

 

10. Cookies we use

10.1 We use cookies for the following purposes:

(a) authentication: we use cookies to identify you when you visit our website and while you navigate our website] [(the cookies used for this purpose are: [identify cookies])]];

(b) state: we use cookies to help us determine whether you are logged in to our website (the cookies used for this purpose are: [identify cookies])]];

(c) personalization: we use cookies to store information about your preferences and to personalize the website for you (the cookies used for this purpose are: [identify cookies])]];

(d) security: we use cookies as an element of security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally [(the cookies used for this purpose are: [identify cookies]) )]];

(e) advertising: we use cookies [to help us show advertisements that will be relevant to you (the cookies used for this purpose are: [identify cookies])]];

(f) analytics: we use cookies [to help us analyze the use and performance of our website and services (the cookies used for this purpose are: [identify cookies])]]; and

(g) cookie consent: we use cookies to store your preferences regarding the use of cookies more generally (the cookies used for this purpose are: [identify cookies])]].

 

11. Cookies used by our service providers

11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11.2 We use Google Analytics to analyze the use of our website. Google Analytics collects information about website usage through cookies. The information collected in relation to our website is used to generate reports about website usage. Google's privacy policy is available at: https://www.google.com/policies/privacy/. [The relevant cookies are: [identify cookies].]

11.3 We publish interest-based Google AdSense advertisements on our website. Google adapts them to reflect your interests. To determine your interests, Google tracks your behavior on our website and on other websites on the web using cookies. This behavioral tracking enables Google to adapt the advertisements you see on other websites to reflect your interests (but we do not publish interest-based advertisements on our website). You can view, delete, or add interest categories associated with your browser by visiting: https://adssettings.google.com. You may also opt out of participating in the AdSense Partner Network cookie using that setting or by using the Network Advertising Initiative's voluntary multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. However, these voluntary opt-out mechanisms use cookies, and if you delete your browser's cookies, your voluntary opt-out will not be maintained. To ensure that a voluntary opt-out is maintained for a particular browser, you may wish to consider using the Google browser extensions available at: https://support.google.com/ads/answer/7395996. [The cookies are: [identify cookies].]

 

12. Managing cookies 

12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser and from version to version. However, you can obtain up-to-date information about blocking and deleting cookies via these links: 

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome); 

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox); 

(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera); 

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer); (e) https://support.apple.com/kb/PH21411 (Safari); and 

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge). 

12.2 Blocking all cookies will have a negative impact on the usability of many websites. 

12.3 If you block cookies, you will not be able to use all the functions of our website. 

 

13. Our details 

13.1 This website is owned and operated by Skirmshop Spain SL. 

13.2 You can contact us by email, using the email address published on our website. The contact details of our Data Protection Officer are: info@skirmshop.es

14. Processing and User Data

"In order to offer you Klarna payment methods, at the time of payment, we may transmit to Klarna during the purchase process your personal data included in the contact form and order details, so that Klarna can assess whether you meet the requirements to access its payment methods and to adapt such payment methods to your profile. Your personal data is processed in accordance with the provisions of the Klarna privacy policy.”