21 BUTTONS APP, S.L., as responsible for the website uk.mylooks.21buttons.com, in accordance with the provisions of Regulation (EU) 2016/679 of 27 April 2016 (GDPR) on the protection of individuals with regard to the processing of personal data and the free transfer of these data and other regulations in force related to the protection of personal data, and in accordance with the Law 34/2002, of 11 July, of Servicios de la Sociedad de la Información y del Comercio Electrónico (LSSICE), informs you that it has implemented the necessary technical and organisational security measures to guarantee and protect the confidentiality, integrity and availability of the data
1. TREATED DATA
21 buttons looks treats the following personal data to which it has access by the following means:
a. User Profile Data: in order to create an account and register as a web user (the / the "User" or "Users") and / or perform certain actions on the web (for example to contact 21 buttons looks) the User must complete the electronic registration form that appears on the web providing a series of data necessary for the provision of our services. In the registration form some mandatory data is specified, and the refusal by users to provide it will imply that they will not be able to register as a user (in the case of the registration form) or to perform certain actions determined on the web (for example, contact us). Likewise, the fact of being a registered User in the web implies having a profile with open fields in which the User can indicate what he considers appropriate (except for the Prohibited Data indicated below).
The data requested in the registration form are: (1) Name and surname (2) e-mail address, (3) physical address, (4) telephone number and (5) payment methods. Bank information regarding payment methods will be collected and stored by Stripe. When offering a monthly subscription service the user must provide us with a credit card number (visa or mastercard) to make payments. Also, if the user needs to have an invoice issued it must complete his registration with the following data: Name and surname (if a natural person) or Name of the company (if a legal person), Address and Tax Number.
Once the user registers and signs up for one of the monthly subscriptions, a form will be sent where, in addition to the data mentioned above, you will be asked for information regarding sizes and fashion tastes.
b. Data associated with web browsing: when a User accesses any of the webs, 21 buttons looks collects the navigation data associated with each one of the Users. In such way, all the actions carried out by the user within the website associated with the user ID, IP address, general information about the device and its operating system/browser, date and time, as well as the IDs of the rest of the elements associated with that action are collected.
d. Data regarding your communications with 21 buttons looks: when you send us a communication, we collect the metadata of the same (time and date of the call or e-mail, identity of the sender and receiver, technical data) and the data incorporated in any communication between the User and 21 buttons looks.
The user guarantees (a) the authenticity and veracity of all data (especially but not only those that are personal data) communicated through the web, (b) that the data shared by him is personal data and that it reflects his own image or a third interested party’s from which he has permission to use such data, (c) and that he will keep updated the information provided to 21 buttons looks, so that it responds at all times to their real situation, him being the sole responsible for false or inaccurate statements made, as well as for the damage caused by it to 21 buttons looks or any third party.
2. PURPOSES FOR DATA PROCESSING
Your personal data will only be used for the following purposes:
• Carry out the necessary commercial and administrative formalities with the users of the platform;
• Send or view electronic commercial communications. They can be of two types: (a) recommendations of User Content or similar that -based on the information we have- we believe may be of interest to you (core functionality of our web services), (b) the periodic sending of electronic commercial communications (including e-mails) promoting or advertising the services and products offered by 21 buttons looks and 21 buttons app (the User will have the option of unsubscribing from the reception of these last types of electronic commercial communications and of opposing himself to the processing of personal data both in the data collection process and in each of the electronic commercial communications). In both types of electronic commercial communications the sectors involved will be fashion, accessories, clothing and lifestyle, in the broad sense as well as the services of 21 buttons looks. The communications may include links to external sites and promotions offered by brands or collaborating companies with 21 buttons looks and 21 buttons app.
• Track user activity on web portals to which users are redirected from the web (usually e-commerce portals of fashion brands or firms), including the registration of purchases or possible purchases of products and manage the relationship between 21 buttons looks and those responsible for those web portals;
• Respond to queries and/or provide information required by the User;
• Perform the services and/or products contracted or subscribed by the User.
• Use your data to contact you, both electronically and non-electrically, to obtain your opinion on the service provided and,
• Profiling and usage analysis will be performed.
• The data of clients and/or suppliers will be treated, within the contractual relationship that binds them with the person in charge, in compliance with the administrative, fiscal, accounting and labour obligations that are necessary by virtue of the legislation in force.
Specific purposes according to the different categories:
• Category “Data of the Forms of the Web and of the Profile”: The Web Page can include forms that are clearly linked to specific purposes which will be indicated (for example the data collected in the "contact form" will be treated for the purpose of answering and communicating with whoever wants to communicate with 21 buttons looks).
• Category “Data included in the User Content”: will only be treated by 21 buttons looks as processors (not as responsible party) according to the clause "9. 21 buttons looks as data processor".
To unsubscribe, you can access the Web at any time and go to the section: profile, options, edit profile, and choose the unsubscribe option.
If the above option is not enabled or does not work for any reason, you can also unsubscribe by sending an email with the subject "Unsubscribe User" to firstname.lastname@example.org, including in the body of the email your name and surname and email used to register on the web.
According to the LSSICE, 21 buttons looks does not practice SPAM, therefore, it does not send commercial e-mails that have not been previously requested or authorized by the User. Consequently, in all communications that the user will receive from 21 buttons looks, the user will have the ability to withdraw their consent to receive our communications.
We will not treat your personal data for any other purpose than those described except by legal obligation or injunction.
Your data will be kept for the duration of the commercial relationship between us or until you exercise your right of cancellation or opposition, or limitation to treatment. However, we will keep certain personal identification and traffic data for a maximum period of 2 years in the event that it is required by the Judges and Courts or to initiate internal actions arising from improper use of the website.
You will not be subject to decisions based on automated processing that produce effects on your data.
3. LEGITIMATION OF DATA PROCESSING
The legal basis for the processing of data is your consent given to carry out the purposes described above, which will be requested at the time the user registers on the platform and accepts the conditions of service.
Failure to provide the personal data requested or not to accept this data protection policy means the impossibility of subscribing, registering or receiving information about the Provider's products and services.
In cases where there is a prior contractual relationship between the parties, the legitimacy for the development of administrative, fiscal, accounting and labour obligations that are necessary under current legislation will be the prior existence of the commercial relationship established between the parties.
In any case, the free and voluntary subscription to the website of 21 buttons looks is considered as the establishment of a contractual relationship between 21 buttons looks and the user. This relationship is based on the provision of information on fashion, accessories, and clothing in a broad sense by 21 buttons looks to the user. Therefore, sending informative communications that fall into this category is considered part of the service contracted by the user at the time of subscribing to the app. This is without prejudice to the fact that the user may, at any time, unsubscribe from the communications or configure their profile not to receive them.
Any communication sent will be incorporated into the information systems of 21 buttons looks. By accepting these conditions, terms and policies, the User expressly consents 21 buttons looks to perform the following activities and / or actions, unless the User indicates otherwise:
• Sending commercial and / or promotional communications by any means enabled informing users of activities, services, promotions, news, offers and other information related to services and products offered by 21 buttons.
• If the User has expressly consented to the emailing of commercial communications by subscribing to the Newsletter, the emailing of such communications by electronic means informing Users of the activities, services, promotions, advertising, news, offers and other information on the services and products of 21 buttons looks, or other products or services that are similar and that may be of interest to the User.
• The conservation of the data during the terms foreseen in the applicable dispositions.
5. OFFICIAL MEANS OF COMMUNICATION
The user is informed that the means enabled by the company to communicate with customers and others affected is the corporate phone, corporate mobile phones and corporate email.
If you send personal information through a means of communication other than those indicated in this section, 21 buttons looks will be exempt from any liability in relation to the security measures of such chosen means of communication.
6. ASSIGNMENTS OR TRANSFERS AND CONSENTS TO DISPLAY
21 buttons looks carries out transfers to third parties that proceed to the treatment and manipulation of the data as well as international transfers with the same purpose. The user expressly accepts the transfer of his data to the 21 buttons app as long as it is limited to the purposes indicated in this document and especially to the contents in the first clause.
Also, 21 buttons will provide information to law enforcement agencies under court order or by obligation of a legal rule, without prejudice to blocking or cancelling your account if there may be evidence of the commission of a crime by the user. The information provided will be only that which is currently available to the provider.
The information you provide us through the web will be hosted on the servers of 21 buttons looks.
7. RIGHTS OF ALL INTERESTED PARTIES
As an interested party, you can request the exercise of the following rights before 21 buttons looks by submitting a letter to the address of the heading or sending an email to email@example.com, indicating as subject: "GDPR: Rights affected", and attaching a photocopy of your ID card or any analogous document in law.
• Right of access: allows the interested party to know and obtain information about their personal data subject to treatment.
• Right of rectification or suppression: right to correct errors and to amend data that appears to be inaccurate or incomplete.
• Right of cancellation: right to delete any data that proves to be inadequate or excessive.
• Right of opposition: right of the data subject not to have his personal data processed or ceased to be processed.
• Limitation of processing: entails the marking of stored personal data in order to limit their future processing.
• Portability of data: the provision of the data undergoing processing to the data subject, so that the data subject may transmit them to another data controller without impediment.
• Right not to be the subject of automated individual decisions (including profiling): right not to be the subject of a decision based on automated processing that produces effects or significantly affects.
As a user, you have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of the processing carried out prior to the withdrawal of consent.
You also have the right to lodge a complaint with the supervisory authority if you consider that your data protection rights may have been violated (agpd.es).
8. ADDITIONAL INFORMATION
8.1. INTELLECTUAL PROPERTY
8.2. SOCIAL NETWORKS
We inform you that 21 buttons looks can have presence in social networks. The treatment of the data that is carried out of the people that become followers in our social will be governed by this section, as well as by those conditions of use, privacy policies and regulations of access set out by each particular social network and which will have been previously accepted by the user.
21 buttons looks will treat your data for the purpose of correctly managing your presence on the social network, informing you of activities, products or services of the provider, as well as for any other purpose that the regulations of the Social Networks allow.
It is forbidden to publish any Contents which:
- Are allegedly illegal under national, EU or international law or that perform allegedly illegal activities or contravene the principles of good faith.
- Attempt against the fundamental rights of the people, disturb, generate any nuisance in the network, or can generate negative opinions in our users or third parties; as well as those contents that 21 buttons may consider inappropriate.
- In general, contravene the principles of legality, honesty, responsibility, protection of human dignity, protection of minors, protection of public order, protection of private life, consumer protection and intellectual property rights and industrial.
In addition, 21 buttons looks reserves the right to remove, without prior notice from the corporate social network, those contents that are considered inappropriate.
The communications sent through the social networks will be incorporated into a file owned by 21 buttons looks, being able to send you information of interest.
In any case, if you send personal information through any social network, 21 buttons looks will be exempt from responsibility in relation to the security measures applicable to such platform, having the user to consult their corresponding particular conditions.
8.3. SECURITY MEASURES
The data you provide will be treated confidentially. 21 buttons has adopted all the technical and organisational measures and all the necessary levels of protection to guarantee the security in the treatment of the data and to avoid its alteration, loss, theft, treatment or unauthorised access, in accordance with the state of the technology and the nature of the data stored. Likewise, it is also guaranteed that the treatment and registration in files, programs, systems or equipment, premises and centres comply with the requirements and conditions of integrity and security established in current legislation.
8.4. SENDING YOUR CV
In the event that the user sends his/her CV through our website http://jobs.21buttons.com, we inform you that the data provided will be processed with the goal of making the user part of any selection processes, as well as carrying out an analysis of the applicant's profile with the aim of selecting the best candidate for the vacant position of the person in charge. We inform you that this is the only official procedure for accepting your CV, so CVs sent by another procedure will not be accepted. In the event of any change in the data, please notify us in writing as soon as possible, in order to keep your data properly updated.
The offers will also be published on our social networks. However, the CV may only be sent via the website set up for this purpose.
The data will be kept for a maximum period of one year, after which the data will be deleted, guaranteeing total confidentiality both in the treatment and in its subsequent destruction. In this sense, after the aforementioned period has elapsed, and if you wish to continue participating in the selection processes of the person in charge, please send us your curriculum again.
The data may be processed and/or communicated to the member companies of our group during the time of conservation of your curriculum and for the same purposes previously informed.
9. 21 BUTTONS AS TREATMENT MANAGER
The User, while using the services provided by 21 buttons looks through the web and while using the actual web may include, through User Content, any personal data of third parties or their own ("Content Data"). This User is solely responsible for these Content Data, as "Responsible of Treatment". 21 buttons looks provides a service of treatment of this information in the name and account of the User, as "Treatment Manager" in order to allow the use of the Platform and provide the services offered through the Platform.
To the extent that 21 buttons looks is "Treatment Manager", 21 buttons (a) implements technical and organizational measures to safeguard the Content Data of any access, loss, destruction, theft, use or unauthorized or unlawful disclosure; (b) treats only the Content Data in accordance with the instructions provided by the User, which include the configuration of his User Account and indications ("clicks" on the Platform) regarding this particular material, (c) does not use the Content Data for purposes other than those related to the development of the Services or according to the instructions provided by the user, (d) does not communicate the Content Data, not even for conservation by third parties (this does not preclude that if a User's instruction is that a User Content should be public and logically subject to recommendations 21 buttons looks complies with that instruction and allows access to Users of such Content Data and may even recommend the display of such User Content).
Upon expiration or termination of this Agreement by reason of termination of the User Account of the User responsible for these Content Data, we will stop using any Content Data and destroy it. 21 buttons looks reserves the right to save such stored Content Data before removing it for as long as 21 buttons looks may be subject to liability as a result of such data processing. If you detect that another User uses in 21 buttons looks your old Content Data without being authorized, you must inform 21 buttons looks of it, since 21 buttons looks does not monitor, edit or control the User Content.
The User responsible for the Content Data authorizes us as the Treatment Manager to allow access and treatment of such Content Data to one or more service providers (data hosting and messaging), as a subcontractor on your behalf, if we reasonably consider that such access and treatment is necessary for the development of the Services. These providers process the data for the sole purpose of providing the aforementioned services which we have indicated, and are currently the Google group (whose subsidiaries with possible access to the data would be: (i) Google Ireland Limited, with offices at Gordon House, Barrow Street, Dublin 4, Ireland, (ii) Google Asia Pacific Pte Ltd., with offices at 8 Marina View Asia Square 1 #30-01 Singapore 018960, or (iii) Google Inc, with offices at 1600 Amphitheatre Parkway, Mountain View, California 94043, (in Ireland, Singapore and the U.S.A. respectively); the Amazon group (whose subsidiaries with possible access to data are (i) Amazon.com, Inc. in the U.S.A. and (ii) Amazon Web Service Ireland Ltd. in Ireland); or the Facebook group (whose subsidiaries with possible access to data are (i) Facebook, Inc, with offices at 1601 S California Ave; Palo Alto, California 94304 and (ii) Instagram, Inc. with offices at 1601 Willow Rd; Menlo Park, California 94025). The countries outside the European Economic Area where data may be processed (all of them except Ireland) may not have personal data protection standards equivalent to those in Spain/Europe). Before such processing takes place, we will ensure that you have entered into a contract with such third parties that is sufficient to commit you to processing personal data in accordance with the applicable provisions of this Policy.
The User responsible for the Content Data declares and guarantees to have all the necessary consents of the persons whose personal data will be treated in accordance with this clause (including the International Transfer of data from this subcontracting or to other users of the Platform from other countries to which it has access). The User responsible for the Content Data will indemnify 21 buttons looks and exempt him from liability in relation to any claim, damage or loss that may suffer that is related to the processing of personal data of third parties treated in accordance with this clause.
21 buttons looks reserves the right to modify this policy to adapt it to any new legislation or jurisprudence.
To all effects the relations between 21 buttons looks with the Users of its services are subject to the Spanish legislation and jurisdiction, to which the parties expressly submit, being competent for the resolution of all the conflicts derived or related to its use the Courts and Tribunals of BARCELONA.