Information on the protection of personal data on registered website customers

Controller

Who is the data controller?

- OSBORNE DISTRIBUIDORA S.A.

- C.I.F. [Tax ID]: A-28318871

- Address: c/ Salvatierra, 6 – 28034 – Madrid

- Telephone: 917283880

- Email address for requests relating to personal data: rgpd@osborne.es


Purpose

Why do we process your data?

OSBORNE DISTRIBUIDORA S.A. processes the data you provide for the following purposes:

- To forward queries to the areas of the Osborne Group companies responsible for the request, query and/or complaint.

- Customer loyalty schemes: processing of personal data relating to management and customer service to offer benefits as a result of loyalty to the brand through regular purchases of Osborne products, which may lead to campaigns to encourage customer loyalty or to approach prospective customers to establish a close and lasting relationship with the brand.

- To send our newsletter and marketing information by physical and/or electronic means.

- To analyse browsing habits and the usability of our website and identify the sales generated after sending out our newsletter, so as to determine consumer profiles and preferences and provide a more personalised service focused on the priorities of our customers. We also process the data to prepare statistics and detect weaknesses to improve our website processes.

Legal basis

What is the legal basis for processing your data?

The legal basis for processing the data is:

-  contract or legal relationship for the management of product purchases, and related queries: Article 6(1)(b) of the EU General Data Protection Regulation.

-  for loyalty schemes, preference profiling and browsing analytics: Article 6(1)(a) of the EU General Data Protection Regulation.

-  Consent to, and legitimate interest in, sending our newsletter and marketing information: Article 6(1)(a) and (f) and Recital 47 of the EU General Data Protection Regulation.

Recipients

Who do we share your data with?

- The personal data are only assigned to the OSBORNE Group companies to which the request by the person relates OSBORNE Group, and as necessary for compliance with legal obligations and to support services related to this data processing and the purposes thereof.

- In the event that provision of the services requires data to be shared with service providers inside and outside the European Union that assist in the administration of this processing, adhesion to the European Union-United States Privacy Shield or adequate compliance with guarantees of the confidentiality and security of the data processing is required.

- The provision of these processing services requires use of the Salesforce IT customer-management platform, which is subject to Binding Corporate Rules that enable personal data to be exported to entities outside the Salesforce group located outside the European Economic Area that have been approved by the data protection authorities of France, the Netherlands and Bavaria, Germany. The Salesforce platform is signed up to the US Privacy Shield platform. OSBORNE and Salesforce have signed standard contractual terms and conditions on the basis approved by the European Commission (https://eur-lex.europa.eu/legal-content/ES/TXT/PDF/?uri=CELEX:32010D0087&from=ES).

Storage

How long will we keep your data?

- Personal data strictly related to the purchase process, such as acquisition, purchase, delivery, returns and complaints, are retained for a period of six years from the sale, in accordance with the Spanish Commercial Code.

- Personal data relating to the other purposes are retained until the data subject formally objects to, or requests cessation of, the relevant processing.

Rights

What are your rights when you provide us with your data?

- Everybody is entitled to obtain confirmation of whether OSBORNE is processing personal data that affects them.

- Interested parties are entitled to access their personal data and request the rectification of any inaccurate data, or deletion of the data when, among other things, they are no longer necessary for the purposes for which they were collected.

- Under certain circumstances, interested parties may request limitation of the processing of their data, in which case the data will only be held for the exercise or defence of claims.

- Under certain circumstances, interested parties may object to the processing of their data for reasons related to their specific situation. In this case, OSBORNE shall cease to process their data, except for overriding legitimate purposes and for the exercise or defence of claims.

- Interested parties may request data portability to obtain the data they have provided to OSBORNE, in a structured and commonly-used format for mechanical reading, to be downloaded by themselves or transmitted by OSBORNE to another entity.

- A data subject may exercise his/her rights by writing an e-mail to rgpd@osborne.es

- If you are dissatisfied with the exercise of your rights, you can file a complaint with the competent Data Protection Agency, at the postal or electronic address given on its website, www.agpd.es.

Security

- Your data will be processed confidentially and subject to appropriate technical and organisational security measures to prevent unauthorised access, alteration, loss or processing.


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