Privacy Policy
PRIVACY POLICY
In accordance with the obligations of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation, "GDPR"), together with Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights, Daughters of Cordera S.L. makes this Privacy Policy available through cordera.es in order to provide information about the processing of personal data, the measures adopted to protect privacy and the information provided by users.
In the event of any modification to this Privacy Policy, CORDERA will communicate the changes through this website or by any other appropriate means so that users may be informed of the updated conditions.
DATA CONTROLLER
Data controller: Daughters of Cordera S.L. (hereinafter, "CORDERA", the "Data Controller" or the "Controller").
Representative: Mónica Cordera
Tax Identification Number (NIF): B32426157
Registered office: Calle Real, 85, 4º, 15003 A Coruña, Spain
E-mail address: info@cordera.es
Business activity: fashion and accessories
PERSONAL DATA PROCESSED
CORDERA processes personal data to provide its services and manage its relationship with users and customers. CORDERA does not intentionally process special categories of personal data unless such processing is required and permitted by applicable law.
If a user provides personal data relating to third parties, the user is responsible for ensuring that such data have been lawfully obtained and that the third party has been appropriately informed where required.
CORDERA may process the following categories of personal data:
1. Identification data: name, surname and, where applicable, identification document or equivalent information.
2. Contact data: e-mail address, telephone number, postal address and other contact information.
3. Payment, billing and transaction data: information necessary to process payments, refunds, invoicing and transactions associated with purchases.
4. Order and service data: information relating to products purchased, orders, order status, delivery, returns, refunds and customer service interactions.
5. Data provided through the contact channels available on the website, including telephone and e-mail communications.
6. Browsing and device data collected through cookies and similar technologies in accordance with the applicable Cookies Policy.
7. International order data: information required to process cross-border purchases, including delivery destination, shipping information, payment status, fraud prevention information, taxes, duties, customs formalities, delivery and return information.
PURPOSES AND LEGAL BASIS FOR PROCESSING
CORDERA collects and processes personal data for the purposes described below:
- Management of user registration and customer accounts.
- Management and fulfilment of purchases and orders placed through the website.
- Management of domestic and international orders, including payment processing, fraud prevention, calculation and collection of applicable taxes and duties, customs formalities, shipping, delivery, returns and refunds.
- Management of requests for information, suggestions, enquiries, complaints and customer service communications.
- Communication with customers and potential customers through the website, e-mail, social media or other communication channels.
- Sending commercial communications, newsletters, product information, news and other marketing communications where legally permitted.
- Management of employment relationships.
- Management of commercial relationships with suppliers and service providers.
- Management of recruitment and personnel selection processes.
- Technical maintenance, security and proper functioning of the website and associated services.
- Analysis of the use and performance of the website and services in order to improve functionality and user experience.
- Marketing, advertising and personalization purposes where legally permitted.
CORDERA collects personal data through different channels and, where required, provides the corresponding information regarding the identity of the controller, the purposes and legal basis of the processing, the recipients of the data, the applicable storage periods and the means available to exercise data protection rights.
For the management of purchases and contracted services, CORDERA primarily processes identification, contact, order, transaction, billing, delivery and return information.
For employment and recruitment purposes, CORDERA may also process academic, professional and employment-related information.
Through its website, CORDERA may collect browsing information through cookies and similar technologies. Detailed information regarding the cookies used, their purposes and available configuration options can be found in the Cookies Policy.
The legal bases applicable to the processing activities described above include:
1. User registration and account management:
(a) The user's consent where required.
(b) The performance of a contract or the application of pre-contractual measures where registration is necessary to provide the requested service.
2. Management, processing and fulfilment of orders:
(a) The performance of a contract, including processing purchases, payments, delivery, returns and refunds.
(b) Compliance with applicable legal obligations, including tax, accounting, customs and regulatory obligations where applicable.
(c) CORDERA's legitimate interest in preventing fraud, protecting transactions and maintaining the security of its services, where such interest is applicable and does not override the rights and freedoms of the data subject.
3. Requests for information, suggestions, enquiries and complaints:
(a) The consent of users or customers who contact CORDERA.
(b) The performance of a contract or pre-contractual measures where the enquiry relates to an existing or potential purchase.
4. Technical maintenance, security and improvement of the website and associated services:
(a) CORDERA's legitimate interest in ensuring the security, proper functioning and continuous improvement of its website and digital services.
5. Marketing and advertising purposes:
(a) The user's consent where legally required, including subscription to newsletters and the use of certain cookies or similar technologies.
(b) CORDERA's legitimate interest where applicable under data protection and electronic communications regulations.
Where processing is based on consent, each consent is independent and may be withdrawn without affecting the lawfulness of processing carried out before its withdrawal or any other processing based on a different legal basis.
RECIPIENTS AND SERVICE PROVIDERS
CORDERA does not disclose personal data to third parties except where necessary to provide the requested services, fulfil contractual obligations, comply with legal requirements or where another lawful basis applies.
In order to operate the website, process purchases and provide its services, CORDERA may engage third-party providers that require access to certain personal data.
These providers may include, among others:
- e-commerce and technology service providers;
- payment service providers;
- fraud prevention and transaction security providers;
- logistics operators and carriers;
- customs agents and customs service providers;
- tax and regulatory service providers;
- providers involved in the processing and management of international orders;
- providers involved in returns and refunds;
- hosting, cloud infrastructure and information technology providers;
- e-mail, customer service and communication providers;
- legal, accounting, auditing and professional advisers.
In connection with international orders, personal data may be shared with service providers involved in cross-border e-commerce operations where necessary to process and fulfil the purchase. This may include the processing of payments, fraud prevention, calculation and collection of applicable taxes and duties, customs formalities, shipping, delivery and returns.
Depending on the nature of the service and the applicable data protection framework, these third parties may act as data processors on behalf of CORDERA or as independent data controllers in relation to specific processing activities.
Where a provider acts as a data processor, it will process personal data in accordance with CORDERA's instructions and the applicable contractual and legal requirements relating to confidentiality, security and data protection.
Personal data may also be disclosed to public authorities, courts, tax authorities, customs authorities, regulatory bodies or other competent authorities where required by law or where necessary to comply with a legal obligation.
INTERNATIONAL DATA TRANSFERS
In connection with the provision of services, particularly those related to international e-commerce, technology infrastructure, payments, logistics, fraud prevention and customer communications, personal data may be processed or accessed from countries outside the European Economic Area ("EEA").
Where personal data are transferred outside the EEA, CORDERA will ensure that an appropriate legal transfer mechanism is in place in accordance with applicable data protection law.
Such mechanisms may include:
- an adequacy decision adopted by the European Commission;
- Standard Contractual Clauses approved by the European Commission;
- other transfer mechanisms permitted under the GDPR; and
- where required, additional technical, contractual or organizational safeguards designed to ensure an appropriate level of protection for personal data.
STORAGE PERIOD
CORDERA will retain personal data only for as long as necessary to fulfil the purposes for which they were collected, comply with applicable legal obligations and address any liabilities that may arise from the processing.
Where personal data are processed in connection with purchases, orders, payments, invoicing, shipping, returns or other contractual services, the information may be retained for the duration of the contractual relationship and thereafter for the periods required by applicable tax, accounting, commercial, consumer protection or other relevant legislation.
If CORDERA processes personal data solely to respond to an enquiry or request for information, the data will generally be retained for a maximum period of two years, unless a longer period is required for legal or contractual reasons.
Data associated with user accounts, contact forms, other enquiries and newsletter subscriptions may be retained until the user requests deletion, withdraws consent where applicable, unsubscribes or the data are no longer necessary for the relevant purpose.
Where a user exercises the right to erasure or restriction of processing, personal data may be blocked and retained where necessary for the establishment, exercise or defence of legal claims or to comply with applicable legal obligations.
RIGHTS OF DATA SUBJECTS
Users may exercise the following rights before CORDERA where applicable:
(a) Right of access
(b) Right to rectification
(c) Right to erasure ("right to be forgotten")
(d) Right to restriction of processing
(e) Right to data portability
(f) Right to object
(g) Right not to be subject to a decision based solely on automated processing where the requirements established by applicable law are met
The exercise of these rights is free of charge, except where requests are manifestly unfounded or excessive, particularly because of their repetitive nature. In such cases, CORDERA may charge a reasonable fee based on the administrative costs involved or refuse to act on the request in accordance with applicable law.
Requests must be submitted by the data subject or an authorized representative. CORDERA may request information necessary to verify the identity of the person making the request where there are reasonable doubts regarding identity.
CORDERA will respond to requests within one month of receipt. Taking into account the complexity and number of requests, this period may be extended by a further two months where permitted by law. In such cases, the data subject will be informed of the extension and the reasons for it.
If CORDERA does not act on a request, the data subject will be informed of the reasons and of the possibility of lodging a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos).
These rights may be exercised by sending a written request to the postal address indicated in the "Data Controller" section or by e-mail to info@cordera.es, indicating "Exercise of GDPR Rights" in the subject line.
RESPONSIBILITY OF THE USER
By providing personal data to CORDERA through electronic channels, the user guarantees that the information provided is true, accurate, complete and up to date and undertakes to keep such information updated where necessary.
The user is responsible for any false, inaccurate or incomplete information provided and for any consequences that may arise from the provision of such information.
DATA SECURITY
CORDERA implements appropriate technical and organizational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, taking into account the state of the art, the nature and scope of the processing and the risks to the rights and freedoms of individuals.
CORDERA also maintains measures designed to strengthen the confidentiality, integrity and availability of information and regularly reviews its internal processes and security controls in order to maintain an appropriate level of data protection.
MODIFICATIONS TO THIS PRIVACY POLICY
CORDERA reserves the right to modify this Privacy Policy at any time in order to adapt it to legislative, regulatory or jurisprudential developments, changes in its services or processing activities, or relevant industry practices.
Where appropriate, material changes will be communicated through this website or by other suitable means before they become effective.
CORDERA recommends reviewing this Privacy Policy periodically in order to remain informed of its most recent version.
