PURPOSE
This privacy policy applies to the collection and use of personal data of customers and visitors of the website www.redleyeurope.com (hereinafter "website") by Cipriano e Maron, Lda (Redley Europe) (who manages this website and is responsible for marketing activities).
At Redley Europe we are committed to respecting and protecting the privacy and controlling the data management of our website (www.redleyeurope.com). We value your trust in sharing your personal data with us and recognize that you have the right to know how we handle that data.
This privacy policy ("Privacy Policy") applies to the collection and processing of personal data carried out:
i. When you interact with us through digital means, including the website http://www.redleyeurope.com (the "Site"), portals and mobile applications, managed by Redley Europe;
ii. When you purchase a product or request other services from Redley Europe, online on our Site or through Redley Europe Digital Platforms, including when you contact our customer service for after-sales services, specific questions or requests;
iii. When we communicate with you as part of our sales activities.
By accessing and using these Digital Platforms or providing your personal data, for example by visiting the shops or contacting our customer service, you confirm that you have read and understood how we collect, handle, use and disclose your personal data as described in this Privacy Policy.
For specific processing activities, we will always need to obtain your consent to collect and process your personal data. Where we need your consent, you will be asked, before you submit personal data or use the relevant sections of the Redley Europe Digital Platforms, to confirm electronically that you consent to the relevant processing activity as described in this Privacy Policy by ticking the specific boxes. Your consent, by ticking the relevant boxes, and your use of this Site means that you agree to the processing activity in question as described in this Privacy Policy. Our records of your acceptance of this Privacy Policy, the date and all future amendments to this Privacy Policy will be considered as irrefutable, written evidence of your consent.
You will also be informed about this Privacy Policy and, where a specific processing activity requires it, you will be asked for your consent when you contact our customer service or provide us with your personal data through in-store interactions.
We collect and process your personal data in accordance with all applicable data protection laws and regulations, including, but not limited to, laws enacted on the subject by the European Union, such as the General Data Protection Regulation (EU) 2016/679 of 27 April 2016 ("GDPR"), as well as orders and guidelines issued by competent data protection authorities, if applicable (the "Data Protection Laws").
WHAT INFORMATION WE COLLECT
We collect your personal data that you provide to us when you:
· use this website (e.g. by registering on the site, opening an account, downloading content, among others.)
· subscribe or participate in our marketing activities (e.g. newsletters, loyalty programs, etc.)
· purchase our products (online or in shop)
· contact our customer service
The Site aims to enable brand awareness, purchase and delivery of Redley® products directly to its consumers, according to availability and price conditions previously established. The data we collect are only those that allow the identification of the user/customer, to register and make possible the operations of purchase and delivery of products, in addition to data collected automatically as a result of the use of the site.
These are the following:
• Name
• E-mail address
• Date of birth
• Telephone Number
• Taxpayer number
• Billing Address
• Delivery address
• Information for payment purposes (encrypted)
WHAT WE USE YOUR INFORMATION FOR
We collect and process your personal information to:
• Manage this site
• to create your account and manage your site registration and newsletter;
• to improve and enhance your browsing experience;
• to provide you with after-sales services;
• to respond to your request(s) for information, enquiry(s), communication(s) or comments;
• send you marketing materials, allow you to participate in promotions, conduct customer surveys and profiling;
• to complete and manage your purchases, administer our customer service and respond to your requests;
• for the purposes of opinion survey (always subject to your consent, which is always optional and at your discretion);
• to send you (subject to your consent, which is optional), including via email or other electronic means of communication such as: SMS, MMS, fax, etc., information and promotional material about our products and services, about special pricing and promotional initiatives and about initiatives such as loyalty programs, events, exhibitions and fairs organized by Redley Europe;
• to improve our products and services;
• for the purposes of internal training and improving our customer service;
• for fraud prevention purposes, through procedures to verify the regularity of transactions, to protect our financial integrity Redley Europe and to protect you against data misuse and fraudulent purchases;
• to comply with our obligations under laws, regulations and to assess and defend a legal claim.
ENTITIES WITH WHOM WE SHARE YOUR INFORMATION
Redley Europe in which you purchase products may share your personal data with S2 Holding Group but, where required by law, we will ask for your consent before doing so.
We also share your personal data with:
• Vendors assisting us in hosting and administering this website and providing our products and services (these recipients act on our behalf and only in accordance with our instructions);
• third parties in case of legal procedures, requests from courts or authorities, other legal obligation, to defend our rights, or in case of merger, acquisition or transfer of assets.
Some of these recipients may be located outside the EEA, but we ensure that your personal data remains adequately protected at all times (if the destination country is one of the countries that the European Commission considers does not offer an adequate level of protection, we will cover the data transfer with appropriate security measures).
WHAT ARE THE LEGAL BASES FOR THE PROCESSING OF MY PERSONAL DATA AS DESCRIBED HERE?
We collect and process your personal data for the purposes described in the section "What we use your information for" according to one of the following legal bases:
• The processing of your personal data is necessary for the performance of a contract with you or for pre-contractual steps at your request (Article 6, 1., (b) of the GDPR);
• Processing is necessary for the purposes of our legitimate interests or the legitimate interests of our affiliates or third parties, except where your interests or fundamental rights and freedoms prevail (Article 6, 1., (f) of the GDPR); The legitimate interests pursued include our interest in managing and maintaining the contractual relationship with you, responding to your specific requests, soliciting your feedback to improve our Site and products or carrying out other general marketing activities.
• Where your specific consent is required for the processing of your personal data as described in this document, your personal data will be processed on the basis of that consent (Article 6, 1., (a) of the GDPR);
HOW LONG IS MY PERSONAL DATA TREATED?
Personal data will only be kept for as long as necessary to achieve the specific data processing purposes described in this document, unless shorter or longer retention periods apply in accordance with applicable law. This may be up to 10 years after the end of the contractual relationship with the customer (in accordance with statute of limitations on legal rights in most EEA countries), unless a shorter or longer retention period applies under applicable laws.
WHERE DOES MY PERSONAL DATA GO? WHO ARE THE RECIPIENTS, WHERE IS IT TRANSFERRED TO AND FOR WHAT PURPOSES?
Personal data collected via the website or other Redley Europe Digital Platforms, in connection with the sale of products and as part of our customer service, is stored on servers provided and managed by our external storage and hosting provider 4Leads, with registered office in Lisbon, servers located in Munich, Germany. All such personal data may be shared with recipients as described below.
We communicate personal data within the limits and in accordance with the situations specified in this Privacy Policy, subject to your specific consent where required under Data Protection Laws:
a. Your personal data is accessible within our organization by internal and external staff who need to access it as part of their duties in relation to the processing purposes specified in this document. We ensure that such persons are bound by appropriate security and confidentiality duties.
b. Your personal data may also be accessible to external service providers that we commission to process personal data on our behalf and under our instructions (as subcontractors). These subcontractors include:
i. External service providers to whom we may call upon for the provision of professional, technical and specialized services useful and necessary for the management of the Redley Europe Digital Platforms and the activities carried out on them, such as the sale of products and related activities, the management of the functions offered by the Redley Europe Digital Platforms and the initiatives and services that you can subscribe to and request through the Redley Europe Digital Platforms, as well as for services strictly linked to the pursuit of other processing purposes specified herein;
ii. External service providers that we use to complete purchase and payment processes and transactions through our e-commerce platform;
iii. External service providers who manage and support Redley Europe's Digital Platforms, the relevant e-commerce platform and all pre- and post-sales activities, such as order processing, marketing, financial services, warehouse management and customer relationship management;
A list of these subcontractors, indicating where they are located, is available upon request to our Legal Department. Such subcontractors are bound by contractual obligations to implement appropriate security measures to protect the security and confidentiality of personal data of all users and customers.
Your personal data may also be communicated to other Group companies in the European Economic Area, which process the personal data on behalf of the controller(s) identified above. A list of these Group companies, indicating where they are located, is available on request from our Legal Department.
Your personal data may also be shared with institutions, authorities, public people, banks and financial institutions, professionals, independent consultants, also in an associated form, business partners or other lawful recipients as provided by applicable laws and regulations, for example in the case of legal proceedings, requests by competent courts and authorities or other legal obligation to protect and defend our rights and property and the Redley Europe Digital Platforms.
Finally, we may also communicate your personal data to third parties in the event of mergers, acquisitions and transfers of any of our assets, products, websites or operations.
With the exception of the above, personal data will not be shared with third parties, natural or legal persons, unrelated to or not performing a commercial, professional or technical function for us under contractual obligations of confidentiality of personal data.
Personal data will not be communicated to third parties for their commercial purposes.
The above recipients may be located in countries other than the country in which the personal data was originally collected, but your personal data will in principle only be transferred within the European Economic Area or other countries recognized by the European Commission as having an adequate level of protection for personal data.
If one of the above recipients is established in a country outside the EEA that is not covered by an European Commission adequacy decision and therefore does not offer the same level of protection for your data as in the EEA, we will implement appropriate safeguards, including but not limited to data transfer agreements under the European Commission's Standard Contractual Clauses for the transfer of data to third countries (Article 46, 2., (c) of the GDPR) or binding corporate rules (Article 47 of the GDPR). A copy of these appropriate safeguards can be obtained by contacting our Legal Department at legal@redleyeurope.com.
YOUR RIGHTS
At any time, you have the right to enforce your rights under data protection legislation, including, where applicable, your right of access, rectification, limitation, deletion, objection (including objecting, at any time and free of charge, to the processing of your personal data for direct marketing purposes), right to portability and your right to withdraw consent. You also have the right to register a complaint with the competent supervisory authority.
As a person whose personal data is processed as described in this Privacy Policy, you have rights that we summarize below. You should note that the exercise of these rights is subject to certain requirements and conditions as set out in applicable law.
RIGHT OF ACCESS
Under applicable law, you have the right to obtain confirmation as to whether or not personal data concerning you are being processed and, if so, the right to access your personal data including, among others, the categories of personal data concerned, the purposes of the data processing and the recipients or categories of recipients. However, we do not have to take into account the rights or freedoms of third parties, so this is not an absolute right. If you request more than one copy of the personal data processed, we may charge a fee based on the administrative and operational costs incurred for the case.
RIGHT OF RECTIFICATION
You have the right to ask us to rectify personal data that is inaccurate concerning you. Taking into account the purposes of the processing, you also have the right to request that your incomplete personal data may be completed, including by means of an additional declaration.
RIGHT TO DELETE DATA
You have the right to ask us to delete your personal data in certain situations, as defined by applicable law. If your request falls within such a situation, we will delete your personal data without undue delay. If, for technical and organizational reasons, we are unable to delete your personal data, we will ensure that it is completely and irreversibly anonymized so that we no longer hold your personal data.
RIGHT TO RESTRICTION OF PROCESSING
In certain situations as defined by applicable law, you have the right to request the limitation of the processing of your personal data. In such a case, your personal data may, with the exception of storage, only be processed with your consent, or for the purpose of asserting, exercising or defending a right in legal proceedings, of defending the rights of another natural or legal person, or for reasons of public interest.
RIGHT TO DATA PORTABILITY
In certain situations as defined by applicable law, you have the right to receive the personal data concerning you that you have provided to us, in a structured, commonly used and machine-readable format, and have the right to transmit such data to another controller or request that we transmit it directly to another controller, where technically possible.
RIGHT TO OBJECT
In certain situations as defined in applicable law, you have the right to object at any time, on grounds relating to your particular situation, to our processing of personal data concerning you and we will have to stop all processing of your personal data, unless we provide compelling legitimate grounds for such processing which override your individual interests, rights and freedoms, or for the establishment, exercise or defense of a right in legal procedures. This applies especially in case of processing of your personal data on the basis of our legitimate interests or for statistical purposes.
RIGHT TO OBJECT TO DIRECT MARKETING
Where your personal data are processed for the purposes of direct marketing, you have the right to object at any time to processing for such marketing (including profiling to the extent that it is related to direct marketing).
RIGHT NOT TO BE SUBJECT TO A DECISION BASED EXCLUSIVELY ON AUTOMATED PROCESSING
Subject to certain limitations, you have the right not to be subject to any decision taken exclusively on the basis of automated processing, including profiling, which produces legal effects concerning you or significantly affects you in a similar manner.
RIGHT TO WITHDRAW CONSENT
If you have stated your consent to any personal data processing activities as described in this Policy, you may withdraw that consent at any time with future effect. Withdrawal of consent does not compromise the lawfulness of the processing carried out on the basis of the consent previously given.
If you wish and or need to access such personal data or exercise any of the rights listed above, you must request in writing, providing proof of your identity, to our Legal Department at legal@redleyeurope.com.
Any communication from us in relation to your rights as set out above will be provided free of charge. However, in the case of manifestly unfounded or excessive requests, in particular due to their repetitive character, we may charge a fee taking into account the administrative and operational costs incurred to provide the information or communication or to take the requested action; or refuse to comply with a request.
In the presence of a complaint about the processing of your personal data, you have the right to present a complaint with the competent supervisory authority.
HYPERLINKS TO THIRD PARTIES
The website may include hyperlinks to other websites, as well as objects or elements controlled by third parties. We do not have access to or control these elements and are not responsible for these third party websites.
The Redley Europe Platforms may contain links to other websites, such as objects or elements controlled by third parties.
An example is plug-ins that may link Redley Europe Digital Platforms to social networks such as Instagram, Facebook, Twitter or Google (so-called "social plug-in") and are usually identified by the logo of the social network. If you use a social plug-in on Redley Europe Digital Platforms, your browser may send the social network certain data, such as: the user ID, information about Redley Europe Digital Platform(s), date and time and other browser-related information. This information is handled by social networks owned and managed by third parties in accordance with their privacy policies.
We have no access to or control over the elements, objects, plug-ins, cookies, web beacons and other tracking technologies owned and managed by third parties available on the Redley Europe Digital Platform(s) or third party website that users may access from the Redley Europe Digital Platform(s), or their methods of processing personal data through such elements or websites. We disclaim any liability for such elements and sites. You should check the privacy policy of such third party websites for the conditions applicable to the processing of personal data, as this privacy policy only applies to this site.
REQUIRED AND OPTIONAL INFORMATION
Some of your personal data is necessary to complete your purchase or to provide the service you have requested from us. If you refuse to provide such personal data, it is impossible for us to complete the purchase or provide the requested service.
However, providing personal data for surveying, marketing and profiling purposes is optional. Your refusal will have no impact on the purchase or the provision of the service you have requested.
Except in relation to navigation data (see the section above - "What information do we collect? "), the provision of your personal data may be necessary to enter into or conclude a contract, including the execution of certain services and functions offered by the Digital Platform(s), such as: registration on the site, subscription to the newsletter(s), purchase of products on the site, management of participation in loyalty programs, promotions, brand actions and other initiatives communicated through the Digital Platform(s), response to and management of requests for information, questions, communications or comments. In the situations specified above, refusal to provide your personal data makes it impossible for us to conclude the contract or provide the services, products or information requested, as illustrated above.
Providing the data for the surveying, marketing and profiling purposes described above is optional; refusing to provide personal data for these purposes has no consequences for the conclusion or performance of the contract. Where required under Data Protection Laws, we ask for your consent before processing your personal data for these purposes.
CONTACT
For any question, doubt or request related to the use of your personal data, simply send email to legal@redleyeurope.com.
