ENORSIA PRIVACY AND COOKIES POLICY

WHO WE ARE?

We are PFD Enorsia UK Ltd., and we process customer’s personal data as controllers. It means that we are responsible to process and protect the customer’s data.

WHAT FOR WE USE CUSTOMER’S DATA?

We use customer data through different modes, (online or in person), among other purposes, to manage customer’s registration as a customer/user, to manage the product purchase, to respond customer’s queries, and wish accordingly, by sending our customized communications.

WHY WE USE CUSTOMER DATA?

We are legally authorized and responsible to process customer’s data for certain reasons. Mainly, we need to process customer data for the contract that explains, the customer accepts with us when register, make a purchase or enjoy any of our products or services with other functions. We also use customer data for other reasons, like, to respond the queries or to send newsletters that customer has asked for.

TO WHOM WE SHARE WITH CUSTOMER DATA?

ENORSIA may share customer’s data with service providers who provide us with assistance or supports, these companies are the contractual partners or third-party service providers, inside and outside the UK, European Union and around the globe.

CUSTOMER’S/USER’S RIGHTS 

Our customers have all the right to access, rectify, add or delete their personal data. In other cases, they are also entitled to other rights, such as, to object us using the data, or to transfer it, as explained at length below.

ENORSIA encourage customers to read our detailed Privacy and Cookies Policy below mentioned, to understand the way we will use their personal data and the rights over the data.

KEEP IN CONSIDERATION BEFORE TO START

In this Privacy and Cookies Policy, all relevant information applicable to customer’s/users' and clients' personal data.

·         PFD ENORSIA is transparent about the use of customer’s personal data, to help and to understand the implications of the manner, we use the provided data, and the rights our customers are entitled regarding their data:

·         PFD ENORSIA permanently make available data for customers, all the information included in this Privacy and Cookies Policy, that can be checked when consider appropriate, and in addition, customer will also find further information on how we use customer’s data as it is interacted with us.

Following are some terms we regularly use in this Privacy and Cookies Policy:

When we talk about our website, we refer, in general, to any of the means you may have used to interact with us. The main ones are:

Our website,  www.enorsia.com

Our Enorsia App, this is, including both the mobile application you installed on your mobile device and others we may develop at any appropriate time in the future.

The data controller is:

PFD ENORSIA UK LTD. company currently operating the supply/sale of ENORSIA brand products:

§  Postal address: 102 LANGLEY ROAD, WATFORD, ENGLAND, WD17 4PJ

§  E-mail of Data Protection Officer:dataprotection@enorsia.com

In fact, PFD ENORSIA UK LTD. (“We”, “Us” or “the Controller”) are the Controller of the data. It means that we are responsible for processing and protecting customer’s personal data.

Why we need to process customer’s personal data?

The purpose leads to which of the data may be processed from time to time, as explained above, we need to process one or the other data, that in general will, depend on each of the following situations:

·         Identity data (like, name, surname, language and country of origin or from where, customers interact with us, contact data, etc.);

·         Financial transactions information (like, payment or card details, information of the purchase orders, returns & refunds, etc.);

·         Connection, geo-location and/or browsing details (if customer interact by using his/her mobile phone,);

·         Commercial information (like, if have been subscribed for our newsletter),

Please keep in mind that, when customers are asked to fill in personal data to give access to any functional page or service of the website, we will mark certain fields as compulsory, since this is the information that we required enable us to provide the service or give you, easy access to the functionality in question.

Please take into account that, if you intend to hide such data available to us, you may be unable to complete your user registration or may not be able to enjoy the particular services or functions.

Considering customer’s intent how he/she interact with our website, i.e.,

·         Quality of the products,

·         Services, or

·         Other functions that customer wish to enjoy

Following are the purposes to process the personal data:

To manage your registration as user of the website

If customer decides to become a registered user of our website, we need to process the data to identify him/her as a user and grant him/her access to its various functions and products available as a registered user. The customer may cancel his/her registered account by contacting with us through Customer Services.

For the development, performance and execution of Purchase Contract executed with us on the website

The purpose includes processing customer’s data, mainly for:

To contact for updates or promotional notices related to the contracted functions and products, including regular surveys and to be able to establish a degree of customer satisfaction with the provided facilities;

To manage payment of the products purchased, regardless of the payment procedure used. Like:

·         If anyone aims for purchasing any of the products through the website, he/she should opt to activate the functions to save his/her card data for future transactions,

·         We need to process the particular data for activation and to develop the relevant functions.

·         Consent to the activation of that particular functions enables user auto-completed payment details to appear in next purchases so that user doesn’t need to introduce that for future processing,

·         Our system deems this data valid and effective for next purchases. Customer may change or cancel his/her cards at any time through the option on payment information, either of website registered user account, or of the “My Account” functions of the Enorsia website/App.

·         Activation of the necessary arrangements in order to save from potential fraud against the user and us during purchase process. If we observe that the transaction can be fake or fraudulent, the system can stop the processing, may cause the blocking of the transaction.

·         To settle returns after purchase and manage requests of availability for articles, may be depending on the availability of such options occasionally.

·         For invoicing and to make available to customers the bills and invoices of the purchases by users have made through the website.

To meet requests or applications that users make through the Customer Support/help

We only process the specific personal data that is necessary to resolve customer’s requests or applications.

Marketing purpose;

This includes the processing of user’s data, mainly, for:

·         When a customer subscribes for Newsletter, the personal data will be processed to manage his/her subscription, it will include sending customized information about our products or services through various modes (like an e-mail or SMS). We may also make available to users this information through push notifications in case he/she has activated them in mobile device.

·         Likewise, please keep in your considerations that this data processing implies analysis of user/customer profile to establish his/her priorities like, the most suitable products and styles, for sending information. For example, based on customer’s purchases and browsing history (i.e., depending on the articles that you clicked), we may suggest our customers, the products we believe for his/her interest and, if he/she is a registered user, we will provide with the "recover cart" function too.

·         The customer may unsubscribe from the Newsletter at any time without any cost through the "Newsletter" section of the website, by responding through the instructions that we may provide our customer along with each notice. If customers do not need to receive push notifications, he/she can deactivate this option in the mobile App.

·         To perform promotional activities (for example, for the competitors or to send the list of items to the designated e-mail address).

On participating in any promotional activity, customer may authorize us to process his/her personal data that have been shared depending on the promotional activity and disclose that using different media like, social networks or the website itself.

In each promotional activity the customers participate, relevant terms and conditions to be applicable, will be available with detailed information about the processing of user’s personal data.

·         To disseminate in the website or other modes in the social networks, photographs or pictures that users shared publicly, with provision of the consent for the purpose.

Analysis of usability and quality to improve our products

The customers who have to access our website/App, will be informed that we will treat their browsing data for analysis purposes, i.e., to understand the manner in which users interact with our website and will be able to contribute for quality improvement.

We occasionally will perform quality surveys and activities to know the level of our customer’s satisfaction to address the areas of improvement.

HOW ENORSIA, legally permitted to process user’s data?

The legal terms on which we are permitted to process customer’s personal data depend on the purpose for which we need to process, following details lead to the explanation:

To manage Website user registration

We process customer’s data because this is necessary on the terms regulating the use of website/App. In other words, for customer to be able to register as a user on the website/App, we need to process personal data, otherwise would not be able to manage registration.

To Develop and making of “Purchase Contract”

We process customer’s data because the processing is necessary to make Purchase Contract.

Certain data processing related to the purchase process to be activated only because customers request or authorize it, as is the case of the storage of payment (card) data for future purchases or to provide users with the Coming Soon activities, when available. In these cases, our processing of user’s data is supported by their consent.

We are convinced that we have a legitimate interest to carry out the necessary verifications to find and to prevent potential fraud when a customer makes purchases. We understand that the processing of the data is positive for all the parties involved when a purchase is paid off and in particular for customer, since this allows us to establish measures to protect users from fraud attempts by any third party.

Customer Support

We consider that we have a legitimate interest in responding to the requests or consultations raised by customers through the various contact channels. We understand that the data processing is also in benefits to the users to the extent that it enables us to assist them adequately and respond to the consultations.

When customers get in touch with us, specifically, for the management of incidents related to the order or the product acquired through our website/App, the processing of the data is necessary to prepare a purchase contract.

When customer’s consultation is related to the exercise of their rights on which we inform them as mentioned below, or to claims on our products, we are legally permitted to process the data for compliance with our legal obligations.

Marketing

We are legally permitted to process customer’s data for marketing purposes due to the consent given to us, for example;

·         when user accepts receiving customized information through multiple channels,

·         when authorizing the sending of push notifications in user’s mobile device or

·         when accepting the legal terms and conditions to participate in a promotional activity or to publish user’s pictures on the website or on our social networks' channels.

In order to show users customized information, we consider that we have a legitimate interest to conduct a profiling with the information that we have about our valued customer (such as his/her browsing, preferences or purchase history) and the personal data that have been provided to us, such as the age range or language, since we understand

that the data processing is also beneficial to users because it allows them to improve their experience and access to the information in accordance with one’s preferences.

Analysis of usability and quality

We are convinced that having a legitimate interest in analyzing the website/App usability and the user's satisfaction level, we understand that the processing of the data is also beneficial for users because of the purpose to improve experience and provide higher quality services.

HOW LONG WILL PFD ENORSIA keep user’s data?

The time, we will keep customer’s data depends on the purposes for which we process it, see below for details:

To manage Website/App user registration

We will process user’s data for the time, he/she remain a registered user (until user decides to unsubscribe)

Development and execution of the Purchase Contract

User’s data is processed for the time, necessary to manage the purchase of the products that he/she buys, including returns, complaints or claims related to a particular purchase of any product.

PFD ENORSIA will process the data until the time as user decides, in case of payment (card) data that is requested us to save for future purchases.

Customer Support

ENORSIA will process customer data for the time, necessary to meet user’s request or application.

Marketing

ENORSIA will process user data until he/she unsubscribe or cancel his/her subscription for the newsletter.

If user participate in promotional activities, we will keep the data during a four months period from the end of the last activity.

Analysis of usability and quality

PFD ENORSIA will process user data occasionally for the time during which we proceed to carry out a specific quality action or survey or until we are convinced it is anonymous.

ENORSIA in fact will process user data for the time strictly necessary to achieve the purpose in question, we will subsequently keep all duly stored and protected for the time during which liability may arise for the processing, in compliance with legislation in force from time to time. Once each of the potential activities (time-barred) we will proceed to delete the personal data.

DO PFD ENORSIA share user data with third parties?

To achieve the purposes mentioned in the Privacy and Cookies Policy, PFD ENORSIA must give access to user’s personal data to third parties that provide us with support in the services that we offer to our valued customers, i.e.:

·         Financial institutions,

·         Anti-fraud detection and prevention entities,

·         Technological service providers,

·         Logistic, transport and delivery partners and service providers,

·         Customer support service providers,

·         Advertising and marketing partners,

For service efficiency purposes, some of the partners are located in territories outside the UK that do not offer a level of data protection comparable to that as of UK. In such cases, we will update users that the data will be transferred with adequate safeguards and always keeping it safe:

Some of the service providers are certified with Privacy Shield, which certification you may consult through the following link:

https://www.privacyshield.gov/welcome

With other service providers, we have agreed Standard Contractual Clauses approved by the UK govt., the content of which you may consult through the following;

The Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2015

In case, we sell or transfer all or a portion of our business or assets to other Company, as a consequence of internal corporate re-organization, we may disclose user’s personal data to the prospective buyer of such business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with our Privacy Policy. In this case, we consider that we have legitimate interest consisting on the re-organization of our internal corporate structure.

USER’S RIGHTS while making personal data available to, PFD ENORSIA

We take responsibility to keep user’s personal data confidential and to ensure that he/she may exercise his/her rights. Keeping in mind, that to exercise rights is free of any charges by writing us an e-mail to just telling us of the reason for the request and what rights would be exercised. If we consider it necessary to identify a user, we may request him/her to provide a copy of documentary evidence as proof.

In particular, the purpose or legal basis PFD ENORSIA use to process customer data, he/she may enjoy the rights mentioned below:

·         To request access to his/her personal data that we have. We remind user that where he/she is a registered user, may also consult the information in the relevant section of his/her online account.

·     To request that we rectify the personal data that we have. Please keep it, in mind that being a registered user on the Website/App, customer may also access the relevant personal data section of his/her online account to change or update it.

o   In any case, please be noted that, on actively making your personal data available to us through any procedure, you guarantee us that its true and accurate and you undertake to notify us, any change or modification in your data.

o   You will be liable for any loss or damage caused to the Website/App or to the person responsible for the Website/App or to any third party by reporting erroneous, inaccurate or incomplete information in the registration forms.

o   Please remember that, as a general rule, customer is responsible to provide us only with his/her own data, not of third parties, other than to the extent permitted in the Privacy and Cookies Policy.

·         To request that we erase customer’s personal data to the extent that it’s no longer necessary for the purpose for which we keep it, as we have explained above, or when we are no longer legally permitted to process it.

·         To request that we cancel or limit the processing of customer personal data, which entails that in certain cases he/she may request us for temporary suspension the processing of data or that we keep them longer than necessary requirements.

If you have given ENORSIA consent to process the data for any purpose, you also keep the right to withdraw it at any time. Some of the circumstances in which user may withdraw his/her consent is detailed in section below where it is explained that for which purpose, we process the particular data.

When we are legally permitted to process user data on his/her consent or on the basis of a contract, as explained in earlier section, user may also have the right to request the portability of his/her personal data. It means that user will have the right to receive the personal data that was made available to us in a structured, commonly used and machine-legible format, to enable to transmit that to any other entity directly without impediments on our part.

In addition, where the processing of user data is based on his/her legitimate interest, he/she will have the right to object to the processing of the data.

WHAT HAPPENS WHEN you provide PFD ENORSIA with third parties data?

We offer various functions that are required to process the personal data of a third party that user must provide, (Card). If user provide us with personal data of third parties, he/she confirm that he/she informed them of the purposes and of the manner in which we need to process the data.

CHANGES to the privacy and cookies policy

PFD ENORSIA may amend the information in the Privacy and Cookies Policy when will consider appropriate. We will notify our users by following various procedures through the Website/App (like, a banner, a pop-up or a push notification), or by sending a notice to his/her e-mail address when the change is relevant to his/her privacy, for review to the changes, assess them and, as find suitable, may object or unsubscribe from any service or function. In any case, we suggest user to review this Privacy and Cookies Policy from time to time in case minor amendments made or any interactive improvement, taking the opportunity that user will always find it as a permanent point of information on our Website and the Mobile App.

INFORMATION on Cookies

PFD ENORSIA use Cookies and similar devices to facilitate users browsing in the Website/App, understand how user interact with us and, in certain cases, to be able to show advertisements & promotions in accordance with his/her browsing habits. Please go through our Cookies Information to understand at length, the cookies and similar devices that we may use, along with the purpose and other relevant information users like.

INFORMATION about Cookies

What is a Cookie?

A Cookie is a small text file that a website/App stores on user’s PC, cell phone or any other device, with information about user’s navigation on the website. Cookies are necessary to facilitate browsing and to make it more user-friendly, and they do not damage any of user’s device.

While the Policy uses the general term “Cookies”, as these are the main tool for saving and storing information used by this website/App, the browser's "Local Storage" space is also used for the same purposes as the Cookies. All such information included in this section is also applicable to the "Local Storage" as well.

What Cookies are used for on the website?

Cookies are an essential part of the website to work. The main purpose of our Cookies is to improve customer’s browsing experience. Like, these are used to remember your preferences (language, country, etc.) while browsing and on future visits. The information collected by the Cookies also enables us to improve the site by estimating;

·         Numbers and patterns of use,

·         Suitability of Website/App to the individual interests of the users,

·         Quicker searches,

On occasion, if we have obtained user’s consent in advance, we may use Cookies, tags or other similar devices to obtain information that enables us to show users, either from our own website/App or from third-party websites or any other means, advertising or promotional based on the analysis of user’s browsing habits.

The Cookies NOT used on the website?

We do not store sensitive personal information, such as customer’s address, password, credit or debit card data, etc. used in the Cookies.

Use of information stored in Cookies?

The information stored in the Cookies from our website is used exclusively by us, except for those identified as "third-party cookies", which are used and managed externally to provide services requested by us for the improvement in quality of services and the experience of the user when browsing the website/App. The main services for which these "third-party cookies" are used are to obtain, access, statistics and to guarantee the payment transactions that are carried out.

How can a User avoid Cookies on this website/App?

If the user prefer to avoid the use of Cookies on this page, taking into account the above-described limitations, he/she must first disable the use of Cookies in the browser and then delete the Cookies saved in his/her browser associated with the website/App. Users may use this option for preventing the use of Cookies at any time.

How User can disable to prevent use of Cookies?

He/she may restrict, block or delete the Cookies from the website at any time by changing the configuration of browser following the steps indicated below.

·         Due to the difference is settings in each browser, Cookies are normally configured in the "Preferences" or "Tools" menu.

·         For further details on configuring Cookies in user’s browser, see the "Help" menu in the browser itself.