DATA PROTECTION POLICY

The Management of Bertinno Pantalón (hereinafter, the data controller), assumes maximum responsibility and commitment to the establishment, implementation and maintenance of this Data Protection Policy, guaranteeing the continuous improvement of the data controller with the aim of achieving the excellence in relation to compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016, relating to the protection of natural persons with regard to the processing of personal data and the free movement of these data and which repeals Directive 95/46/EC (General Data Protection Regulation) (OJEU L 119/1, 04-05-2016), and the Spanish regulations on the protection of personal data ( Organic Law, specific sectoral legislation and its development regulations).

Bertinno Pantalón’s Data Protection Policy rests on the principle of proactive responsibility, according to which the data controller is responsible for compliance with the regulatory and jurisprudential framework that governs said Policy, and is capable of demonstrating it to the control authorities.
competent.
In this sense, the data controller will be governed by the following principles that must serve all of its staff as a guide and frame of reference in the processing of personal data:

• Data protection by design: the data controller will apply, both at the time of determining the means of processing and at the time of the processing itself, appropriate technical and organizational measures, such as pseudonymization, designed to effectively apply the principles of data protection, such as data minimization, and integrating the necessary guarantees in the processing.

• Data protection by default: the controller will apply appropriate technical and organizational measures to ensure that, by default, only personal data that are
necessary for each of the specific purposes of the treatment.

• Data protection in the information life cycle: measures that guarantee the protection of personal data will be applicable during the complete information life cycle.

• Lawfulness, loyalty and transparency: personal data will be processed in a lawful, fair and transparent manner in relation to the interested party.

• Limitation of purpose: personal data will be collected for specific, explicit and legitimate purposes, and will not be further processed in a manner incompatible with said purposes.

• Data minimization: personal data will be adequate, relevant and limited to what is necessary in relation to
with the purposes for which they are processed.

• Accuracy: personal data will be accurate and, if necessary, updated; All reasonable measures will be taken to promptly delete or rectify personal data that is inaccurate with respect to the purposes for which it is processed.

• Limitation of the conservation period: personal data will be maintained in a way that allows the identification of the interested parties for no longer than necessary for the purposes of the processing of personal data.

• Integrity and confidentiality: personal data will be treated in such a way as to ensure adequate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, through the application of technical measures or appropriate organizational structures.

•Information and training: one of the keys to guaranteeing the protection of personal data is training and
information that is provided to the personnel involved in their treatment. During the life cycle of the
information, all personnel with access to the data will be appropriately trained and informed about their
obligations in relation to compliance with data protection regulations.

Bertinno Pantalón’s Data Protection Policy is communicated to all staff of the controller and made available to all interested parties. Consequently, this Data Protection Policy involves all the staff of the data controller, who must know it and assume it, considering it as their own, with each member being responsible for applying it and verifying the data protection regulations applicable to their activity. , as well as identify and provide opportunities for improvement that you consider
timely with the objective of achieving excellence in relation to its compliance.
This Policy will be reviewed by the Management of La Garrocha, as many times as deemed necessary, to adapt, at all times, to the current provisions regarding the protection of personal data. Information in compliance with personal data protection regulations In Europe and Spain there are data protection regulations designed to protect your personal information, which are mandatory for our entity. Therefore, it is very important for us that you fully understand what we are going to do with the personal data we ask for.

This way, we will be transparent and give you control of your data, with simple language and clear options that will allow you to decide what we will do with your personal information. Please, if after reading this information you have any questions, do not hesitate to ask us.
Thank you very much for your help.

• About us?
• Our name: Bertinno Pants (Name
prosecutor: Jose Manuel Bermúdez Ortega)
• Our main activity: Sale of pants
• Our address: Camino del Fontanal S/N, 14800-
Priego de Córdoba (Córdoba)
•Our contact telephone number: 957 701483,
• 957 701688
•Our contact email address:
bertinnopantalon@gmail.com
•Our website: bertinnopantalon.com
• For your confidence and security, we inform you that we are
an entity registered in the following Commercial Registry:

• What are we going to use your data for?
In general, your personal data will be used to be able to relate to you and provide you with our services. Likewise, they can also be used for other activities, such as sending you advertising or promoting our activities.

• Why do we need to use your data?
Your personal data is necessary to be able to interact with you and provide you with our services. In this sense, we will provide you with a series of boxes that will allow you to decide in a clear and simple way about the use of your personal information.

• Who will know the information we ask for?
In general, only duly authorized personnel of our entity may have knowledge of the information we request.

Likewise, those entities that need to have access to it so that we can provide our services may be aware of your personal information. Thus, for example, our bank will know your data if payment for our services is made by card or bank transfer. Likewise, those public or private entities to which we are obliged to provide your personal data in order to comply with any law will have knowledge of your information. Giving you an example, the Tax Law requires the Tax Agency to be provided with certain information on economic operations that exceed a certain amount.
In the event that, apart from the aforementioned assumptions, we need to disclose your personal information to other entities, we will previously request your permission through clear options that will allow you to decide in this regard.

• How and where do we collect your personal data?
We may collect your data when you register in our online store, either to create a new customer account or to access different services such as requesting to send newsletters, social networks, etc. In these cases, the information that we can collect is what is provided to us through the different forms on the website in which name, postal address, email, telephone number is indicated, as well as the IP address, username and password, the latter encrypted. , the browser used, the purchase and browsing history.

Data such as the type of browser you use, its settings, operating system, approximate location and type of device are data that we collect through the use of cookies. Which are small text files that are stored on your computer, mobile phone or tablet and that help us give you better
service: show you personalized content when you visit us, measure and analyze traffic on our websites and target specific advertising. Cookies are completely secure since they can only be modified by your browser. If you want more information about our use of cookies, you can consult our cookie policy.

• What tools do we use to improve our
services?

La Garrocha works with different tools from other companies that it integrates into the web to offer a better service, such as Facebook, Twitter and Instagram to share content on social networks as well as offer services that can capture what is published and from where. Data management tools and advertising campaigns and analysis tools such as Google Analytics or Facebook.

• What rights do I have over my data?
• Right of access
You have the right to be informed if we have registered your data, as well as to provide you with a copy of it. You can request it from your customer profile on the website.
• Right to rectification
You have the right to rectify inaccurate data, to have incomplete personal data completed or to add more information than you already gave us at the time.
• Portability right
You have the right to receive your personal data provided in a structured, commonly used and machine-readable format and to be able to transmit it to another service manager, whenever technically possible.
• Right to be forgotten (deletion)
You have the right to have your personal data deleted from our systems. Therefore, you can request the deletion of your data from your customer profile. These would only be available to Justice or Public Administrations as stipulated in the law and for the time established by legal regulations.
• Right to object
Through the right of opposition, you can oppose the processing of your personal data when, for reasons related to your personal situation, the processing of your data must cease or when the processing is intended for direct marketing.

• And with whom do you share my personal data?
As a general rule, we do not share your personal data with anyone and we guarantee its confidentiality and security. However, sometimes we need to share your data with third parties, either to be able to offer you our services or due to legal requirements. For example, we need courier companies to have your shipping and contact information to be able to send you the order you have placed in our online store.
We may use your data with service providers, platforms or tools that are necessary for its management and thus be able to provide you with a better service, both in terms of information based on promotions and news and in offering you a shopping experience more adapted to your tastes. We have data treatment and confidentiality agreements to guarantee that they will be treated appropriately and in a completely secure manner. We will not share your data with third parties to send commercial communications for services from other companies other than ours.

However, if you want to exercise any of your rights regarding your data, you can contact us at
email bertinnopantalon@gmail.com
• You have control over your personal data
Your privacy is a priority for us, so at any time you can request a “Copy of your personal data” stored on our servers; as well as “Unsubscribe” by deleting all your personal data from our databases. For example, when you unsubscribe, the company data will be kept (ads, contacts received, etc.), but it will be separated from all your personal data.

• How are we going to protect your data?
We will protect your data with effective security measures based on the risks involved in the use of your information. To this end, our entity has approved a Data Protection Policy and annual controls and audits are carried out to verify that your personal data is safe at all times.
• Will we send your data to other countries?
In the world there are countries that are safe for their data and others that are not so safe. So, for example, the European Union is a safe environment for your data. Our policy is not to send your personal information to any country that is not secure from a data protection point of view. In the event that, in order to provide you with the service, it is essential to send your data to a country that is not as safe as Spain, we will always request your permission in advance and apply effective security measures that reduce the risks of sending your information. personnel to another country.
• How long will we keep your data?
We will retain your data for the duration of our relationship and for as long as we are required to do so by law. Once the applicable legal deadlines have expired, we will proceed to dispose of them in a safe and environmentally friendly manner.
• What are your data protection rights?
You can contact us at any time to find out what information we have about you, rectify it if it is incorrect and delete it once our relationship ends, if this is legally possible. You also have the right to request the transfer of your information to another entity. This right is called “portability” and can be useful in certain situations.

To request any of these rights, you must make a written request to our address, along with a photocopy of your ID, to be able to identify you. In the offices of our entity we have specific forms to request these rights and we offer our help in completing them. To learn more about your data protection rights, you can consult the website of the Spanish Data Protection Agency.
Data (www.agpd.es)
• If you believe that your rights have been disregarded, where can you file a complaint?
If you understand that your rights have been neglected by our entity, you can file a claim with the Spanish Data Protection Agency, through any of the following means:

•Electronic headquarters: www.agpd.es
• Postal address: Spanish Data Protection Agency
C/ Jorge Juan, 6 28001-Madrid
• Via telephone: 901 100 099 / 91 266 35 17
Filing a claim with the Spanish Data Protection Agency does not entail any cost and the assistance of a lawyer or attorney is not necessary.
• Will we profile you?
Our policy is not to create profiles about the users of our services.
However, there may be situations where, for service delivery, commercial or other purposes, we need to profile information about you. An example could be the use of your purchase or service history to be able to offer you products or services adapted to your tastes or needs.
In this case, we will implement effective security measures that protect your information at all times from unauthorized persons who seek to use it for their own benefit.

• Will we use your data for other purposes?
Our policy is not to use your data for purposes other than those we have explained to you. Yes, however,
If we need to use your data for different activities, we will always request your permission in advance through clear options that will allow you to decide on the matter.