I. PRIVACY AND DATA PROTECTION POLICY

Respecting the provisions of current legislation, Blandy Shoes (hereinafter, also Website) undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected.

Laws included in this privacy policy

This privacy policy is adapted to the current Spanish and European regulations regarding protection of personal data on the internet. Specifically, it respects the following rules:

Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and the free circulation of these data (RGPD).

Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).

Royal Decree 1720/2007, of December 21, which approves the Development Regulation of Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD). Law 34/2002, of July 11, on Services of the Information Society and Electronic Commerce (LSSI-CE).

Identity of the person responsible for the processing of personal data

The person responsible for the processing of personal data collected in Blandy Shoes is: Tamara Peixoto Cardoso, with NIF: 53364110Q (hereinafter, Responsible for the treatment).

Contact details are the following:

Address: Rua Concorida 9 2º Oficina 3

Contact phone: 613001117

Contact email: clientes@blandy-shoes.com

Record of Personal Data

In compliance with the provisions of the RGPD and the LOPD-GDD, we inform the User that personal data collected by Blandy Shoes, through the forms provided on its pages will be incorporated and will be treated in their file in order to facilitate, expedite and fulfil the commitments established between Blandy Shoes and the User or the maintenance of the relationship established in the forms that are filled out, or to attend to a request or inquiry.

Also, in accordance

with the provisions of the RGPD and the LOPD-GDD, unless the exception provided for in article 30.5 of the RGPD, a record of treatment activities is kept that specifies, according to its purposes, the treatment activities carried out and the other circumstances established in the RGPD.

Principles applicable to the processing of personal data

The processing of the User's personal data will be subject to the following principles set out in the article 5 of the RGPD and article 4 and following of Organic Law 3/2018, of December 5, of Protection of Personal Data and guarantee of digital rights: Principle of legality, loyalty and transparency: the consent of the

User prior completely transparent information of the purposes for which the data are collected. personal information.

Principle of purpose limitation: personal data will be collected for specific purposes, explicit and legitimate.

Principle of data minimsation: the personal data collected will only be the strictly necessary in relation to the purposes for which they are processed.

Principle of accuracy: personal data must be accurate and always up to date.

Principle of limitation of the conservation period: personal data will only be kept for a way that allows the identification of the User during the time necessary for the purposes of its treatment.

Principle of integrity and confidentiality: personal data will be treated in a way that is guarantee your security and confidentiality.

Principle of proactive responsibility: the Data Controller will be responsible for ensuring that the above principles are fulfilled.

Categories of personal data

The categories of data that are treated in Blandy Shoes are only identifying data. In this instance, special categories of personal data are processed in the sense of article 9 of the RGPD.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent.

Blandy Shoes undertakes to obtain the express and verifiable consent of the User for the treatment of their personal data for one or more specific purposes.

The User will have the right to withdraw their consent at any time. It will be easier to remove the consent than to give it. As a general rule, the withdrawal of consent will not be a condition of the use of the Website.

On occasions when the User must or may provide their data through forms to make inquiries, request information or for reasons related to the content of the Website, the User will be informed in the event that the completion of any of them is mandatory because they are essential for the correct development of the operation carried out.

Purposes of the treatment to which the personal data are destined

Personal data is collected and managed by Blandy Shoes in order to facilitate, expedite and comply with the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter fills out or to attend a request or consultation.

Likewise, the data may be used for the commercial purpose of personalisation, operational and statistics, and activities pertaining to the corporate purpose of Blandy Shoes, as well as for the extraction, data storage and marketing analysis to develop the Content offered to the User, as well as how to improve the quality, operation and navigation of the Website.

At the time the personal data is obtained, the User will be informed about the purpose or purposes specific of the treatment to which the personal data will be used; that is, the use or uses that will be given to the information collected.

Retention periods of personal data

Personal data will only be retained for the minimum time necessary for the purposes of the User’s service and, in any case, only during the following period: 18 months, or until the User requests its deletion.

At the time the personal data is obtained, the User will be informed about the period during which personal data will be kept or, when that is not possible, the criteria used to determine this term.

Recipients of personal data

The User's personal data will not be shared with third parties.

In any case, at the time the personal data is obtained, the User will be informed about of the recipients or categories of recipients of personal data.

Personal data of minors

Respecting the provisions of articles 8 of the RGPD and 7 of Organic Law 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights, only those over 14 years old may grant their consent for the processing of their personal data in a lawful manner by Blandy Shoes. In the case of a minor under 14 years of age, the consent of the parents or guardians will be necessary, and this will only be considered lawful to the extent that they have authorised it.

Secrecy and security of personal data

Blandy Shoes undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected, in order to guarantee the security of the data of a personal nature and the destruction, loss or accidental or illegal alteration of personal data is avoided transmitted, stored or otherwise processed, or the unauthorized communication or access to said data.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is they transmit in a secure and confidential way, as the data is transmitted between the server and the User, and in feedback, fully encrypted or encrypted.

Blandy Shoes cannot guarantee the unenforceability of the internet or the absence of hackers or others who fraudulently access personal data.

However, Blandy Shoes undertakes to notify the User without undue delay when a violation of the security of personal data that is likely to pose a high risk to the rights and freedoms of natural persons. Following the provisions of article 4 of the RGPD, it is understood byviolation of the security of personal data any violation of security that causes the

destruction, loss or accidental or illegal alteration of personal data transmitted, kept or treated in another way, or unauthorised communication or access to said data.

Personal data will be treated as confidential by the Data Controller, who will undertakes to report and guarantee through a legal or contractual obligation that said confidentiality is respected by its employees, associates, and anyone to whom it makes the information.

Pights derived from the processing of personal data

The User has an agreement with Blandy Shoes and may, therefore, exercise their rights against the Responsible party in the case of the following rights recognised in the RGPD and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

Right of access: It is the right of the User to obtain confirmation of whether Blandy Shoes is treating or not their personal data and, if so, obtain information about their data specific personal data and the treatment that Blandy Shoes has carried out or carries out, as well as, among others, the information available on the origin of said data and the recipients of the communications made or planned of the same.

Right of rectification: It is the right of the User to have their personal data modified that prove to be inaccurate or, taking into account the purposes of the treatment, incomplete.

Right of deletion (\ "the right to be forgotten \"): It is the right of the User, provided that the legislation does not establish otherwise, to obtain the deletion of their personal data when they are not necessary for the purposes for which they were collected or processed; the User has Withdrawn their consent to the treatment and this does not have another legal basis; the User objects to the treatment and there is no other legitimate reason to continue with it; Personal information has been unlawfully treated; personal data must be deleted in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer from Information services to a child under 14 years of age. In addition to deleting the data, the party Responsible for the treatment, taking into account the available technology and the cost of the User’s application, must take reasonable measures to inform those responsible who are treating the personal data of the interested party's request to delete any link to these data personal.

Right to limitation of treatment: It is the right of the User to limit the treatment of their personal information. The User has the right to obtain the limitation of the treatment when contesting the accuracy of your personal data; the treatment is unlawful; the Data Controller no longer need the personal data, but the User needs it to make claims; and when the User has opposed the treatment.

Right to data portability: In the event that the treatment is carried out by means automated, the User will have the right to receive from the Data Controller their data personal data in a structured, commonly used and machine-readable format, and transmit them to another responsible for the treatment. Whenever technically possible, the Data Controller will directly transmit the data to that other person in charge.

Right of opposition: It is the right of the User not to carry out the processing of their data of a personal nature or the treatment thereof by Blandy Shoes is stopped. Right not to be the subject of a decision based solely on the treatment automated, including profiling: It is the User's right not to be subject to a individualized decision based solely on the automated processing of your data personal, including profiling, existing unless current legislation establishes otherwise.

Thus, the User may exercise their rights by written communication addressed to the party Responsible for the treatment with the reference \ "RGPD-www.blandy-shoes.com \", specifying:

Name, surname of the User and copy of the DNI.

In cases where a representation is submitted, Identification of the person representing the User by the same means is also necessary, as well as the document certifying the representation. The photocopy of the DNI may be replaced, by any other legally valid means that proves identity.

Request with the specific reasons for the request or information to which you want to access.

Address for notification purposes.

Date and signature of the applicant.

Any document that proves the request you make.

This request and any other attached document may be sent to the following address and / or email:

Postal address: Rua Concorida 9 2º Oficina 3

Email: clientes@blandy-shoes.com

Links to third party websites

The Website may include hyperlinks or links that allow access to third party web pages other than Blandy Shoes, and therefore not operated by Blandy Shoes. The owners of said web sites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Claims before the supervisory authority

In the event that the User considers that there is a problem or violation of current regulations in the way in which your personal data is being processed, you will have the right to effective judicial protection and file a claim with a supervisory authority, in particular, in the State where you have your habitual residence, place of work or place of the alleged offense. In the case of Spain, the authority control is the Spanish Agency for Data Protection (http://www.agpd.es).

II. ACCEPTANCE AND CHANGES IN THIS POLICY PRIVACY

It is necessary that the User has read and agrees with the conditions on data protection of a personal nature contained in this Privacy Policy, as well as that you accept the treatment of their personal data so that the person in charge of the treatment can proceed to the same in the form, during the terms and for the purposes indicated. The use of the Website will imply the acceptance of the P

Blandy Shoes reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Agency for the Protection of Data. Changes or updates to this Privacy Policy will not be explicitly notified to the User. T

The User is recommended to consult this page periodically to be aware of the latest changes or updates.

This Privacy Policy was updated to adapt to Regulation (EU) 2016/679 of the Parliament Council and Council, of April 27, 2016, regarding the protection of natural persons in what Regarding the processing of personal data and the free circulation of these data (RGPD) and the LawOrganic 3/2018, of December 5, Protection of Personal Data and guarantee of rights digital.

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