Privacy Policy

PERSONAL DATA INFORMATION
Last revised: May 25, 2018.

WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR DATA?
The person responsible for processing the data is TRANSCORTANA, SL (“CORTANA”), with NIF number B-62683834 CORTANA's contact information is as follows:
– Postal address: Customer Service, Can Pujolet, 3, 08032 (Barcelona).
– Telephone: 93 310 08 03
– Email: administracion@cortana.llos.dev

WHAT TYPE OF PERSONAL INFORMATION DOES CORTANA COLLECT?
CORTANA may collect the following personal information from users of the CORTANA website and/or the CORTANA mobile application (“WEB/APP”) through the corresponding forms: name, email address, postal address, phone number telephone, date of birth, sex and credit card (PAN+CVV2) in compliance with PCI DSS standards or account number (provided by the client in case of return) when the user visits the WEB/APP, registers, makes an online order, contact CORTANA or participate in CORTANA promotions or surveys.
In addition, CORTANA collects all information related to your navigation on the WEB/APP and your interaction with the brand.
All the personal data that CORTANA collects come from the interested party, with the exception of contact information that may be provided to us by friends or family:
– To send a gift voucher or other gift.
– To share favorites saved on the WEB/APP.

FOR WHAT PURPOSE DO WE PROCESS PERSONAL DATA?
The personal data of the interested party will be processed for the following purposes as applicable:
– Manage and develop the registration on the WEB/APP. Registration will involve the creation of profiles of the user's navigation on the WEB/APP. Said profiling consists of the use of the customer's personal data and browsing information such as the products viewed or added to the basket, the sections of the WEB/APP visited, the location to evaluate their preferences and/or personal interests with the objective of offering you the contents of the WEB/APP, offers, services and products appropriate to your profile.
– Manage and develop the online purchase. We use the customer's personal information to process and deliver your order, inform you by email and/or SMS of the status of your order.
– Manage and send information about exclusive promotions, latest news and personalized information adapted to the profile, interests and needs of the interested party as a customer via email, SMS or postal mail. The sending of this information will involve the creation of user profiles, which consists of using personal data, the history of their purchases if applicable, as well as navigation information on the WEB/APP to evaluate certain aspects related to their personal preferences with the objective of offering you commercial communications appropriate to your profile.
– Content, products or services will be personalized to the client in communications based on their interests. To manage communications, see the 'Subscriptions' section in My Account.
– Manage the alert service for when a certain item of clothing is available on the WEB/APP.
– Management and issuance of sales documents: digital ticket, sales invoice or Tax Free.
– Manage the WIFI service in CORTANA stores.

HOW LONG WILL WE KEEP THE DATA?
CORTANA will store personal data only for the period of time reasonably necessary taking into account the needs to respond to questions that arise or resolve problems, make improvements, activate its services and comply with the requirements of applicable legislation. This means that it can retain personal data for a reasonable period of time even after the data subject has stopped using CORTANA services or has stopped using the WEB/APP. After this period, personal data will be blocked from all CORTANA systems.

WHAT LEGITIMATES US TO PROCESS THE DATA?
CORTANA has the following legitimate bases to process personal data:
Contract execution
The legal basis for the processing of the personal data of the interested party that is collected is the execution of the purchase and sale contract. In this sense, the interested party is obliged to provide the data that is necessary for its execution. If you do not provide us with this information, the sale will not be possible.
Legal obligations
The management and issuance of the sales invoice is based on CORTANA's legal obligation in its relationship with customers.
Consent
In relation to the following purposes, the legal basis for the processing of the personal data of the interested party will be the consent of the interested party, if it has been given:
– Registration management on the WEB/APP.
– Management of sending information about exclusive promotions, latest news and personalized information adapted to the profile of the interested party.
– Management of the garment availability alert service on the WEB/APP.
– Management and issuance of the following sales accreditation documents: digital ticket and Tax Free.
– Management of the WIFI service in CORTANA stores.
The withdrawal of consent to these treatments by the interested party will not condition the execution of the sales contract entered into between the interested party and CORTANA.
Legitimate interest
In relation to the following purposes, the legal basis for the processing of the interested party's personal data will be the legitimate interest of CORTANA:
– The creation of profiles by browsing the WEB/APP by a user registered there, as well as by all those users who have provided us with their data for any other purpose.
– The creation of profiles to send information about exclusive promotions, latest news and personalized information adapted to the profile of the interested party.
– Sending satisfaction surveys on the products purchased or services used by CORTANA customers to request their opinion and be able to improve them.
Our legitimate interest is to be able to ensure that our WEB/APP remains secure, as well as to help CORTANA understand the needs, expectations and level of satisfaction of users and, therefore, improve services, products and brands. All these actions are carried out in order to improve the level of customer satisfaction and ensure a unique browsing and purchasing experience.

TO WHICH RECIPIENTS CAN WE COMMUNICATE THE DATA?
The personal data of the interested party may be transferred/communicated to the following recipients:
– CORTANA Group companies.
– Administrations and Public Organizations when required by tax, labor, Social Security or any other applicable regulations.
– Companies in charge of data processing, such as franchisees and suppliers that provide services to CORTANA (messaging companies, communication sending companies, agencies, profiling companies, etc.).
International data transfers may also occur at the site of the previous transfers/communications for which CORTANA will use the Standard Contractual Clauses adapted by the European Commission and the EU-US Privacy Shield. As a guarantee for those transfers made to countries that do not have an adequacy decision from the European Commission. In any case, third parties with whom certain personal data are shared will have previously accredited the adoption of appropriate technical and organizational measures for their correct protection.
CORTANA does not under any circumstances sell customer data to third parties.

HOW DOES CORTANA PROTECT PERSONAL DATA?
The WEB/APP uses information security techniques such as firewalls, access control procedures and cryptographic mechanisms, all with the aim of preventing unauthorized access to data and guaranteeing its confidentiality. To achieve these purposes, the user agrees that CORTANA obtains data for the purposes of the corresponding authentication of access controls.
Additionally, any transaction made through the WEB/APP is carried out through secure payment systems. Confidential payment data is transmitted directly and in encrypted form (SSL) to the corresponding entity.
CORTANA states that it has adopted all the necessary technical and organizational measures to guarantee the security and integrity of the personal data it processes, as well as to prevent its loss, alteration and/or access by unauthorized third parties.

WHAT ARE YOUR RIGHTS REGARDING PERSONAL DATA?
You have the following rights that can be exercised through the email address administracion@cortana.llos.dev:

Right of access : You have the right to obtain confirmation as to whether CORTANA is processing personal data that concerns you or not, as well as to access the personal data that CORTANA has about you.

Right to rectification: You have the right to request that CORTANA rectify personal data when it is inaccurate or to complete it when it is incomplete. If you are registered on our WEB/APP, it may be easier for you to correct them directly by modifying your profile.

Right to deletion/right to be forgotten: You can request that personal data be deleted when, among other reasons, the data is no longer necessary for the purposes for which it was collected.

Right of limitation: You have the right to request the limitation of the processing of your data, in which case we will only keep it for the exercise or defense of claims.

Right to portability: You have the right to receive personal data in a structured, commonly used and machine-readable format, and to transmit it to another controller when the processing is based on consent or a contract, and is carried out by automated means.

Right to object: You can object to personal data being processed based on the public or legitimate interest pursued by CORTANA, including profiling. In such case, CORTANA will stop processing the data, except for compelling legitimate reasons or the exercise or defense of possible claims.

Automated individual decisions: You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects on you or similarly significantly affects you. However, it will not be possible to exercise such right if the decision is necessary for the conclusion or execution of a contract between you and CORTANA; is authorized by the law applicable to CORTANA provided that it establishes appropriate measures to safeguard your rights, freedoms and legitimate interests; or is based on your explicit consent.

Right to file a claim: You have the right to file a claim with the Spanish Data Protection Agency.

To process the request, we may ask you to prove your identity.

USE OF OUR WEBSITE
The user undertakes to make appropriate use of the contents of the Website, being obliged to (i) provide truthful and accurate information about the data requested in the registration or order form, and keep them updated, whenever they do so. use of the Web; (ii) not engage in illicit, illegal or activities contrary to good faith and public order; (iii) not disseminate content or propaganda of a racist, xenophobic, discriminatory nature based on race, sex, ideology, religion or that in any way violates morality, public order, fundamental rights, public freedoms, honor, the privacy or image of third parties and in general the current regulations; (iv) not cause damage to the physical and logical systems of the Website, Cortana providers or third parties, nor introduce or spread computer viruses or any other physical or logical systems on the network that are likely to cause the aforementioned damage. mentioned; (v) not use the contents of the Website and its information to send advertising, or send messages for any other commercial purpose, or to collect or store personal data of third parties; (vi) not try to access and, where appropriate, use the email accounts of other users and modify or manipulate their messages.
Cortana reserves the right to make, without prior notice, any modifications it deems appropriate on its Website, and may change, delete or add both the content and services provided through it and the way in which they are presented or located on the Website. your portal.
INTELLECTUAL AND INDUSTRIAL PROPERTY
All intellectual and industrial property rights of the Website and its contents, including but not limited to images, sound, audio, video, designs, texts, graphics, logos, icons, color combinations, structure, buttons, as well as the software , trade names, brands, works, illustrations, photographs or industrial drawings and any other signs susceptible to industrial and commercial use are the property and ownership of Cortana or third party owners thereof who have duly authorized their inclusion on the Website.
The reproduction, distribution and public communication, including the method of making it available, of all or part of the contents of the Website, for commercial purposes, on any medium and by any technical means, are expressly prohibited without the authorization of Cortana.
The user agrees to respect the intellectual and industrial property rights owned by Cortana. The user may use the Website and its contents for personal and private use. Any other use is prohibited and will require the user to obtain the prior express written authorization of Cortana. The user must refrain from deleting, altering, evading or manipulating any protection device or security system that was installed on the Web.
RESPONSIBILITY DERIVED FROM THE USE OF THE WEBSITE
Cortana is not responsible, in any case, for damages of any nature that may be caused, by way of example: errors or omissions in the content, lack of availability of the portal or the transmission of viruses or malicious or harmful programs in the contents, despite having adopted all the necessary technological measures to avoid it.
From the client's website you may be redirected to content on third-party websites. Since the provider cannot always control the content introduced by third parties on its websites, it does not assume any type of responsibility with respect to said content. In any case, the provider states that it will proceed to the immediate withdrawal of any content that could contravene national or international legislation, morality or public order, proceeding to the immediate withdrawal of the redirection to said website, informing the competent authorities the content in question.
Cortana is not responsible for the information and content stored, by way of example but not limited to, in forums, chats, blog generators, comments, social networks or any other means that allows third parties to publish content independently on the Web. However, Cortana makes itself available to all users, authorities and security forces, and actively collaborates in the removal or, where appropriate, blocking of all content that could affect or contravene national or international legislation, third-party rights. or morality and public order. If the user considers that there is any content on the Website that could be susceptible to this classification, please notify the website administrator immediately.
The Website has been reviewed and tested so that it works correctly. In principle, correct operation can be guaranteed 24 hours a day, 7 days a week, all year round. However, Cortana does not rule out the possibility that there may be certain programming errors, or that force majeure, natural disasters, strikes, or similar circumstances may occur that make access to the Website impossible.
The introduction of hyperlinks for commercial purposes on web pages other than Cortana that allow access to the Web is prohibited, without the prior consent of Cortana. Cortana is not responsible for the use or content of third-party web pages that may link to Cortana.es.

USE OF COOKIES

WHAT ARE COOKIES AND HOW DOES CORTANA USE THEM?
Cortana, on its own behalf or on behalf of a third party contracted to provide measurement services, may use cookies when a user browses the Web. Cookies are files sent to the browser through a web server with the purpose of recording the user's activities during their browsing time.
Through the use of cookies, it is possible for the server where the Website is located to recognize the web browser used by the user in order to make navigation easier, allowing, for example, access to users who have registered. previously, access the areas, services, promotions or contests reserved exclusively for them without having to register for each visit. They are also used to measure the audience and traffic parameters, control the progress and number of entries.
Guarantees on the use of cookies
The cookies used by the website are only associated with anonymous users and their computer and do not themselves provide personal data about users.
Some cookies are used by third parties (e.g. Google) to provide Cortana with data on the effectiveness of their promotions. In no case do cookies collect personal information that can identify a specific user.
The cookies used on the Website are, in any case, temporary in nature, with the sole purpose of making their subsequent transmission more efficient. None of the cookies used on the Website will have a validity period of more than two years.
Users have the possibility of configuring their browser to be notified of the receipt of cookies and to prevent their installation on their computer.
By deleting Cortana cookies or disabling them, the user risks not being able to access certain functionalities of the Website.
To use the Website, it is not necessary for users to allow the installation of cookies, without prejudice to the fact that it is necessary for them to log in as such in each of the services whose provision requires prior registration or login.

WHAT TYPES OF COOKIES DOES CORTANA USE?
Cortana uses four types of cookies:
Technical cookies: They allow the user to browse the Web and use functionalities such as the shopping cart.

Analysis cookies: Cortana uses Google Analytics cookies to quantify the number of users who visit the Website. These cookies allow us to measure and analyze the way in which users navigate the Web. This information allows Cortana to continually improve its services and the shopping experience of Web users. For more information, you can consult the Google Analytics privacy page: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

Personalization cookies: When the user is browsing or purchasing through the Web, the website will remember their preferences (for example, their location or preferred language). Thanks to these cookies it is possible to offer a simpler, simpler and more personalized browsing experience for users.

Advertising cookies: These cookies are used to show relevant advertisements to users. In addition, they limit the number of times each user views an ad and helps Cortana measure the effectiveness of its advertising campaigns. By browsing the Website, the user accepts that Cortana downloads these types of cookies to their device and makes queries when the user visits the Cortana Website in the future.

WHAT HAPPENS TO LINKS TO OTHER WEB PAGES?
The Website may contain links to other websites, with privacy policies different from Cortana's. In this sense, Cortana is not responsible for the content or practices of linked sites. Cortana recommends Web users review the privacy policy of any website they may access through Cortana.es.

HOW DOES CORTANA COLLECT AND USE IP ADDRESSES?
The Web servers will be able to automatically detect the IP address and domain name used by users.
An IP address is a number automatically assigned to a computer when it connects to the Internet. This information allows the subsequent processing of the data in order to obtain only statistical measurements that allow knowing the number of visits made to the Website, the order of visits, the access point, etc.