- WHO WE ARE. We are Industria de Diseño Textil, S.A. (Inditex, S.A.) and we process your personal data as controller. This means that we are responsible for how we process and protect your data.
- WHAT WE USE YOUR DATA FOR. We will use your data (collected online or through other means), among other purposes to respond to your queries, solve your doubts and attend your suggestions.
- WHY WE USE YOUR DATA. We are entitled to use them because we have a legitimate interest to respond to your queries, solve your doubts and attend your suggestions.
- WHO WE SHARE YOUR DATA WITH. We share your data with service providers who provide us with assistance or support, these being companies in the Inditex Group or third party providers, both inside and outside the European Union.
- YOUR RIGHTS. You have the right to access, rectify or delete your personal data. In certain cases, you are also entitled to other rights, such as, for example, to object to us using your data, or to the portability of your data, as explained in depth below.
BEFORE YOU START …
- We are transparent about what we do with your personal data, to help you to understand the implications of the way in which we use your data, and the rights you are entitled to in relation to your data:
- You will also find further information on how we use your data as you interact with us.
When we speak about our Platform, we refer, in general, to any of the channels or means, digital or in person, you may have used to interact with us. The main ones are:
- Our Website, www.wateractionplan.com;
- by phone, post mail or electronic mail.
- WHO IS THE CONTROLLER OF YOUR DATA?
Your data controllers are:
- INDUSTRIA DE DISEÑO TEXTIL, S.A. (Inditex, S.A), Spanish company that acts as parent company of the Inditex Group (hereinafter, "INDITEX"):
- Postal address: Avda. de la Diputación, Edificio Inditex, 15143, Arteixo (A Coruña), Spain.
- E-mail address of the Data Protection Officer: firstname.lastname@example.org
In other words, INDITEX (“We” or “Us”), is the Controller of the data. This means that we are responsible for processing and protecting your personal data.
- WHY WE PROCESS YOUR PERSONAL DATA
Depending on the purpose for which we process your data from time to time, as explained above, we need to process one or other data, which will in general be, depending on each case, as follows:
- your identity data (for example, your name, surname, language and market from which you interact with us and contact data);
- transactions information (for example, any information that you provide us on your purchases tickets, orders, returns, etc.);
- connection and browsing data;
Remember that, when we ask you to fill in your personal data to give you access to any functionality or service of the Platform, we will mark certain fields as compulsory, since this is information that we need to be able to provide the service or give you access to the functionality in question. Please take into account that, if you decide not to make such data available to us, you may be unable to enjoy those services or functionalities.
We will process your personal data for the following purposes:
1. To meet requests or applications that you make through the Corporate Contacts and Customer Contacts channels
We only process the personal data that are strictly necessary to manage or resolve your request or application.
2. Analysis of usability and quality to improve our services
If you access our Platform, we inform you that we will treat your browsing data for analytic and statistic purposes, i.e., to understand the manner in which users interact with our Platform and thus be capable of introducing improvements in the Platform, as well as to address the suggestions for improvements that, as user, you might send to us.
- HOW WE ARE LEGALLY PERMITTED TO PROCESS YOUR DATA?
The legal terms on which we are permitted to process your personal data also depends on the purpose for which we process them, as explained in the following table:
1. Corporate Contacts and Customer Contacts
We consider that we have legitimate interest in answering the requests or consultations raised by you through the existing different contact channels. We understand that the processing of these data is also beneficial to you to the extent that it enables us to assist you adequately and answer to the consultations raised.
When you get in touch with us, in particular, for the management of incidents related to your order or the product/service of our brands acquired through one of the stores operated by the companies of the Inditex Group, the processing of your data is necessary to perform the purchase contract.
When your consultation is related to the exercise of your rights on which we inform you below, or to claims on the products or services of the Inditex Group brands, we are legally permitted to process your data for compliance with our legal obligations.
2. Analysis of usability and quality
We consider that we have a legitimate interest in analysing the Platform usability and the user's satisfaction degree, since we understand that the processing of these data is also beneficial for you because the purpose is to improve the user experience and provide a higher quality service, as well as to address the suggestions that you, as user, could send to us.
- HOW LONG WILL WE KEEP YOUR DATA?
The time for which we will keep your data will depend on the purposes for which we process them, as explained below:
Time for which the data are kept
1. Corporate Contact and Customer Contact
We will process your data for the time necessary to meet your request or application.
2. Analysis of usability and quality
We will process your data occasionally for the time during which we proceed to carry out a specific quality action or survey or until we anonymise your browsing data. As well as during the strictly necessary time to address your suggestion.
Notwithstanding the fact that we will process your data for the time strictly necessary to achieve the purpose in question, we will subsequently keep them duly stored and protected for the time during which liability may arise for their processing, in compliance with legislation in force from time to time. Once each of the potential actions is time-barred we will proceed to delete the personal data.
- DO WE SHARE YOUR DATA WITH THIRD PARTIES?
- technological service providers,
- providers of customer support related services.
For service efficiency purposes, some of these providers are located in territories outside the European Economic Area that do not offer a level of data protection comparable to that of the European Union, as the United States of America. In such cases, we inform you that we will transfer your data with adequate safeguards and always keeping your data safe:
- Some providers are certified Privacy Shield, which certification you may consult through the following link:
- With other providers, we have agreed Standard Contractual Clauses approved by the EU Commission, the content of which you may consult through the following link:
- WHAT YOUR RIGHTS ARE WHEN MAKING YOUR DATA AVAILABLE TO US
We undertake to keep your personal data confidential and to ensure that you may exercise your rights. Bearing that in mind, you may exercise your rights free of charge by writing us an e-mail to our e-mail address (email@example.com), simply informing us of the reason for your request and the right that you wish to exercise. If we consider this necessary to be able to identify you, we may request you to provide a copy of a document evidencing your identity.
In particular, notwithstanding the purpose or legal basis we use to process your data, you have the following rights:
- To request access to your personal data that we hold.
- To request that we rectify the personal data that we hold. In any case, please take into account that, on actively making your personal data available to us through any procedure, you guarantee that they are true and accurate and you undertake to notify to us any change or modification of your data. You will be liable for any loss or damage caused to the Platform or to the person responsible for the Platform or to any third party by reporting erroneous, inaccurate or incomplete information in the registration forms. Please remember that, as a general rule, you must provide us only with your own data, not with those of third parties.
- To request that we erase your personal data to the extent that they are no longer necessary for the purpose for which we need to keep processing them, as we have explained above, or when we are no longer legally permitted to process them.
- To request that we cancel or limit the processing of your personal data, which entails that in certain cases you can request us to temporally suspend the processing of the data or that we keep them longer that necessary.
Where the processing of your data is based on our legitimate interest, you will also have the right to object to the processing of your data.
Finally, we inform you that you have the right to file a claim before the responsible data protection regulatory authority, in particular, before the Spanish Data Protection Agency (https://www.agpd.es/portalwebAGPD/index-ides-idphp.php).
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