In accordance with the provisions of current regulations on the Protection of Personal Data, Nanos accepts and consents that his/her personal data may be collected, processed and incorporated into the processing system owned by FASHION EL PULPO, for the purpose of providing the services of the company linked to the textile sector.

FASHION EL PULPO informs you that it has adopted all the required security measures, and that the data will be kept for the period strictly necessary. Nanos will process the data in a confidential, lawful, fair, transparent, adequate, pertinent, limited, exact and updated manner. You may exercise the rights of access, rectification, limitation of processing, deletion, portability and opposition to the processing of your personal data, as well as the consent given for the processing of the same, by directing your request to the postal address indicated above or to the email addressdataprotection@elpulpo.es

WHO ARE WE?

We are Fashion el Pulpo SL and we process your personal data as Data Controller. This means that we are responsible for how your data is used and protected.

WHAT DO WE USE YOUR DATA FOR?

We will use your data (obtained online or in person), among other purposes, to manage your registration as a user, manage the purchase of products or services, answer your queries and, if you wish, send you our personalized communications.

WHY DO WE USE THEM?

We may process your data for a number of reasons. The main reason is that we need to process it to execute the contract you agree to with us when you register and make a purchase or enjoy any of our services or features. We also use your data for other reasons, for example, to answer your questions or to send you newsletters that you have asked us to receive.

WHO DO WE SHARE YOUR DATA WITH?

We will share your data with service providers who help or support us.

YOUR RIGHTS

You have the right to access, rectify or erase your personal data. In some cases, you also have other rights, for example, to object to our use of your data or to port it, as we explain in detail below.
We invite you to read our full Privacy Policy below to fully understand how we will use your personal data and the rights you have in relation to it.

BEFORE YOU START...

• In this Privacy Policy you will find all the relevant information that applies to our use of the personal data of our clients and users, regardless of the channel or medium (online or in person) that you use to interact with us.
• If you would like information about how we use cookies and other similar devices that may be installed on the devices of our clients and users, we recommend that you consult the Privacy Policy.
• We are transparent about what we do with your personal data, so that you understand the implications of our uses or the rights you have in relation to your data.
• We make all the information in this Privacy Policy permanently available to you, which you can consult whenever you deem appropriate, and you will also find information about each processing of your personal data as you interact with us.
• Some names that we will use in this Privacy Policy: When we talk about our Platform, we will generally refer to any of the digital or in-person channels or media that you have used to interact with us, mainly we refer to our website or one of our Physical Stores.

WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR DATA?

The persons responsible for the processing of your data are Fashion el Pulpo SL, CIF B70567763, a company that currently operates in Spain the sale of products of the Nanos brand

• Postal address: C/ Parroquia de Rois B30 Bergondo, 15165 A Coruña
• Email address of the Data Protection Officer:dataprotection@elpulpo.es

FOR WHAT PURPOSE DO WE PROCESS YOUR PERSONAL DATA?

Depending on the products, services or functionalities that you wish to enjoy at any given time, we will need to process certain data or others, which in general will be, as appropriate, the following:

• your identifying data (for example, your first name, last name, image, language and country from which you interact with us, contact information, etc.);
• financial and transactional information (for example, your payment or card details, information about your purchases, orders, returns, etc.);
• connection, geolocation and navigation data (for example, location data, device identification number or advertising ID);
• commercial information (for example, if you have subscribed to our newsletter),
• data about your tastes and preferences.

Please note that when we ask you to fill in your personal data to give you access to a feature or service on the Platform, we will mark some fields as mandatory, since these are data that we need in order to provide you with the service or give you access to the feature in question. Please note that if you choose not to provide us with this data, you may not be able to complete your registration as a user or you may not be able to enjoy those services or features. In other cases, we may obtain information passively by using tracking tools, such as browser cookies or other similar technologies on our Platform or from the communications we send you. In such cases, we will only process your data in relation to that feature or service, in accordance with the provisions of this Privacy and Cookies Policy.

Depending on how you interact with our Platform, we will process your personal data for the following purposes:

1. To manage your registration as a user of the platform

If you decide to register as a user on our Platform, we need to process your data to identify you as a user of the Platform and give you access to its different functionalities, products and services that are available to you as a registered user. You can cancel your registered user account by contacting us through Customer Service.
Please be advised that the data we collect about your activity, obtained through the Platform's various channels, including your purchases, will remain linked to your account so that all information can be accessed at once.

2. For the development, fulfillment and execution of the sales or service contract that you have contracted with us on the Platform. This purpose includes the processing of your data mainly for:

• Contact you regarding updates or informative communications related to the functionalities, products or services contracted, including the sending of quality surveys about the products or services provided.
• Manage payment for the products you purchase, regardless of the payment method used.
• Activate the necessary mechanisms to prevent and detect unauthorized uses of the Platform (for example, during purchase or return processes), as well as potential fraud against you or us. If we consider that the transaction may be fraudulent or detect abnormal behavior that indicates an attempt at fraudulent use of our features, products or services, this process may have consequences such as blocking the transaction or deleting your user account.
• Manage possible changes or returns once you have made a purchase and manage requests for information on the availability of garments, product reservations through the Platform.
• For billing purposes and to make available to you the tickets and invoices of the purchases you have made on the Platform.
• Guarantee the use of other functionalities or services to the extent that they are available, such as the purchase, receipt, management and use of the Gift Card or Gift Ticket.

3. To respond to requests or queries you make through customer service channels

We only process personal data that is strictly necessary to manage or resolve your request or query. If you decide to use WhatsApp as a channel to communicate with Customer Service, we will provide your phone number to WhatsApp Inc. to verify that you are a user of this service. We recommend that you review your privacy settings and read WhatsApp's privacy policy for more detailed information on WhatsApp's use of the personal data of users who use its services. If available, and you decide to communicate with Customer Service through the chat service of a social network or other partner, some of your data, such as your name or username, will be imported from your account on the social network or partner. You should also be aware that the data you enter into this service will be available to your social network or partner and will be subject to their corresponding privacy policies. Therefore, we recommend that you review your privacy settings and read the privacy policy of the social network or partner for detailed information on their use of your personal data when using their services.

4. For marketing purposes , this purpose includes the processing of your data, mainly:

• Personalize the services we offer you and make recommendations based on your interaction with us through the Platform and the analysis of your user profile (for example, based on your purchase and browsing history).
• To the extent that you subscribe to our Newsletter, we will process your personal data to manage your subscription, including sending you personalized information about our products or services through various means (such as email). We may also send you this information through push notifications if you have activated them on your device.
• Please note, therefore, that this data processing involves analysing your user or customer profile to determine your preferences and therefore which products and services best fit your style when sending you information. For example, based on your purchase and browsing history (namely, based on the items you have clicked on), we will make suggestions about products that we think may interest you and, if you are a registered user, we will provide you with the "cart recovery" feature.
• Please note that you can unsubscribe from the Newsletter at any time and free of charge through the "Newsletter" section of the Platform, as well as through the instructions we provide in each communication. If you do not wish to receive push notifications, you can deactivate this option on your device.
• Show you online advertising that you may see when you browse websites and apps, for example on social media. The advertising you see may be displayed at random, but other times it may be advertising that may be related to your purchase history, preferences and browsing.
• If you use social media, we may provide certain data to the companies we work with so that they, as joint controllers, can show you advertisements about our brand and, in general, offer you advertisements that are relevant to your profile on these social media. If you want information about the use of your data and the functioning of advertisements on these social media, we recommend that you review the information about your privacy on the social media networks in which you participate.
• Additionally, we use your data to perform measurement and segmentation analyses of the ads we show to users on some partner platforms. To do this, we collaborate with these third parties who offer us the necessary technology (for example, through cookies, pixels, SDK) to use these services. Please note that we may need to provide them with certain information or some type of identifier each time (for example, the advertising ID associated with the device, an identifier associated with a cookie, etc.). If you want more information in this regard, you can review our Cookie Policy. Likewise, you can reset your advertising identifier or disable the personalization of ads on your device by modifying your preferences in the settings section of your device.
• Data enrichment: Where we obtain your personal data from different sources, we may combine them in certain circumstances to improve our understanding of your needs and preferences in relation to our products and services (including for the purposes of analysis, generating usage profiles, marketing studies, quality surveys and improving our interaction with our customers). By this we mean, for example, how we combine your information if you have a registered account and, using the email associated with that account, make a purchase as a guest, or automatically collected information (such as IP or MAC addresses or metadata) that we may link with information you have provided directly to us through your activity on the Platform or in one of our stores (for example, information related to your online or physical store purchases, your preferences, etc.).
• Carry out promotional actions (for example, to run contests or send your list of saved items to the email address you provide). By participating in any promotional action, you authorize us to process the data you provide us with based on each promotional action and to communicate them through various means such as social networks or on the Platform itself. For each promotional action in which you participate, you will have available the legal bases where we will provide you with more detailed information about the processing of your data.
• Share on the Platform or through our social media channels photographs or images that you have shared publicly, provided that you give us your consent to do so.

5. Usability and quality analysis to improve our services

If you access our Platform, we inform you that we will process your browsing data for analytical and statistical purposes, that is, to understand the way in which users interact with our Platform and with the actions we carry out on other websites and apps, in order to improve our services. Likewise, we occasionally carry out quality actions and surveys aimed at understanding the level of satisfaction of our customers and users and detecting those areas in which we can improve.

WHAT IS THE LEGITIMATION FOR THE PROCESSING OF YOUR DATA?

The legal basis that allows us to process your personal data also depends on the purpose for which we process it, as explained below:

• Managing your registration as a user of the Platform: the processing of your data is necessary for the execution of the terms that regulate the use of the Platform. In other words, in order for you to register as a user on the Platform, we need to process your personal data, since otherwise we would not be able to manage your registration. We consider that we have a legitimate interest in linking your purchases and the data we collect about your activity through the different channels of the Platform to your account. In the event that you choose to use access or login through a social network, the reason why we are authorized to process your data is the consent you give when authorizing the transfer of your data from the social network.

• Development, fulfilment and execution of the sales or services contract: the processing of your data is necessary for the execution of the sales or services contract that binds us. It is possible that some data processing associated with the purchasing process is activated only because you request or authorise us to do so, such as the storage of payment data for future purchases. In these cases, the basis on which we process your data is your own consent. We consider that we have a legitimate interest in carrying out the necessary checks to detect and prevent possible fraud or fraudulent use when you use the Platform, for example, when making a purchase or return. We understand that the processing of this data is positive for all parties: for you, since it allows us to put measures in place to protect you against attempted fraud by third parties; for Us, because it allows us to prevent misuse of the Platform; for all our customers and society, because it also protects their interest in ensuring that fraudulent activities are discouraged and detected when they occur.

• Customer service: We consider that we have a legitimate interest in responding to the requests or queries that you submit to us through the various means of contact available. We understand that the processing of this data is also beneficial to you as it allows us to adequately serve you and resolve the queries raised. When you contact us, in particular, to manage incidents related to your order or the product/service purchased through the Platform, the processing is necessary for the execution of the sales contract. When your query is related to the exercise of the rights about which we inform you below, or to claims related to our products or services, what legitimizes us to process your data is compliance with legal obligations on our part.

• Marketing: The legitimate basis for processing your data for marketing purposes is the consent you give us, for example when you agree to receive personalized information through various means, when you authorize the sending of push notifications on your mobile device, or when you accept the legal bases to participate in a promotional action or to publish your photographs on the Platform or on our social media channels. In order to offer you personalized information or services, whether on our Platform or on that of third parties, and to commit to improving the data, we consider that we have a legitimate interest in profiling with the information we have about you (such as your browsing habits, preferences or purchase history) and the personal data you have provided us with, such as age range or language, since we understand that the processing of this data is also beneficial to you because it allows you to improve your experience as a user and access information in accordance with your preferences.

• Usability and quality analysis: We consider that we have a legitimate interest in analyzing the usability of the Platform and the degree of user satisfaction, since we understand that the processing of this data is also beneficial to you because the purpose is to improve the user and customer experience and offer a higher quality service.

HOW LONG WILL WE KEEP YOUR DATA?

The retention period of Your data will depend on the purposes for which we process them, as explained below:

• Manage your registration as a user of the Platform: we will process your data for as long as you remain a registered user (i.e., until you decide to unsubscribe).

• Development, fulfillment and execution of the contract of sale or services: we will process your data for the time necessary to manage the purchase of the products or services you have acquired, including possible returns, complaints or claims associated with the purchase of the particular product or service. In some cases, we will only process the data until the moment you decide, as is the case of the payment data that you have asked us to store for possible future purchases (if this functionality is available).

• Customer service: We will process your data for as long as necessary to respond to your request or query.

• Marketing: We will process your data until you unsubscribe or cancel your subscription to the newsletter. We will also show you personalized ads until you change your device, browser or cookie settings, which will revoke said permission.

• Usability and quality analysis: we will process your data punctually during the time in which we proceed to carry out a specific quality action or survey or until we anonymize your browsing data. Regardless of whether we process your data for the time strictly necessary to fulfill the corresponding purpose, we will subsequently keep them duly stored and protected for the time in which liabilities arising from the processing may arise, in compliance with the regulations in force at any given time. Once the possible actions in each case expire, we will proceed to delete the personal data.

WILL WE SHARE YOUR DATA WITH THIRD PARTIES?

In order to fulfill the purposes indicated in this Privacy Policy, it is necessary that we give access to your personal data to third parties that support us in the services we offer you, namely:

• financial institutions,
• fraud detection and prevention entities,
• technology and analytical service providers,
• suppliers and collaborators of logistics, transport and delivery services or their associated establishments,
• Customer service providers,
• providers and collaborators of services related to marketing and advertising, such as advertising agencies, advertising partners or social networks that, in certain cases, may act as joint controllers. For the efficiency of the service, some of the aforementioned providers are located in territories outside the European Economic Area that do not provide a level of data protection comparable to that of the European Union. In such cases, we inform you that we transfer your data with adequate guarantees and always maintaining the security of your data, since we use the most appropriate tools for the international transfer of data, such as the Standard Contractual Clauses or any other relevant complementary measure. You can consult the content of the Standard Contractual Clauses at the following link: https://commission.europa.eu/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transferpersonal-data-third-countries_en

WHAT ARE YOUR RIGHTS WHEN YOU PROVIDE US WITH YOUR DATA?

We are committed to respecting the confidentiality of your personal data and guaranteeing that you can exercise your rights. You can exercise them free of charge by writing us an email to our addressdataprotection@elpulpo.es , simply indicating the reason for your request and the right you wish to exercise. If we consider it necessary to identify you, we may request a copy of a document proving your identity. We may also offer you the possibility of exercising your rights and setting your privacy preferences when using some of our services or by making specific channels available to you within our Platform. In particular, regardless of the purpose or legal basis under which we process your data, you have the right to:

• Ask us to rectify the data we already have. Remember that if you are a registered user on the Platform, you can also access the section corresponding to your personal data in your account to modify or update your personal data. In any case, please note that, by actively providing us with your personal data by any means, you guarantee that it is true and accurate and you undertake to notify us of any change or modification to it. Any loss or damage caused to the Platform or the person responsible for the Platform or any third party due to the communication of erroneous, inaccurate or incomplete information in the registration forms will be the sole responsibility of the user. Please remember that, as a general rule, you should only provide us with your own personal data, not that of third parties, except as permitted in this Privacy and Cookies Policy.
• Ask us to delete your data to the extent that it is no longer necessary for the purposes for which we need to process it as we have informed you above, or that we no longer have the legitimacy to do so.
• Ask us to limit the processing of your data, which means that in certain cases you can ask us to temporarily suspend the processing of the data or to keep it beyond the time necessary when you may need it. If you have given us your consent for the processing of your data for any purpose, you also have the right to withdraw it at any time. Some of the ways in which you can withdraw your consent are explained in the section where we explain for what purposes we process your data. If you do not want information to be sent to third parties to show you ads, you have several means, such as changing the preferences on the device, browser or cookie settings, reviewing the privacy policy and settings of the social networks on which you have a profile or sending us an email with your request to the address mentioned above. When our legitimacy for the processing of your data is your consent or the execution of the contract, you will also have the right to request the portability of your personal data. This means that you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format, in order to be able to transmit it to another entity directly, whenever technically feasible.

Furthermore, when 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 of your right to lodge a complaint with the relevant data protection control authority, in particular, with the Spanish Data Protection Agency: https://www.aepd.es/

WHAT HAPPENS IF YOU PROVIDE US WITH THIRD PARTY DATA OR IF A THIRD PARTY HAS NOT PROVIDED THEIR DATA?

We offer features or services that require us to process the personal data of a third party that you, as a user or customer, provide to us, such as for the activation and sending of the Gift Card or the management of the Gift Ticket request (where these features are available) or when you authorize a third party to collect an order in our stores or associated establishments. If you provide us with personal data of third parties or if it is necessary for us to request it from them to collect an order on your behalf, you guarantee that you have informed them about the purposes and the way in which we need to process their personal data. If a third party has provided us with your data or has provided it as a result of a feature or service requested by one of our users, we will use it to manage the feature or service that is being developed in each case, within the purposes set out in this Privacy and Cookies Policy, a link to which we usually include in our communications.

CHANGES TO THE PRIVACY AND COOKIE POLICY

We may modify the information contained in this Privacy Policy whenever we deem it appropriate. If we do so, we will notify you in different ways through the Platform (for example, through a banner, a pop-up or a push notification), or we will even communicate it to your email address when the change in question is significant for your privacy, so that you can review the changes, evaluate them and, if applicable, object to or unsubscribe from any service or functionality. In any case, we suggest that you review this Privacy Policy from time to time in case there are minor changes or we introduce any interactive improvements, taking advantage of the fact that you will always find it as a permanent point of information on our Website.

INFORMATION ABOUT COOKIES

We use cookies and similar devices to facilitate your navigation on the Platform, to understand how you interact with Us and, in certain cases, to be able to show you advertising based on your browsing habits. Please read our Cookie Policy to learn more about the cookies and similar devices we use, their purpose and how to manage your preferences, as well as other information of interest.