This Privacy Policy will apply to the processing carried out by POLO CLUB EUROPE SL of the personal data of the users (hereinafter, “User(s)” or “you”) whose information has been collected via the following means:

- the website www.poloclub.com (hereinafter, the “Website”)

- e-mail communications.

- WhatsApp communications.

- communications via social networks.

1. Controller responsible for the processing

POLO CLUB EUROPE SL (hereinafter, “POLO CLUB” or “Us”).
B-54512512
Ptda. Jubalcoi Polígono 1, Nº 90
03295 Elche (Alicante).
Email: rgpd@poloclub.com

2. Is it necessary to provide the required data?

POLO CLUB will duly state when the data collected via the Website, email, WhatsApp and social networks are mandatory or voluntary. Failing to provide the information with the required personal data or doing so partially could imply that POLO CLUB may not be able to deal with the requests or services required by the Users.

Additionally, in the event that the Users provide data of third parties, they guarantee that they have informed these third parties of the aspects contained in this Privacy Policy and, if necessary, that they have obtained the consent of these third parties.

• What data we collect and what for

POLO CLUB will process the following data depending on how you interact with Us or what for, for the following purposes:

PROCESSING	TYPE OF DATA	PURPOSE
WHEN YOU MAKE A PURCHASE OR RETURN	-     The identifying data you provide Us with (name and surname, address, telephone number, e-mail address). -     Details about your account number or bank cards for completing your purchase. -     Personal characteristics: age and gender (only for conducting surveys).	· To manage the purchase and shipment of products.  · To manage orders and returns. · To inform you occasionally about news/promotions related to POLO CLUB’s products. · To send you surveys via Hubspot and other channels such as Outvio, to find out your satisfaction with the purchase you have made or with the return process.
	LEGAL GROUNDS: the execution of a contract or pre-contract to which the User is a party, to manage their purchase, orders and returns (art. 6.1.b of the General Data Protection Regulation, hereinafter, GDPR). The legitimate interest of POLO CLUB to send you timely and occasional news/promotions related to previous purchases from POLO CLUB and the sending of occasional shopping experience surveys or satisfaction surveys in the return process (art. 6.1.f) GDPR).
WHEN YOU REGISTER AS A CUSTOMER ON OUR WEBSITE	-     The identifying data you provide Us with (name and surname, address, telephone number, e-mail address). -        Details about your account number or bank cards for completing your purchase. -        Product preferences (optional). -        Personal characteristics (optional): age, gender.	· To manage your User profile. · To manage direct access to order status, order history, etc. · To notify you of any changes to our service. · To notify you of new promotions/giveaways by email or SMS.
	LEGAL GROUND: the execution of a contract or pre-contract to which the User is a party (art. 6.1. b GDPR).
WHEN THE CUSTOMER IS A MEMBER OF THE LOYALTY PROGRAMME	-        The User’s personal details when registering. -        Date of birth(optional). -        Order history.	· To manage the profile as a Member of the Loyalty Programme based on the different categories. · To manage the points earned on purchases. · To apply the agreed discounts according to the Member’s category. · To send communications related to the Loyalty Programme.
	LEGAL GROUND: the execution of a contract or pre-contract to which the User is a party (art. 6.1. b GDPR), for managing the Loyalty Programme membership, including sending communications about the Loyalty Programme, points balance, discounts applied, etc.
WHEN A MEMBER OF THE LOYALTY PROGRAMME INVITES A FRIEND TO PARTICIPATE	-        The friend’s email address	· To send two communications to offer a discount for the next purchase at POLO CLUB.
	LEGAL GROUND: The friend’s – owner of the data – consent (Art. 6.1.a) GDPR).
WHEN YOU CONTACT POLO CLUB	-     The identifying data you provide Us with in relation to your order, your User profile or any query you make (e.g. availability of clothes).	·  To assist you when you ask Us questions ·  To exchange communications by email. ·  To send satisfaction surveys about the operation of our customer service.
	LEGAL GROUND: The user’s consent. (art.6. 1.a) GDPR) for the exchange of communications and response to queries. Legitimate interest (art. 6.1.f) GDPR) for sending satisfaction surveys to check the efficiency of our customer service.
WHEN YOU SEND US YOUR CV	-         Your identifying details, such as name, surname, ID, etc. -         Contact details: home address, telephone number, addresses (including postal and electronic), etc. -         Data about your personal characteristics, such as: gender, date and place of birth, age, nationality, etc. -         Professional and educational details.	·  To manage the application to apply for a job selection process. ·  In order to manage and process your request for accessing a selection process, the information provided may be contrasted with third-party sources (Internet, information provided by you regarding previous jobs, academic institutions also referred to by you in your CV, etc…).
	LEGAL GROUND: The execution of a contract or pre-contract with the User (art. 6.1.b) GDPR).
WHEN YOU REQUEST US TO SEND YOU AVAILABILITY NOTICES	-          The email address you provide.	· To inform you of the availability of the products requested
	LEGAL GROUND: The user’s consent (art. 6.1.a) GDPR).
WHEN YOU REQUEST US TO SEND YOU NEWSLETTERS OR PUSH NOTIFICATIONS	-          The e-mail you provide Us with to send you communications about offers and products of your interest. -          Product preferences (optional). -          The User’s IP, in the case of sending push notifications.	·  To keep you informed about POLO CLUB news and offers. ·  To take into account your product preferences, to send a newsletter that fits your interests.
	LEGAL GROUND: the express consent of the User (art.21.1. of the Law on Information Society Services and art. 6.1.a) RGPD) for the sending of the newsletter and push notifications , which is understood to be granted by “checking” the box enabled for this purpose in the corresponding form.
WHEN YOU NAVIGATE OUR WEBSITE	Each time you access the POLO CLUB Website, we automatically collect and process information about how you access and use the Website and, in particular, the following personal data: -          Technical information, including your IP address, access data, browser and version, operating system and/or -          Information regarding your visits to our Website, including the Uniform Resource Locator (URL), the services viewed or searched and the pages you visit, the response time of the site, download errors, the time and date of the visit, the time spent on those pages, information about interaction on the site (for example, clicks and/or mouse movements), the methods used to leave the site, unique device identifiers, and other diagnostic data and/or -          Information collected through the use of cookies. You can learn more about the use of cookies and how to manage them in our Cookie Policy	·  To allow you to participate in interactive features of our Website when you choose to do so. ·  To collect statistical analysis, research and profiles for navigation and content interest, or other valuable information that will enable Us to improve our Website and service.   ·  To detect, avoid and address technical problems.
	LEGAL GROUND: The user’s express consent. (art. 22 LSSI and Art. 6.1.a GDPR)
WHEN YOU DEFER PAYMENT	-        The identifying data you provide Us with (name and surname, address, telephone number, e-mail address). -        Details about your account number or bank cards for completing your purchase.	·  To defer payments based on options chosen by the User. ·  To communicate the data to the company that finances the payments.
	LEGAL GROUND: the execution of a contract or pre-contract to which the User is a party. (art. 6.1.b GDPR)
WHEN YOU INCLUDE A SUGGESTION OR COMPLAINT IN THE WEB EXPERIENCE AREA	-        Contact details: email. -        Those personal data that are included in the mailbox to issue the complaint or suggestion.	·    To be able to learn about the experience of Users and verify by entering their email that the opinion is real. ·    We may contact those Users who did not have a good experience at the email provided.
	LEGAL GROUND: The User’s consent (art. 6.1.a) GDPR)
WHEN YOU ENTER A GIVEAWAY OR CONTEST	The data requested in the terms of the giveaway, generally: -        Identifying details (name, surname, gender, age). -        Contact details (email, phone number). -        Postal address for sending the prize. The condition of social media User.	·    To manage the participation of Users in the contest/giveaway set out in the Terms. ·    To inform the winner of the contest/giveaway. ·    To send or deliver the prize(s).
	LEGAL GROUND: The User’s consent (art. 6.1.a) GDPR) or execution of a contract (art. 6.1.b) GDPR) according to what is stipulated in the legal terms of the giveaway/contest.

 

3. Recipients

POLO CLUB shall not share any information you provide Us with unless authorised by you, there is a legal obligation to do so, or under express judicial request or as requested by Security Forces.

You should also know that, in order to carry out our activity, POLO CLUB may contract third parties (natural or legal persons) to provide any services on our behalf – such as the courier services that deliver your order – to provide services related to ours or to help Us analyse how our service is used, all of which may involve the processing of your personal data.

These third parties will have access to your personal data only to perform these tasks on our behalf on the basis of the corresponding processing contract where we give them instructions on how they have to process and protect your data. They are obliged not to disclose or use your data with any other purpose.

FLEXIBLE PAYMENT OPTION

-If you choose Klarna flexible payments, you will need to enter your personal data in the form Klarna has put on our Website to carry out credit assessments and to adapt the payment methods available for you. Klarna will be responsible for the personal data you provide. These data will be processed according to their privacy policy, which you can find here.

You can learn more about Klarna and the flexible payments here.

If you buy from outside Spain and Portugal and you choose Scalapay flexible payments, only available in Italy for the moment, you will need to enter your personal data in the form Scalapay has put on the corresponding website to carry out credit assessments and to adapt the payment methods available for you. Scalapay will be responsible for the personal data you provide. These data will be processed according to their privacy policy, which you can find here. 

You can learn more about Scalapay and the flexible payments here.

RETURNS

In case of returning the product, you shall provide your email via the following link. Outvio shall process the return of the product or products. In addition, Outvio may send you surveys to measure customer satisfaction in relation to the return.

Learn more about Outvio and its privacy management here.

4. Transfer of data to third countries

POLO CLUB, as the data controller, informs you that some of the specific storage and processing activities carried out are performed with the support of natural or legal persons located outside the European Union.

However, in these cases, POLO CLUB informs you that we take the necessary steps to ensure that your data is processed securely and in accordance with this Privacy Policy. In particular, POLO CLUB informs you that we will not transfer your personal data to organisations or countries located outside the European Union, unless they are countries with an adequate level of protection or sufficient guarantees are offered and they recognise the data subject’s enforceable rights and effective legal actions.

5. Storage

The personal data provided will be held, in general, for the time strictly necessary to fulfil each of the intended purposes plus, where appropriate, the limitation periods for the requirement of contractual or precontractual responsibilities, or until you revoke your consent to the processing.

In particular:

• Data on purchases made shall be kept for a period of 5 years unless other time limits apply.

• The data provided by registering on our Website will be processed until the moment you decide to stop being a registered User of our Website.

• The data provided and collected as a Member of the Loyalty Programme will be kept until you decide not to continue in the Loyalty Programme or until you decide not to continue being a registered User of our Website.

• The data of the friends referred by members of the Loyalty Programme will be processed only to send them two communications to inform them of the discount offered, and will be stored for a month.

• The personal details for the delivery of commercial communications by email or SMS will be used for this purpose until you notify Us you do not want to continue receiving such communications.

• The data for receiving our newsletter will be held as long as you do not unsubscribe.

With regard to push notifications , if you do not wish to receive them, you shall disable this option from the settings panel of your browser. This process may vary depending on the browser you use. Below is how to disable these notifications from the different browsers:

• Chrome

• Safari

• Mozilla Firefox

• Microsoft Edge

• The details of the queries you make to Us through the customer service channels or any other queries you make to Us through the channels available on our Website (for example, clothes availability notifications) will be held until the inquiry has been resolved, unless such data must be incorporated into the User's purchase record, in which case the storage time for purchases shall apply.

• The data for sending product availability notices will be processed only for this purpose and will be stored for the reasonable necessary time to send the notices and then the data will be deleted permanently.

• Data generated by web browsing will be held in accordance with or as established in our Cookie Policy.

• The data for entering the giveaways shall be kept only for managing them.

• Your rights

You have the following rights that affect the processing of your personal data: access, rectification, deletion, opposition, limitation and transfer, which you can exercise at the e-mail address rgpd@poloclub.com, stating in the subject ‘EXERCISE OF RIGHTS’.

In the event that POLO CLUB has reasonable doubts regarding the identity of the person making the request, POLO CLUB may request Users to provide the additional information necessary to confirm their identity.

Occasionally, the request exercised will result in the storage, limitation or blocking, as appropriate, to give effect to such rights.

For those cases in which the legal ground is consent, you have the right to withdraw consent at any time, without affecting the legality of the processing based on consent prior to withdrawal.

In addition to the foregoing, you may, at any time, object or revoke your consent for receiving commercial communications by requesting it at the email address provided above, at the link provided for that purpose in each of the commercial communications we send you or, if you are a registered User of our Website, via the option enabled for that purpose in your profile.

Similarly, in the event that POLO CLUB does not comply with its legal obligations in relation to the protection of your personal data, you have the right to file your claim to the competent authority, which in Spain is the Spanish Data Protection Agency (www.aepd.es)

• Safety

The main mission is to ensure and guarantee the processing of both personal data and associated information, ensuring their custody and integrity. Therefore, POLO CLUB takes organisational and technical measures to ensure the safety of personal data and to prevent its alteration, loss, processing or unauthorised access, in view of the state of the technology, the nature of the stored data and the risks to which they are exposed, whether they come from human action or from the physical or natural environment, not being responsible for any loss or manipulation of data that is unauthorised and unwillingly unanticipated or due to malicious attacks by third parties.

1. Links to other websites

Our Website may contain links to other websites not managed by Us. By clicking on a third-party link, you will be redirected to this third party's site. We have no control or take no responsibility with respect to the privacy policies or practices of third-party sites or services.

We strongly recommend that you review the Privacy Policy for all the sites you visit.

6. Children’s privacy

Our service is not intended for anyone under 18.

We do not try to collect personal information from children under 18. If you are a parent or guardian and are aware that your child or ward has provided Us with personal information, please contact Us.

The Users guarantee the truthfulness and authenticity of the information and data they communicate when using this Website. Any false or inaccurate communication resulting from the information and data expressed, as well as any prejudice that such information may cause, shall be the Users’ sole responsibility.

If we are aware that we have collected personal data of children under 18 without checking that consent was given or authorised by the parent or guardian of the child, we will take the steps to remove that information from our servers and we reserve the right not to provide the service.

7. Changes to this Privacy Policy

POLO CLUB may update this Privacy Policy at any time. The Privacy Policy published at that specific time will apply. Therefore, we ask you to check it from time to time. You will be duly informed of any amendments to this Privacy Policy so that you are aware of such changes, and can exercise your rights if you do not agree.

 

Latest version:  June 2024