PRIVACY POLICY

Version 05 of May 2021

It is important that you read this General Privacy Policy carefully before browsing the www.sanpatrick.com website.

This website is operated by the Spanish company San Patrick, S.L.U. (hereinafter referred to as “San Patrick”). San Patrick is committed to the privacy of its users and customers and therefore makes this General Privacy Policy available to you. Here you can find out which personal data we collect from users, how we treat such data, the purposes of such treatment, your obligations as a customer, how to contact us and what to do to exercise your rights.

The purpose of this General Privacy Policy is to explain how San Patrick processes different personal data for different purposes. It should not however be considered exhaustive as it is supplemented by information made available to the customer in the various data gathering forms or interactions between Pronovias and the User.

SAN PATRICK AND THE USER OR CUSTOMER
WHAT DATA DOES SAN PATRICK GATHER FROM USERS AND PROCESS?
PREPARATION OF PROFILES
COMMERCIAL MAILINGS
WHAT INFORMATION DO WE SHARE WITH THIRD PARTIES?
DURATION OF PROCESSING AND PRESERVATION OF DATA
YOUR OBLIGATIONS AS A CUSTOMER
YOUR RIGHTS AS A CUSTOMER
DATA SECURITY
COOKIES POLICY
ALTERATIONS OF GENERAL PRIVACY POLICY
CONTACTS

1. SAN PATRICK AND THE USER OR CUSTOMER

The company San Patrick, S.L.U. (hereinafter “San Patrick”), incorporated in accordance with Spanish law, with offices at Polígono Industrial Mas Mateu, s/n., 08820 El Prat de Llobregat (Barcelona) holder of Tax Identification Code number B-63523609 and owner of the website http://www.sanpatrick.com (hereinafter the “Website”). Hence San Patrick is the controller of the Website.

San Patrick is part of the international corporate group Pronovias, which includes all those companies affiliated under its various brands, among others: “White One", "Pronovias", "St. Patrick" and "La Sposa", companies that you can consult at any time at [see link].

And as will be set out in the course of this General Privacy Policy, some of our stores spread throughout the world and managed in each case by the local company of the Pronovias Group may gather data for us or use it to provide a better service.

Accessing the Website, using any channel of communications with us, or visiting a store, are some of the ways to acquire the status of User or Customer (hereinafter the “Customer”).

This General Privacy Policy constitutes, together with the Terms of Use and the Cookie Policy, as well as the different Specific Privacy Policies that may be included in each data collection form, the set of rules that regulate the use of the Website, as well as the relationship between San Patrick and the User. This General Privacy Policy governs, in particular, San Patrick's treatment of Customers' personal data.

This General Privacy Policy is available in the languages available in the Website for you to consult, archive or print any time you wish.

2. WHAT DATA DOES SAN PATRICK GATHER FROM USERS AND PROCESS?

San Patrick may gather a wide variety of information from Customers in relation to the purposes set out, on a non-exhaustive basis, in this General Privacy Policy. And as we have already indicated all forms or forms of interaction with the Customer in which personal data is gathered we may provide information by way of an appropriate specific Privacy Policy unless covered by this one. Apart from cookies and other web analysis technology, or comments made by our customers in the blog or on social networks or other sites on the Internet, Pronovias may gather personal data and information from Customers by way of the following channels, forms or routes of the Website, and in our stores:

Newsletter registration form.
User account (My changing room).
Online purchase.
Appointment booking.
Payment for appointment.
Registration for events and/or presentations.
Participation in competitions, draws or promotions.
Participation in web surveys or satisfaction surveys.
Adding products to “My favourites”.
Chat online.
Visit to store.
Processing of data in third party applications.
Notice of availability of product in our Online Store.
Social media interactions, including requesting permission to use your content and interactions for our Photoslurp promotion.
Providing us with pictures and information about your wedding via our website Real Brides’ photographs and wedding information page.

Each time we gather data from our Customers by any of the above channels a Customer account is created. This account covers all services of Pronovias and contains all information concerning the interaction of Pronovias with our customers. The creation of an account does not apply when the information has been gathered via social media or our website Real Brides photographs and wedding information.

Our website also provides spaces for requesting information on our business partners, and the possibility of job seekers entering staff selection processes both for offices and stores.

For these reasons we set out below the type of information we may gather at different times:

- - Personal and contact information.
    
    We collect, store and process all personal information and contact details that you provide to us when you register on the Website, when you visit a store or when you contact San Patrick for any reason (from making an appointment or signing up for an event to making a complaint or contacting customer service).
    
    The personal and contact details that we collect are those that the Website requests at any time in its registration forms or user profile, etc., such as, for example, full name, address, shipping address, contact telephone numbers, e-mail, wedding/event date, etc., or those that San Patrick may request in order to attend to and process any consultation or request that you make to us.
  - Information on your devices and the use you make of the Website.
    
    We gather, store and process information on the devices from which you access the Website (e.g. whether it is a mobile telephone or a pc, the operating system of the device you use to access the Website, your IP address, etc.) and on the Internet browser you use for this.
    
    We also gather, store and process information on the use you make of the Website such as, for example, how you have reached the Website, which levels or sections of the Website you visit, what processes you have initiated and in what phase you have abandoned them, which websites you browse when you leave the Website, etc.
    
    Generally, we obtain this information by using Cookies, and its being processed will depend on whether you have accepted these. Further information is available in the Cookies Policy
  - Information on your interaction with Pronovias and your preferences.
    
    For us it is very important to know our Customers as it is in this way we can improve offering you products and services increasingly in line with your needs and preferences, improve our services and update or alter the Website. You will find further information on the profiles we prepare, based on all of this information, in the following section.
    
    For this, and to process and handle any request or interaction you have with San Patrick, we gather, store and process all information on your likes and preferences you provide on interacting with us. For example we will keep relevant information in telephone contacts, on using the Website, on booking an appointment, filling in the registration form in the Website, your adding our products to “My favorites”, taking part in surveys in the website or satisfaction surveys, choosing a language of preference, using customer service or chat online, and any data you voluntarily provide on visiting any store and which you agree to being processed for the purposes indicated at the time.
    
    As a general rule, any fields to be filled in the data collection forms contained on the Website; answering the questions asked in the surveys or user profile, or any fields to be filled in the data collection forms included on the Website are voluntary. However, in certain cases there may be mandatory data (such as an address if you make a purchase, or an email if you agree to receive commercial communications by this means), in which case we will inform you accordingly. The fields included in the forms and marked with an asterisk (*) are absolutely necessary to attend your request, or to create your Client account, the inclusion of the other data being voluntary.
    
    We also collect information that you disclose and/or provide to us when you interact with San Patrick offline, for example, through customer service or when you visit any of our stores, contact us through customer service or send us electronic or postal communications. San Patrick may also treat the information you post or provide to us when interacting on those platforms, forums, social networks, applications or websites to which San Patrick is present (hereinafter referred to as "Forums and Social Networks"). In this regard, we inform you that, without prejudice to the respective policies and conditions of use and registration of these forums and social networks, by accepting to interact with San Patrick through these channels, you authorize us to treat the information you publish and / or provide with the compatible purposes indicated in each case, such as managing a complaint, as well as processing any query or request made.
    
    Likewise in cases in which it is possible for the Customer to register or access the Website by way of a user account in a Forum or Social network, by using this option you authorise San Patrick to gather and process information accessible in the user account of the Forum or Social network. These options are already configured by the Forums and Social Networks themselves and are offered as a service both to their users and to third parties to facilitate registration or access without the user having to enter his or her data or credentials. The data is transferred from the Forum or Social Network for the purposes referred to at the time and in accordance with the rules applicable in the Forum or Social Network, and respecting at all times the configuration the user has determined in them. We will keep you duly informed of the information we gather from Forums and Social Networks at the time of the request for data.
  - Location
    In some cases we may need to know your location when you use the Website, for example to book an appointment for you at your nearest store. Where San Patrick wishes to know your location we will ask for your consent in advance, particularly if you have not activated the tracking function in the device from which you access the Website.
  - Contact, payment and billing information.
    
    In the event that you contract the appointment service in a country where San Patrick does not offer this service free of charge, San Patrick may collect and process information and personal data related to the payment method you choose, bank details, contact details, billing details, etc.

- - Images and social media profile information

In an effort to engage with our customers, we are using a third party processor, Photoslurp, to alert us to images on social media platforms, such as Instagram, Facebook and Pinterest, where Pronovias is tagged or the word or hashtag “#Pronovias” is used. When we would like to use your image on our website or re-post it on one of our social media profiles, we will comment on your image and ask for your consent to do so and process your data as described in this privacy policy. If you consent, we may process the relevant image/content, as well as your name and social media username. You can find the terms and conditions for this here. Should there be other people in your image, we require that you ask them for consent in line with this policy and those terms before agreeing to our request. Please refer to section 7 below for more information on this.

- - ‘Real Brides’ photographs and wedding information

We have created a page on our website where our customers can upload photographs from their wedding and tell us the story behind their relationship and wedding by completing a number of fields and Pronovias may then choose to publish the photographs and information you provide us with. None of these fields are mandatory and no customers is in any way obliged to provide us with this information. Should you wish to, we will ask for your consent to process the data you have provided us with. If you provide us with any personal data that is related to someone else, we ask that you request permission and seek consent from them first. For example, your partner’s name or wedding photographer’s name. You can find the terms and conditions for this promotion here. Should there be other people in your image, we require that you ask them for consent in line with this policy and those terms before agreeing to our request. Please refer to section 7 below for more information on this.

You may withdraw your consent to the publication of your picture and processing of your information on your wedding at any time simply by sending an email to the privacy@pronovias.com email address, or by postal mail addressed to PRONOVIAS, Calle Om, 16, Polígono Industrial Mas Mateu, s/n, 08820 El Prat de Llobregat (Barcelona), attaching in either case a copy of your personal identity documentation or passport and indicating "Ref. Data Protection" as reference on the envelope (in case of opting for postal mail) or in the subject line (if you opt for email), stating that you wish to revoke your consent to the publication of your picture and processing of your information on your wedding.

3. PREPARATION OF PROFILES

As stated above, at San Patrick we prepare profiles of the Customers who interact with us, creating a user or customer account containing all of the information gathered using the various data gathering channels both physical and online. The profile may be complete or incomplete depending on the type of interaction. We prepare these profiles on the basis of our legitimate business interests, which include knowing our customers and improving our services on the basis of their preferences and needs.

We set out below the various profile options depending on your relationship with us and any options you have selected:

- - 3.1. Profile in store or customer service: We may ask you in our stores or by way of our telephone customer service to supply us with personal data, for reasons including maintaining a commercial relationship, providing personalised attention or handling bookings for appointments. For this we create a Customer file where we store all relevant information such as for example preferred styles of clothing, colours, whether you are interested in a wedding dress or a party dress, etc. This information helps us to adapt the service we provide and keep you informed of news or events in the stores you have visited (e.g. arrival of new collections or new colours, trunk shows or private sales, etc.), the store continuing direct mailing in addition to any information we send from San Patrick (e.g. by email if you have consented to this). And if you visit our stores we may send you satisfaction surveys both on the quality of the service received and on our products. This helps us to improve on a day-by-day basis. These satisfaction surveys may be sent electronically even if you have not agreed to receive commercial mailings, as it is not advertising, it is the best way we have of ensuring we have given you the best in-store service in line with the quality standards of the Pronovias Group, and we thus have a legitimate interest in processing your contact and mailing data for these purposes. If you think the service was inadequate we may contact you by telephone or any other means of mailing you have indicated to deal with any incident which may have occurred during your visit to the store.
  - 3.2 Online profile: The new technologies allow us to prepare much more precise profiles analysing not just the preferences you expressed in our stores but also the following: Information provided on booking an appointment, e.g. the date of an event, including your wedding; the type of environment in which the event or your wedding will be held; your preferences on the shape or neckline of the dress; your budget for the dress; Information provided at the time of creating a user account, e.g. identification or contact data or your address; Purchases you have made by way of our online store, by which we can deduce your style and preferences; Behaviour in the web site (content you access, type of dresses visited, favourite colours, how often you visit the website …), which helps us to understand what you like; Behaviour in relation to our newsletter (what type of content makes you click or open the newsletter; how often you open our communications…); Relevant information based on the dresses you include in the “My favorites” section (type of dress, colours, and other characteristics which help us to understand your preferences in our products). These profiles may be combined when you contact Pronovias either by physical channels (visiting a store or customer service) or online via the website, app, social networks, etc.
  - 3.3 Use of the information generated in user profiles: Any information we gather on our customers is used for various purposes which may be put in two main groups, (i) purposes relating to a personalised service adapted to our customers, and (ii) purely advertising purposes. As regards personalised service knowing your preferences means that all of our stores can anticipate your needs and hence offer added value in our services. For example knowing your dress preferences means staff can not just show you dresses which match those preferences (e.g. long or short party dresses, with a particular neckline or colour, etc.), if you have booked an appointment they can make a prior selection of all the dresses or products which might match, including available sizes and colours. If you have a coming event, particularly in the case of your wedding, knowing the date means we can see the dresses available for fittings and the availability of sizes and types of dress. The generating of these profiles also allows us to improve our advertising as we can personalise and adapt the content of our advertising to your interests, the type of advertising we send you or the regularity with which we send it. For example if we know of your interest in our new collections we will inform you each time they are presented and put on sale. And if you have shown an interest in our events, for example the presentation of new collections, we can invite you to them also taking into account your location and where the presentation is being held. All contacts can be made both electronically, as stated above, and by telephone, both directly from San Patrick by way of Customer Service and directly from the store, in order to inform you of the arrival of new dresses, confirm future visits or bookings or generally preserve our ties with you. Personalisation of the content means we can ensure we send information which will be of interest to you. For example if we know you have a preference for long dresses we will prioritise news or promotions of this type of dress. And depending on your interaction with us we can offer you special promotions, competitions or participation in events exclusively for customers. In the following section on Mailings you can obtain further information on how we send mailings, the channels used and the platforms we work with to improve our advertising capacity. All of the information contained in the Customer account, and therefore all information on your profile and preferences, is accessible by our stores, which use it to improve the personalised service at the store. All data is at all times the property of San Patrick, S.L.U., although the store, particularly in the case of franchises, may ask you for additional data for its own use during your visit to the store.

4. COMMERCIAL MAILINGS

At San Patrick we will process the data you supply us with in order to send you commercial mailings where we have obtained your prior consent for this. If you give your consent we will send you information, advertising, surveys, invitations to events or promotions concerning products or services relating to the activity of San Patrick. At the moment of data being gathered you may as a Customer decide whether or not you wish to receive this type of mailing from us, and you may always withdraw your consent at any time.

If you agree to us sending you commercial mailings electronically (email, SMS, instant messaging or social networks among others), you must bear in mind that all mailings sent by San Patrick may be adapted and personalised according to your interests, either on the basis of the products and services you have ordered or for example any data we can deduce or obtain from your browsing habits, interest in particular content or reaction to our mailings, as explained in the section above “Preparation of Profiles”.

This personalisation is partially automated in the sense that San Patrick determines the parameters of the personalisation but it is the technological platform which generates the Customer profile. As a general rule we do not send general mailings not segmented by way of this process as we think it is in the interests of both San Patrick and our Customers to send and receive information which is relevant, and because not segmenting would not alter the number of mailings received, only their content. In this regard if you do not wish to be segmented for advertising purposes we would ask you not to subscribe to San Patrick mailings or the Newsletter.

All newsletters and commercial mailings will be sent by SAN PATRICK, S.L.U., including on behalf of other companies of the PRONOVIAS Group, as the company in charge of the Group's advertising and communications.

The commercial mailings sent electronically referred to above may be sent by the following channels:

Mailings by email, SMS or MMS o direct messaging (whatsapp, telegram, Facebook Messenger, direct messages in forum or social network applications, etc):

If we have the relevant information (email, mobile telephone number, etc.) we can send you commercial mailings by these means. As a general rule the channel of communication will be just email, wherever possible, although some messages may be sent by another of the means indicated (e.g. the sending of reminders, events or surveys).

Commercial mailings in third party platforms (e.g. social networks):

Some third party platforms (i.e. websites, communities or applications, for example) allow other advertisers, such as San Patrick, to use the platforms to advertise directly to San Patrick customers who also have a user account in the platform.

For this the platform may require the advertiser (San Patrick) to prove the identity of its Customers, providing basic identification data such as for example an email address or a telephone number in an encrypted form protected by way of tools provided by the platform itself.

Once the identity of the Customer and the existence of a user account in the platform have been established San Patrick can create what is commonly known as a “personalised public” with those customers who have agreed to receive advertising in the platform, with San Patrick advertising appearing directly in the user profile.

For example in social networks this type of activity can be found in Facebook (Custom Audience), Twitter (Personalised audiences) or Google (Customer Match).

The purpose of this activity is essentially one of advertising and hence your data is only used if you have agreed to receive our mailings.

These third party platforms may also allow advertisers such as Pronovias to use their tools to identify users who, within their platform, have a “similar profile” to Pronovias customers.

The procedure for identifying and proving the identity of customers is the same as above.

For example in social networks this type of activity can be found in Facebook (Lookalike Audience), Twitter (Personalised audiences) or in Google (Similar Audiences).

In this case, as the data is not used directly for advertising to our Customers, being aimed at persons who are not customers but have a profile similar to our customers, we will use the basic data of all of our Customers (and not just those who have agreed to receive advertising) to identify potential customers in the platform. In this way the advertising will be sent only to those potential customers who have given their consent to the platform in question for the sending of advertising. This processing is carried out on the basis of our legitimate interest in expanding our customer base, but you may object to your data being processed for these purposes at any time.

As stated above these services only ask for basic identification data, i.e. we do not supply all of your personal data, or any preferences we are aware of, we merely provide an email account or telephone number which is shared in encrypted form and protected by tools provided by the platforms themselves, sufficient for the social network to identify you in its database.

Secure communication techniques are also used, including the encryption of data before uploading it, to ensure the confidentiality and security of the information.

Finally we do not obtain data about you directly from these third party platforms, i.e. we may obtain anonymous and statistical information but never precise information on your interests or whether you have seen a particular advertisement, unless you interact with us or the particular advertisement.

If you do not wish us to use your data for advertising purposes in third party platforms you may contact us at the email and postal addresses given below. If we are already using it in these platforms we will erase it in the following update of the data supplied.

You may withdraw your consent to the sending of electronic commercial mailings at any time simply by following the instructions given at the foot of all electronic mailings sent by Pronovias or by sending an email to the address privacy@pronovias.com or writing to Polígono Industrial Mas Mateu, s/n., 08820 El Prat de Llobregat (Barcelona) enclosing in both cases a copy of your identity document or passport and indicating “Ref. Data protection” on the envelope (if you are using post) or in the reference field (if you are using email) and stating that you wish to withdraw your consent to the sending of electronic commercial mailings.

5. WHAT INFORMATION DO WE SHARE WITH THIRD PARTIES?

Your data will not be assigned, sold, hired out or in any other way made available to any third party, except for service providers of San Patrick who provide certain services for us (for example the sending of the newsletter, marketing or customer service suppliers, data and database storage or handling, transport or logistics suppliers, Forums or Social Networks in which we advertise, etc.), but not for their own purposes. Our stores may also access the data but not use it without our consent or without following the instructions given by Pronovias.

Notwithstanding this, San Patrick informs you that if you acquire our products or order certain services by way of the Website (such as, for example, booking an appointment) it may be necessary to communicate all or part of your personal data to third parties in order to process the purchase or service, for example:

your personal and contact data, which it may be necessary to send to the store where you have made the booking in order for them to contact you and conform the appointment, and inform you of any incident in relation to the same;
your contact, address and delivery data, which it may be necessary to send to transport and messenger companies for them to be able to process the product purchases you make with us and deliver them to where you indicate; or
your personal data and/or method of payment data, which are processed directly by the secure payment services platform Adyen, which processes it in its own name to process the transactions you carry out with us. This may include exchange of information with other companies and organisations for protection against fraud and reduction of credit risk.

Notably, your details may be communicated or transferred to those stores with which you may be interested in maintaining any relationship (for example, attending events or arranging an appointment), and which may be managed by companies other than those of the Pronovias Group (see link), for example, in the case of franchises or wholesalers, which are managed by third parties. In any case you will have the basic information of these third parties in the form. These third parties will only process your details in order to manage your consultation, attendance at the event or management of your appointment, although they may request your consent for additional processing.

In accordance with current regulations San Patrick will only send the personal data of Customers which is strictly necessary, and the third parties receiving the same may only process your personal data to process the purchase of the product or service in question unless we expressly inform you of any additional processing.

In compliance with current data protection regulations, we inform you that it is possible that, in order to carry out some or all of the purposes mentioned in this General Privacy Policy, your details may be communicated by San Patrick to other affiliated companies of the Pronovias Group (or other companies that provide services to this group) for the purposes set out in this General Privacy Policy or those indicated in any Privacy Policy informed on the various forms and that, in some cases, this communication may involve the transfer of your personal details to countries outside the European Union (for example, the United States). Given that the laws of countries outside the European Union where your personal details may be transferred may not provide an adequate level of protection for your personal details, in such cases San Patrick, in compliance with current regulations, implements appropriate technical and contractual safeguards to ensure that your personal information is treated in accordance with legally established standards of security and confidentiality, which may include:

Standard clauses approved by the EU: These are contracts approved by the European regulator and which provide sufficient guarantees that the processing complies with the requirements laid down in the European Data Protection Regulation.
Third party certificates: For example, the Privacy Shield, a framework agreement between the EU and the United States which provides a standardised framework for data processing in accordance with the requirements of the European Data Protection Regulation.

Outside the cases specified above, San Patrick will not disclose, transfer, sell or rent personal information that you provide to us through the Website to third parties, except when disclosure is required by law, by court order, or by a competent authority, as well as when we must communicate the data essential for the logical reason of providing the service or is expressly requested by obtaining your prior express consent for communication to third parties.

6. DURATION OF PROCESSING AND PRESERVATION OF DATA

As a general rule we process the data for the time necessary for the maintenance of the appropriate commercial relation.

For example your Customer Account will be preserved for a period of 5 years from your last interaction in Pronovias or Pronovias Online, which includes use of our website, reading our electronic communications or visiting any of our stores. Any data we collect from you in connection with our Real Brides project, either through our website, social media and/or Photoslurp project or via Photoslurp, will be kept for a period of 5 years from the day of collection, unless you choose to withdraw your consent or unless we are otherwise required to keep it due to local legislation, to comply with any judicial orders or requests from authorities, or for the purposes of defending any legal claims.

If you have subscribed to our commercial mailings your personal data will be preserved until you cancel the subscription or you expressly request that your data not be used in third party platforms (being eliminated from the same), or we decide or ascertain by any means available in the technology of the time that our mailings do not interest you, for example because you do not browse the website or you do not open our emails.

We will inform you of the preservation time of your data in the various forms in which personal data is requested, without prejudice to your data being preserved for a longer period duly anonymised for statistical or market research purposes, wherever possible or blocked to comply with legal obligations (for example the Consumer Protection Act and commercial or tax regulations may oblige us to preserve certain data for a specific period of time).

7. YOUR OBLIGATIONS AS A CUSTOMER

On sending your data to San Patrick by any medium (by email, telephone, instant messaging applications, Forums and Social Networks or by way of any of the data gathering channels available in the Website), you undertake to San Patrick that the data you are supplying corresponds to your true identity and that the said data is updated, truthful, accurate and complete at the time at which you supply it. You are solely responsible for the truthfulness, accuracy and completeness of the personal data you supply and hence you must inform San Patrick as quickly as possible of any change or alteration of any personal data you have provided us with. Remember also that personal data is the property of each person, and it is thus totally prohibited to supply to San Patrick any third party data or information without their prior consent (for example, if you give the address of a relative as the address for the delivery of an order you must tell them you are passing their data to San Patrick, and that they can access this Policy in our website).

As a Customer you will be solely liable for any direct or indirect damage or loss caused to San Patrick and/or third parties as a result of breach on your part of the obligation to provide truthful, accurate, complete and updated information corresponding to your true identity.

If you register on the Website remember your password is secret, personal and non-transferable and that you as the Customer are solely responsible for maintaining its confidentiality and secrecy. For this reason San Patrick recommends you pay particular attention when entering your personal data, especially bank data, and that you do not share your registration code or password with third parties. Any damage or loss caused directly or indirectly to San Patrick or to third parties under your password and registration code will be solely your responsibility.

8. YOUR RIGHTS AS A CUSTOMER

As a User you have the right to access your information, to rectify it if the details are incorrect, to opt out of the processing of your details, to delete them, to limit the processing or to transfer your details. You may also withdraw any consent given at any time. Please note that if at the time of exercising any right this could prevent the provision of any outstanding service, such as sending the product to your home if you request that we delete your data.

To exercise your rights of access, correction, erasure, restriction or portability in relation to any data you have supplied to any company of the Pronovias Group [see link] you just have to contact San Patrick, which will centralise handling of the rights exercised in relation to the processing of your data, either by email at privacy@pronovias.com or by writing to Polígono Industrial Mas Mateu, s/n., 08820 El Prat de Llobregat (Barcelona) enclosing in both cases a copy of your identity card or passport and indicating “Ref. Data protection” as a reference on the envelope (if you use post) or the reference field (if you use email) and clearly explaining the right you wish to exercise and the data necessary for such exercise.

You can also make submissions to the Data Protection Committee of PRONOVIAS if you consider Pronovias or Pronovias Online has processed your data in breach of this General Privacy Policy and any other related regulations currently in force, by electronic communication to gdprcommittee@pronovias.com. You have the right to make a complaint to the relevant supervisory authority at any time; however, we ask that you write to us first so that we can try to address the issue and provide you with a resolution.

9. DATA SECURITY

The Website contains the appropriate safeguards and uses technology based on the industry standards to improve the security, integrity, confidentiality, availability, exhaustiveness, accuracy and protection of the personal data it has compiled, and has taken reasonable precautions to protect this information from possible loss or misuse. The rules on data protection and security of San Patrick are reviewed on a regular basis and improved where necessary, with reasonable measures being adopted to ensure that only authorised persons are able to access the information you supply.

Despite this, although at San Patrick we make an effort and use all means at our disposal to ensure the security, confidentiality, availability, inviolability and integrity of your data, San Patrick is not able absolutely to guarantee technical security as a medium like the Internet is not impregnable and malicious actions on the part of third parties may occur which are beyond the control of San Patrick.

In no case and under no circumstances will San Patrick be liable for damages or losses derived from causes not attributable to San Patrick such as, by way of example and in no way limited to, viruses, harmful components, malfunctioning of the browser, computer intrusions or attacks by third parties.

10. COOKIES POLICY

At San Patrick we make available to you all information on the cookies we use in the Website in our Cookies Policy.

11. ALTERATIONS OF GENERAL PRIVACY POLICY

This General Privacy Policy may change over time as a result of the following circumstances among others: (i) changes in the Website; (ii) modifications to the data processing carried out by San Patrick; (iii) changes to the purposes for which San Patrick compiles your personal data, for example, as a result of changes in San Patrick either at corporate level or at operating or business level; (iv) statutory or case law developments, or (v) the laying down of new criteria by the Spanish Data Protection Agency.

For this reason, San Patrick reserves the right unilaterally to alter this General Privacy Policy informing the User of such alteration clearly and sufficiently in advance. San Patrick recommends the User read carefully the General Privacy Policy in force at the time he or she accesses the Website or before registering, subscribing or purchasing any product. If any alteration of the General Privacy Policy significantly affects Users we will inform them sufficiently in advance of the application of the changes and, if necessary, ask for the appropriate consents.

12. CONTACTS

For any doubt, enquiry or information concerning this General Privacy Policy or for sending us any suggestion or claim you can contact San Patrick by sending an email to privacy@pronovias.com or by way of telephone customer service. Official claim forms are also available at the offices of San Patrick should you need them for any reason.