Privacy policy

1. Purpose

This Privacy Policy aims to inform individuals (hereinafter, users or data subjects) who visit our Website (hereinafter, website, site, or the web) about how we collect, process, and protect the personal data they choose to provide us by any means (forms, emails, phone, contracts, etc.) and after reading it, freely decide whether they want us to process it. Additionally, it will serve to expand the information previously provided to data subjects in the information clauses set out in the processes of collecting their personal data.

Likewise, this policy aims to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter GDPR) and Organic Law 3/2018, of 5 December, on Personal Data Protection and guarantee of digital rights (hereinafter, LOPDGDD).

2. Who is responsible for processing your personal data?

Entity:	BERWICK 1707, S.L.
Tax ID:	B86491073
Address postal:	C/ Hermosilla, 11 ground floor, 28001 Madrid (Madrid) Spain
Phone:	91 283 478
Email:	info@berwickshoes.com
Corporate purpose:	Retail sale of footwear
Website:	https://berwickshoes.com/
Registry data:	Madrid Mercantile Registry Volume 30078, Folio 91, Section 8, Sheet M 541429

3. What personal data will we process and how do we obtain it?

For the development of our business activity, it is essential to process personal data which can be collected by digital means, paper documents, or as a result of face-to-face or telephone conversations, and in all these cases the data will be processed fairly, lawfully, and transparently.

The categories of data that our entity will process about the data subjects are:

Identification data: name and surname, ID or equivalent document, image, voice, and signature.
Contact data: phone, email, postal address.
Access data: username and password.
Commercial data: budgets, purchasing conditions, management and history of services and/or purchases, outcome of contacts (phone, email, messaging, and other communication channels).
Accounting data: income and expense control, billing data.
Bank details: bank accounts and cards.
Data curricular: data academic, experience professional, characteristics personal, etc.
Transaction of goods and services: bank transfers and direct debits, amounts and concepts.
Data of navigation: analysis of the time spent on our website, pages visited, demographic data (e.g., age, gender, language).

Our entity will not collect special category data (e.g., health data, ethnic origin, political opinions, or religious beliefs), but if it is necessary to process them, we will inform you and request your prior and express consent.

Consequently, the requested data will be adequate, relevant, limited to what is strictly necessary, processed only by personnel and/or collaborators authorized by our entity, who will have signed a confidentiality agreement and commit to complying with the necessary security standards to guarantee the confidentiality, integrity, and availability of the processed data and other requirements legally established in the GDPR. Therefore, they will be processed legally.

The data to be processed is provided by the interested party themselves or their legal representative, although there may be cases where we delegate some functions to certain collaborators who are responsible for collecting their data, but it will always be processed with their prior and express consent.

If an interested party does not provide the requested data or provides incomplete or incorrect data, it will not be possible to fulfill and maintain the relationship with them.

The categories of data we may process about a person will depend on the relationship they have with our entity, as shown below:

3.1. Clients:

Identification, contact, access, commercial, accounting, banking, goods and services transaction, and financial data will be processed and may only be collected if the client provides it at the time of purchasing goods, requesting pre-contractual measures, or during the maintenance of the commercial relationship, whether in person, by phone, email, or through the forms available on our website, online chat, instant messaging, etc.

3.2. Information requesters:

Whether the requested information is in person, by phone, or in writing (e.g., email or web forms), we will request and/or process identification, contact, and commercial data.

3.3. Suppliers:

Identification, contact, commercial, accounting, banking, goods and services transaction, and financial data will be processed. This data may be processed throughout all stages of the commercial relationship and only if the supplier provides it to start the commercial relationship.

3.4. Job applicants:

For this category of interested parties, curricular, identifying, contact data, and others related to their professional or personal characteristics will be processed, which will be provided by the applicant themselves when submitting their application by any means (e.g., in person, email, web forms), they may also be collected during personnel selection interviews (in-person or remote), and we may even receive the job application through a collaborator to whom we have delegated certain functions.

interested party voluntarily.

3.5. Claimants:

They will be processed data of aidentifying, contact, and personal information of the claimant or third parties that the claimant sends us.

3.6. Users website:

When visiting our website and only if the user expressly authorizes it, analytical data (e.g., visit time or pages viewed) and even demographic data (e.g., gender, age, country, or language) may be collected. For more information, visit our Cookies Policy.

3.7. More information for data subjects:

The legally established information will be made available to the data subjects in the corresponding information clauses, included in the different data collection means, so that the interested person can freely and expressly decide whether they want their personal data to be processed by our entity.

All categories and types of personal data processed will be duly identified in the corresponding processing activities owned by our entity.

4. What will your data be processed for?

In general, the processing of personal data carried out by our entity aims to comply with and maintain the relationship with the different groups of people with whom we have contact.

Depending on this relationship, the processing of your data serves different purposes, which we detail below by way of example and not limitation:

4.1. Clients:

Your personal data will be processed to identify you, manage access to our online store as a registered customer, fulfill and maintain the pre-contractual and contractual relationship including sending commercial communications by various means, handle inquiries, perform quality controls and commercial statistics, for the sale and delivery of goods, for accounting and billing management, the transaction of goods and services, collection management, incident management, claims, and exercise of rights, as well as

as well as for other purposes we are obliged to fulfill in order to comply with this relationship, the laws to which we are subject, or to attend to our legitimate interests.

4.2. Information requesters:

We will process your personal data to respond to any information requests you may have, to identify you, to send or deliver quotes and information about goods and/or services of your interest, including commercial information related to your request in our response (verbal or written). We will also make follow-up contacts through various means to learn about decisions made regarding the commercial proposals we have sent you.

4.3. Job applicants:

Your data will be processed to include you in our selection processes and job pool, to identify you, as well as to contact and inform you about vacancies, coordinate interviews, and other matters related to your application.

4.4. Suppliers:

Your personal data will be processed to maintain the pre-contractual and contractual relationship, fulfill the commercial relationship whether for requesting quotes, purchasing goods, or contracting services, to make inquiries and identify you, for accounting management and the transaction of goods and services, as well as for other purposes necessary to fulfill this relationship, our legal obligations, and legitimate interests.

4.5. Claimants:

Personal data will be processed to identify you, manage your claim, and contact you regarding its status, as well as to comply with our legal obligations and legitimate interests.

4.6. Users website:

By accepting the installation of cookies when visiting our website, data may be processed for different purposes (e.g., visit analysis). For more information, please visit our Cookie Policy.

4.7. More information for data subjects:

The legally established information will be made available to the data subjects in the corresponding privacy clauses included in the different data collection methods (e.g., forms, recordings, contracts, etc.) so that you can freely and expressly decide whether you want the requested personal data to be processed by our entity. Likewise, this information will be reminded in the different documents or communications we share with the data subjects (e.g., badges, invoices, legal notices, etc.).

If the data subject does not provide the requested data or provides incomplete or incorrect data, we may not be able to respond to your information request or interact with you.

The data will not be further processed or used for purposes other than those accepted by the data subjects.

The purposes that motivate the processing of personal data will be duly identified in the corresponding processing activities owned by our entity.

5. Why do we process your data (legal basis)?

The processing of your personal data by our entity is carried out based on one or more of the following legal grounds:

When you give us your express, free, informed, and unequivocal consent, after being informed at the time of data collection and more extensively through this privacy policy, that after reading it and agreeing, you may voluntarily authorize us to process your data for one or more purposes by checking the boxes provided for this purpose in our web forms, by verbal consent (which will require voice recording), or by signing the information clauses we provide at each moment when requesting your personal data.
For the execution of a contract in which you are a party or have requested pre-contractual measures from us.
When processing is necessary to comply with a legal obligation applicable to our entity.
When processing is necessary to satisfy legitimate interests pursued by our entity or a third party, provided that such interests do not override the interests or fundamental rights and freedoms of the data subject. In this regard, we inform you that our entity has conducted an analysis balancing our legitimate interests with the rights and freedoms of the data subject, always respecting their fundamental rights.

If the user is under 14 years old, consent from parents, guardians, or legal representatives is required to process their data. The user is solely responsible for the truthfulness of the data they provide.

6. Data retention

The personal data provided will be kept while we maintain the relationship with the interested party and for the time necessary to fulfill the purpose for which the data was collected.

Once this relationship ends, we will keep them blocked in cases where it is necessary to retain them until the limitation of liabilities for the exclusive purpose of claims or legal actions, as well as to comply with our legal obligations, for example:

Interested parties	Sectorial scope	Legal base	Retention period
Clients Suppliers	Accounting	30.1 R.D. Code of Commerce	6 years from the last entry Clients Suppliers
	Tax	66 General Tax Law 58/2003	General term: 4 years In case of losses during the fiscal year: 10 years Invoices: 5 years Any person
	General	1964.2 of the Civil Code	5 years: Personal actions without a special limitation period prescribe after five years from when the obligation can be demanded. In ongoing obligations to do or not do, the period will start each time are breached.
People workers	Labor	Art. 21 of Royal Legislative Decree 5/2000 – Order Social	4 years: Job applicants
	Labor	Labor Relations Guide of the AEPD	1 year People workers
	Risk prevention work-related	4.3 of Royal Decree 5/2000 – Social Order	5 years Web users
	Use of cookies	Guide on the use of cookies by the AEPD	24 months maximum Information seekers
	Commercial Legal	20.1 a and d) Constitution Spanish	The shortest possible time or as indicated by law. Clients Suppliers Visitors Job applicants People workers
	Video surveillance	22.3 LOPDGDD – personal data protection	1 month Clients
	User information in internet service providers	Art. 5 of Law 25/2007 – retention of electronic communications data and public communications networks	12 months from the date the communication was made. The data to be retained are those established in Article 3 of the law. After consulting with operators, this period may be extended by regulation to a maximum of 2 years or a minimum of 6 months.

7. Profile creation

We do not create profiles nor make automated decisions using your personal data, but if we do, you will be informed and prior authorization will be requested.

Similarly, you have the right to object to this type of processing at any time by writing to our entity at: info@berwickshoes.com

8. Data sharing

As a general rule, our entity does not share personal data with third parties without prior consent, although it may be shared with other companies within our corporate group for centralized service management purposes. However, it will be necessary to share data in the following cases:

In the case of our clients or suppliers, their personal data may be shared with third parties due to legal obligations (e.g., Tax Agency), or in cases and with entities necessary to provide our services or pay invoices (e.g., banking institutions), or in the case of goods delivery, their data may be shared with transport companies collaborating with our entity.

Likewise, the personal data of clients or suppliers may be processed by third parties to whom we delegate some of our obligations (e.g., accounting advisors), and all of them have committed through a data processing agreement to comply with the same security measures implemented by our entity, as well as to adhere to the duty of secrecy and confidentiality regarding the personal data processed, among other obligations related to personal data protection.

In the case of job applicants, their data will not be shared with third parties, unless we are legally required to do so. However, it may be shared with other companies within our corporate group for centralized service management purposes.

Regarding information requesters or users of our website, their data will not be disclosed to third parties, except in the cases previously mentioned and informed at the time of collection and only with their express consent, unless our legitimate interest prevails or we are legally obliged to do so, in which case their consent will not be necessary.

In general terms, we may disclose your personal data to Judges, Courts, the Public Prosecutor's Office, and/or competent Public Administrations in the event of possible claims when we are obliged to do so.

9. International Data Transfer

In case of transfers to third-party entities located in countries outside the European Economic Area, we will inform and request the prior and express consent of the data subjects.

10. Security Measures

Our entity has implemented all necessary technical and organizational measures to protect the personal data processed, preventing loss, theft, or unauthorized use.

These measures have been created based on the type of data processed and the purposes motivating such processing. They are periodically verified in our internal compliance controls with personal data protection regulations and through external audits.

11. Your Rights

You, as the owner of your personal data and acting on your own behalf or through your representative, may contact our entity at any time and request to exercise your rights regarding personal data protection.

We explain what these rights are:

11.1. Right of Access:

You have the right to know and request from us at any time the following information:

Whether or not we are processing your personal data.
The purposes of the processing, as well as the categories of personal data processed.
The source of your data, if you did not provide it to us.
The recipients or categories of recipients to whom my personal data have been or will be disclosed, including, where applicable, recipients in third countries or international organizations.
Information about the appropriate safeguards regarding the transfer of my data to a third country or an international organization, if applicable.
The expected retention period, or if not possible, the criteria to determine this period.
If there are automated decisions, including profiling, significant information about the logic applied, as well as the importance and expected consequences of such processing.
Copy of your personal data that are subject to processing.

11.2. Right of Rectification:

Request from us the rectification of your personal data when these are inaccurate, as well as to complete them when they are incomplete.

11.3. Right of Objection:

You may object to our processing of your data when it is incorrect or no longer necessary for its processing.

In the case that you act as a defendant or person affected by a complaint under Law 2/2023, you may not exercise your right of objection, as it is presumed (unless proven otherwise) that there are grounds legitimizing the processing of your personal data, in accordance with the provisions of Article 31.4 of the Law.

11.4. Right of Erasure:

Request that your data be deleted for any of these reasons:

Your data is no longer necessary for the purposes for which it was collected or processed.
You have not given consent for the processing of your data.
When you have exercised the right of objection.
When the data has been processed unlawfully.
When the data must be deleted to comply with a legal obligation.

11.5. Right to Restriction of Processing:

You may request to exercise this right when one or more of these situations occur:

When you contest the accuracy of your data, during a period that allows the controller to verify the accuracy of it.
When the processing is unlawful and you object to the deletion of your data and instead request the restriction of its use.
When the data is no longer needed for the purposes of processing, but the data subject needs them for the formulation, exercise, or defense of claims.
When you have objected to processing under Article 21, paragraph 1, while it is verified whether the legitimate grounds of the controller override those of the data subject.

11.6. Right of Portability:

This refers to the right to obtain data related to you in a structured, commonly used, and machine-readable format, as well as to transmit it to another controller for further processing.

11.7. Right not to be subject to automated decisions:

Right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

11.8. How can you exercise your rights?

To exercise any of your rights, you must contact BERWICK 1707, S.L. in writing, either by postal mail to the address: C/ Hermosilla, 11 ground floor, 28001 Madrid or by email: info@berwickshoes.com stating the rights you wish to exercise.

If you wish to submit any suggestions or inquiries regarding the processing of your personal data, you can contact our data protection consultants:

BUSINESS ADAPTER, S.L.

Ronda Guglielmo Marconi, 11, 26, (Technology Park) 46980 Paterna (Valencia). Data Protection Officer Contact Form

We inform you that you have the right to file a complaint with the Spanish Data Protection Agency at: C/ Jorge Juan, 6, 28001 Madrid or at www.aepd.es.

12. Commitment to Personal Data Protection

Scope of Application

Our commitment to personal data protection will be mandatory for all departments and employees of our entity, as well as for any third parties acting on our behalf.

Purpose

We have established protocols for processing your personal data, in accordance with European and Spanish data protection regulations.

Principles

We will process your data lawfully, fairly, transparently, with data minimization, accuracy, limited retention period, integrity, confidentiality, and active accountability.

Special Category of Data

Our entity prohibits the processing of personal data revealing ethnic or racial origin, political opinions, religious or philosophical beliefs, trade union membership, processing of genetic or biometric data, health data, or data relating to sexual orientation, except in legally authorized exceptions and with the prior consent of the data subject.

Rights of Data Subjects

Our entity will attend to and respond to your requests to exercise your rights as quickly and diligently as possible.

Record of Activities, Impact Assessment, and Security Measures

Our entity will maintain a record of processing activities and will analyze the purposes of the processing, categories of data subjects and data, recipients, international transfers, retention periods, etc., to assess processing risks and implement the necessary security measures to guarantee the confidentiality, integrity, and availability of personal data.

Likewise, for each processing activity, the need to carry out an Impact Assessment and determine whether there is an obligation to appoint a Data Protection Officer has been analyzed, establishing, if necessary, that the person appointed for this position has sufficient knowledge and experience according to current regulations.

Control

We have external assistance advising us in this matter, monitoring all publications made by the competent control bodies and other European and Spanish entities related to data protection regulations, in order to comply with these regulations at all times.

13. Policy Update

Our entity reserves the right to modify this Policy without prior notice. Therefore, we recommend reviewing it each time you visit our website.

Text updated on February 27, 2025.