Privacy policy

1.  Object

The is purpose of this Privacy Policy to inform people (hereinafter, users or interested parties) who visit our website (hereinafter, website, website or the website) about the way in which we collect, process and protect the personal data that you decide to provide us with by any means (forms, e-mails, telephone, contracts, etc.) and, after reading , itfreely decide whether you wish us to process it. Additionally, it will serve to expand on the information that we have previously provided to the interested parties in the informative clauses provided in the processes for collecting their personal data.

Furthermore, 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 RGPD) and with Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights (hereinafter LOPDGDD).

2.  Who is the controller of your personal ?data

Entity:  BERWICK 1707, S.L.

VAT NUMBER:  B86491073

Postal :address  C/ Hermosilla, 11 bajo, 28001 Madrid (Madrid) Spain

Telephone:  91 283 478

E-mail:  info@berwickshoes.com Company :object  Retail sale of footwear Website:  https://berwickshoes.com/

Registration :data  Madrid Mercantile Register Volume 30078 , Folio 91, Section 8, Page M 541429

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

In order to carry out our business activities, it is essential to process personal data, the collection of which may be carried out by digital means, by means of paper documents or as a result of face-to-face or telephone conversations, and .in any of these cases the data will be processed in a fair, lawful and transparent manner

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

• Identification data: name and surname, ID card or equivalent , documentimage, voice and
• Contact details: telephone, email, postal
• Access data: username and
• Commercial data: estimates, purchase , conditionsmanagement and history of services and/or purchases, results of contacts (telephone, email, messaging and other communication channels).
• Accounting : datacontrol of income and expenditure, .invoicing data
• Bank details bank :accounts and bank .cards
• Curricular data: academic , dataprofessional , experiencepersonal ,
• Transaction of goods and services: transfers and direct , amounts and
• Browsing data: analysis of time spent on our website, pages visited, demographic data (e.g. age, gender, language).

We 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 ask for your prior express consent.

Consequently, the data requested will be adequate, relevant, limited to those strictly essential and necessary, processed only by personnel and/or collaborators authorised by our entity, who will have signed a confidentiality commitment and undertake to comply with the necessary security standards that guarantee the confidentiality, integrity and availability of data processed and other legal requirements established in the RGPD. Therefore, they will be treated within the law.

The data to be processed are provided by the interested party or their legal , representativealthough it may be the case that we delegate some functions to certain collaborators and they are responsible for collecting your data, but they will always be processed with your prior express consent.

In the event that a data data subject does not provide the we request or provides incomplete or incorrect , it datawill not be possible to fulfil and maintain the relationship with the data subject.

The categories of data that we may process about an individual will depend on the relationship that the individual has with our organisation, as shown below:

3.1.  Clients:

Data an ofidentifying, contact, access, commercial, accounting, banking, transaction of goods and services, financial , and may only be collected if the customer provides them to us at the time of purchase of goods, when requesting measures nature will be processedpre- contractual or during the maintenance of the commercial relationship, either personally, by telephone, e-mail or through the forms provided on our website, online chat, instant messaging, etc.

3.2.  Information :seekers

Whether the information requested is in person, by telephone 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, business, commercial, accounting, banking, transaction of goods and services and financial . data will be processedThese data may be processed during all stages of the business relationship and only if the supplier provides them in order to start the business .relationship

3.4.  Job :seekers

For this category of interested parties, curricular, identification, contact and other data related to their professional or personal , which will be provided by the applicant themselves characteristics will be processedwhen they send us their application by any means (e.g. in person, by e-mail, web forms), they may also be collected in staff selection interviews (in person or online), and the job application may be even sent to us by a collaborator to whom we have delegated certain functions.

interested on a voluntary basis.

3.5.  Complainants:

We will process identification , datacontact data and personal information of our own or of third parties that the claimant .sends us

3.6.  Web users:

When visiting our website and only if expressly authorized by the user, analytical data (e.g. time of visit or pages may be collectedviewed) including demographic data (e.g. gender, age, country or language) . For more information visit our Cookie Policy.

3.7.  More information for those interested:

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

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

4.  What will your data ?be processed for

In general, the purpose of the processing of personal data carried out by our entity is the fulfilment and maintenance of the relationship with the different groups of people with whom we have contact.

Depending on this relationship, your data will be processed for different purposes, which, by way of example but not limitation, are detailed below:

4.1.  Clients:

Your personal data will be processed to identify you, manage access to our online shop as a registered customer, fulfil and maintain the pre-contractual and contractual relationship including the sending of commercial communications by different means, answer queries, carry out quality controls and commercial statistics, for the sale and delivery of goods, for accounting and managementinvoicing , the transaction of goods and services, collection management, incident management, complaints and the exercise of rights, as well as to

or for such other purposes as we may be required to fulfil that relationship, to comply with the laws to which we are subject or pursue our legitimate interests.

4.2.  Information :seekers

We will process your personal data to deal with requests for information of any kind that you wish to send us, to identify you, to send or deliver quotations and information about the goods and/or services of interest to you, including in our reply (verbal or written) the commercial information related to your request. We will also make follow-up contacts, by different means, to know the decisions taken with respect to the commercial proposals that we have sent you.

4.3.  Job :seekers

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

4.4.  Suppliers:

Your personal data will be processed for the purpose of maintaining the pre-contractual and contractual relationship, fulfilling the commercial relationship whether for the request of quotations, for the purchase of goods or contracting of services, for making enquiries and identifying you, for accounting management and the transaction of goods and services, .as well as for other purposes necessary to fulfil the said relationship, our legal obligations and legitimate interests

4.5.  Complainants:

Personal data will be processed in order to identify you, to deal with your complaint and to contact you about the status of your complaint, and to comply with our legal obligations and legitimate interests.

4.6.  Web users:

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

4.7.  More information for those interested:

The information legally established will be made available to the interested parties, the corresponding informative clauses included in the different means of data collection (e.g. forms, locutions, contracts, etc.) so that they can freely and decide expressly whether they want the personal data requested to be processed by our entity, in the same sense, this information will be recalled in the different documents or communications that we share with the interested parties (e.g. badges, invoices, legal notices, etc.).

In the event that the data data subject does not provide the we request or provides incomplete or erroneous , datamay not be able to respond to your request for information or to deal with your request.

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

The purposes for which personal data are processed will be duly identified in the corresponding processing owned by our entity.

5.  Why do we process your data (legitimation)?

The processing of your personal data by our company is carried out on one or more of the following legitimate bases:

1. When you give us your express, free, informed and unequivocal consent, after being informed at the time of collecting your data and more broadly with this privacy , policythat after reading it and if you agree, you can voluntarily authorise us to your data for one or more purposes, by ticking the boxes provided for this purpose on our web forms, by your verbal consent (voice recording will be required) or by signing the informative clauses that we provide you with at any given time when requesting your personal
2. For the performance of a contract to which you are a party or for which you have requested to us take measurespre-contractual .
3. Where the processing is necessary for compliance with a legal obligation applicable to
4. When the processing is necessary for the fulfilment of legitimate interests pursued by us or by a third party, provided that such interests are not overridden by the interests or fundamental rights and freedoms of the data subject. In this regard, we inform that our entity has carried out an analysis weighing our legitimate interests with the rights and freedoms of the data subject, always respecting his or her fundamental rights.

In the event that the user is under 14 years of age, it will be necessary to have the consent of the parents, guardians or representativelegal , to process their data. The user is solely responsible for the veracity of the data he/she sends us.

6.  Data retention

The personal data provided will be kept for as long as we maintain the relationship with the data subject and for the time necessary to fulfil the purpose for which the data were collected.

At the end of this relationship, we will keep them blocked in cases where it is necessary to retain them until the of limitations expires statutefor the sole purpose of claims or legal , actionas well as to comply with our legal , obligationsfor example:

7.  Profiling

We do not profile or make automated decisions using your personal data, but if we do, we will inform you and ask for your prior permission to do so.

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

8.  Transfer of data

As a general rule, our company does not pass on personal data to third parties without prior consent, although it may be passed on to other companies in our group of companies for the purpose of centralised management of services. However, it will be necessary to transfer data in the following cases:

In the case of our customers or suppliers, your personal data may be transferred to third parties by legal obligation (e.g. Tax ), Agencyor in those cases and entities necessary to provide our services or pay invoices (e.g. Banks) or in the case of delivery of goods, your data may be transferred to transport companies collaborating with our company. T

Likewise, the personal data of customers or suppliers may be processed by third parties to whom we delegate some of our obligations (e.g. accountants) and all of them have committed themselves by means of a data processor contract to comply with the same security measures implemented by our entity, as well as to submit to the duty of secrecy and confidentiality regarding the personal data processed, among other obligations in the field of personal data protection.

In the case of job applicants, your data will not be passed on to third parties, unless we are legally obliged to do so. They may, however, be passed on to other companies in our group of companies for the purpose of centralised service management.

With respect to those requesting information or users of our website, their data will not be transferred to third parties, except in the cases set out above and informed at all times of their 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 the Judges, Courts, the Public Prosecutor's Office and/or to the competent in the event of possible claims when we are obliged to do so.Public Administrations

9.  International transfer of data

In the case of transfers to third parties located in countries outside the European Economic Area, we will inform and request the prior express consent of the persons concerned.

10.  Security measures

Our company has implemented all the necessary technical and organisational measures to protect the personal data processed, preventing their loss, theft or unauthorised use.

These measures have been created on the basis of the type of data processed and the purposes for which it is processed. They are regularly verified in our internal controls of compliance with personal data protection regulations and by means of 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 us at any time and ask us to exercise your personal data protection rights.

We explain what these rights are:

11.1.  Right of Access:

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

• Whether or not we are processing your personal .data
• The purposes of the processing, as well asthe categories of personal data to be
• The origin of your data, if not provided by
• The recipients or categories of recipients to whom my personal , data have been or will be disclosedincluding, where applicable, recipients in third parties or international organisations.
• Information on appropriate safeguards concerning the transfer of my data to a third country or to an international , where organisation
• The expected retention , periodor if this is not possible, the criteria for determining this
• If there are automated decisions, including profiling, meaningful information on the logic applied, as well the significance and intended consequences of such processing.
• A copy of your personal data which are subject to

11.2.  Right of rectification:

Ask us to rectify your personal data if it is inaccurate, andto complete it if it is incomplete.

11.3.  Right of Opposition:

You can object tothe processing your data if it is incorrect or no longer necessary.

In the event that you act in the capacity of a respondent or person concerned by a complaint under Law 2/2023, you may not exercise your right of objection, as it is presumed (upon proof to the contrary) that there are grounds that legitimise the processing of your datapersonal , in accordance with the provisions of article 31.4 of the Law.

11.4.  Right of Suppression:

Ask us to delete , your datafor any of these reasons:

• Your data are no longer necessary for the purposes for which they were collected or
• You have not consented to the processing of your
• Where he has exercised his rightto
• When the data have been processed

• When the data must be deleted in order to comply with a legal .obligation

11.5.  Right to restriction of processing:

You may ask us to exercise this rightin one or more of the following situations:

• Where you contest the accuracy of your data, fora period of time that allows to the data controller verify the accuracy of the
• Where the processing is unlawful and you object to the erasure of your data and request instead the restriction of their
• Where the data are no longer required for the purposes of processing, but the data subject needs them for purpose of themaking, exercising or defending claims.
• Where you have objected to the processing pursuant to Article 21(1), while it is being verified whether the legitimate grounds of the controller outweigh those of the data subject.

11.6.  Right of Portability:

This refers to the rightto obtain data relating to you, in a structured, commonly used and machine-readable , formatand to transmit it to another controller for further processing.

11.7.  The right not to be subject to automated :decisions

The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects on him or her or similarly significantly affects him or her.

11.8.  How can you exercise your rights?

To exercise any of your rights, you must write to BERWICK 1707, S.L., either by post to the address: C/ Hermosilla, 11 bajo, 28001 Madrid or by email to:info@berwickshoes.com stating the rights you wish to exercise, accompanied by a copy of your ID card or equivalent document if you need to prove your identity. If you are acting on behalf another person, you must provide proof of representation.

If you have any suggestions or queries about the processing of your personal data, you can contact our data protection consultants BUSINESS ADAPTER, S.L.

Ronda Guglielmo Marconi, 11, 26, (ParkTechnology ) 46980 Paterna (Valencia). Contact  form for interested parties

We inform you that you have the right to make a complaint to the Spanish Data Protection Agency at: C/ Jorge Juan, , 628001 Madrid or at www.aepd.es.

12.  Commitment to Personal Data Protection

Scope of application

Our commitment to the protection of personal data is binding on all departments and employees of our company, as well as third parties acting on our behalf.

Object

We have established protocols for the processing of your personal , in dataaccordancewith the provisions of European and Spanish data protection regulations.

Principles

We will treat your data lawfully, fairly, , transparentlywith data , minimisationaccuracy, retention period limitation, completeness, confidentiality and active accountability.

Special category of data

Our entity prohibits the processing of personal data revealing racial , or ethnic originpolitical , opinionsreligious or philosophical , beliefstrade union , membershipthe processing of genetic or biometric , datadata relating to health or data relating sexual orientation, except in the legally authorised exceptions and with the prior consent of the data subject.

Rights of data subjects

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

Registration of Activities, Impact Assessment and Security Measures

We will keep a record of processing activities and analyse the purposes of processing, categories of data subjects and data, recipients, international , transfersretention , periodsetc., in order to assess the risks of processing and implement the necessary security measures to ensure the confidentiality, integrity and availability of personal data.

Likewise, for each processing activity, the need to draw up an Impact Assessment and determine whether there is an obligation to appoint a Data , establishingProtection Officer has been analysed, if necessary, that the person appointed to this post has sufficient knowledge and experience in accordance with the provisions of the regulations in force.

Control

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

13.  Updating this Policy

We reserve the rightto modify this policy without prior notice. We recommend that you therefore consult it each time you visit our website.

Text updated on 27 February 2025.