This Privacy policy shall apply to the processing of personal data by POLO CLUB EUROPE SL and collected by the following means:

- The website www.poloclub.com

- E-mail communications.

- WhatsApp communications.

- communications through social networks.

1. Responsible for the processing

POLO CLUB EUROPE, S.L. (POLO CLUB).
B-54512512
Ptda. Jubalcoi Polígono 1, Nº 90
03295 Elche (Alicante).
E-mail: rgpd@poloclub.com

2. What data we collect and what for

POLO CLUB will process the following data depending on how you interact with us on our website or what for:

PROCESSING	TYPE OF DATA			PURPOSE
WHEN YOU MAKE A PURCHASE	-The identifying data you provide to us (first and last name, address, telephone number, e-mail address). -Details about your account number or bank cards for completing your purchase.			-To manage the purchase and shipment of products.  -To manage orders and returns. -To inform you occasionally about news/promotions related to your previous purchases. -To send you surveys through Hubspot and other channels to find out your satisfaction with the purchase you have made.
	Legal ground: the execution of a contract or pre-contract to which the user is a party (Art. 6.1.b GDPR) and the legitimate interest for the delivery of occasional commercial communications and shopping experience surveys (Art. 6.1.f GDPR)
WHEN YOU REGISTER AS A CUSTOMER ON OUR WEBSITE	-The identifying data you provide to us (first and last name, address, telephone number, e-mail address). -Details about your account number or bank cards for completing your purchase. -Preferences.			-To manage your user profile. -To manage direct access to order status, order history, etc. -To notify you of changes to our service. -To notify you of new arrivals/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) and the legitimate interest for the delivery of commercial communications (Art. 6.1.f GDPR)
WHEN THE CUSTOMER IS A MEMBER OF THE LOYALTY PROGRAMME	-The customer’s personal details when registering. -Date of birth. -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 agreed discounts according to the Member’s category. -To send communications related to the Loyalty Programme.
	Legal grounds: To manage your membership to the Loyalty Programme, including the delivery of communications about the Loyalty Programme, points earned, discounts applied, etc., the processing of data will be necessary to execute a contract or pre-contract of which the user is a party (art. 6.1.b GDPR).
WHEN A MEMBER OF THE LOYALTY PROGRAMME INVITES A FRIEND TO PARTICIPATE	-Friend’s email address	-To send two communications to offer a discount for the next purchase at POLO CLUB.
	Legal ground: The data owner’s consent. (Art. 6.1.a) GDPR)
WHEN YOU CONTACT POLO CLUB	-The identifying information you provide to us in connection with your order, your user profile or any queries you make to us (e.g., availability of clothes).			-To assist you when you ask us questions -To exchange communications by email.
	Legal ground: The data owner’s consent. (Art. 6.1.a) GDPR)
WHEN YOU SEND US YOUR CV	-Your identifying details such as name, surname, ID, etc. -Contact details: address, telephone number, addresses (including postal and electronic), etc. -Data about your personal characteristics, such as: sex, 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 interested party (Article 6.1.b) GDPR).
WHEN YOU REQUEST US TO SEND YOU AVAILABILITY NOTICES	-The email you provide.		-To inform you of the availability of the products requested
	Legal grounds: The data owner’s consent (Art. 6.1.a) GDPR).
WHEN YOU REQUEST US TO SEND YOU NEWSLETTERS OR OF PUSH NOTIFICATIONS	-The e-mail you provide to us to send you communications about offers and products of your interest; in the case of the newsletter, POLO CLUB does not need to process any users’ personal data for sending push notifications.			-To keep you informed about POLO CLUB news and offers. -To notify you of changes to our service.
	Legal ground: The data owner’s consent (art.6.1.a) GDPR) or legitimate interest for sending the newsletter (art.6.1.f) GDPR) in case the user has registered as a customer on our website.
WHEN YOU NAVIGATE OUR WEB PAGE	-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 data owner’s consent. (Art. 6.1.a) GDPR)
WHEN YOU DEFER PAYMENT	-The identifying data you provide to us (first and last name, 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 customer.
	Legal ground: The execution of a contract or precontract to which the user is a party. (Art. 6.1.b GDPR)
WHEN YOU INCLUDE A SUGGESTION OR COMPLAINT IN THE WEB EXPERIENCE SPACE	-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 he/she is a real opinion. -We may contact those users who did not have a good experience at the email provided.
	Legal grounds: The data owner’s (Art. 6.1.a) GDPR)
WHEN YOU ENTER A GIVEAWAY OR CONTEST	-Identifying details (name, surname, gender, age). -Contact details (email, phone number). -Postal address for sending the prize. -Social media user.		-To manage the participation of users in the contest/giveaways set out in the Terms. -To inform the winner of the contest/giveaway. -To send or deliver in person the prize(s).
	Legal grounds: The data owner’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.
WHEN YOU MAKE A RETURN	-Identifying details (name, surname, age). -Contact details (email, phone number). -Shipping address. -Details about your account number or bank cards for the refund.		-To manage the return of the products purchased at Polo Club. -To send satisfaction surveys through Outvio.
	Legal ground: The execution of a contract or precontract to which the user is a party. (Art. 6.1.b) GDPR)

 
3. Recipients

POLO CLUB shall not share any information you provide to us unless authorised by you, there is a legal obligation 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 the site 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.

More information on Klarna and the flexible payments here.

RETURNS

In case you return a product, OUTVIO will handle this return. Therefore, you shall provide your email through 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 company responsible for processing your data, informs you that we do not intend to transfer your personal data to countries outside the European Union, although we cannot guarantee that certain specific storage and processing activities are not carried out by natural or legal persons outside the European Union.

However, if any processing activity is carried out by companies or individuals located in third countries, POLO CLUB will take all the necessary measures to ensure that your data is processed safely and in accordance with this Privacy Policy, and we will not transfer your personal data to an organization or country outside the European Union unless they are in countries with an adequate level of protection or sufficient guarantees are provided and enforceable rights and effective legal actions are granted to the data owner.

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 the 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.

Regarding push notifications, if you do not wish to receive them, you need to disable this option from the set-up 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 data of the queries you make to us through the customer service channels or any other query you make to us through the channels enabled on our website (for example, to be notified when a garment is available again), will be stored until the query has been solved, unless such data has to be incorporated into the customer’s purchasing record, in which case the storing periods related to the purchase will 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.

6. Your rights

You have following the 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 any case, the person concerned must prove their identity by providing a copy of their national ID, passport or other similar document.

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

For those cases in which legal basis 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 to the receipt of 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, through 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)

7. Security

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 organizational and technical measures to ensure the security of personal data and to prevent its alteration, loss, processing or unauthorized 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 unauthorized and unwillingly unanticipated or due to malicious attacks by third parties.

8. 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 any 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.

8.1. Children’s privacy

Our service is not for anyone under 18.

We do not intend 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.

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 sole responsibility of the users.

If we are aware that we have collected personal data of children under 18 without checking that consent was given or authorized 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.

8.2. 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 shall be informed of any amendments to this Privacy policy so that you are aware of such changes, and exercise your rights if you do not agree.

Latest version: January 2024