PRIVACY POLICY

Version 20 of April 2020

It is important you read this General Privacy Policy carefully before browsing the website www.pronovias.com or downloading and using the Pronovias mobile application. Pronovias is a company committed to the privacy of its users and customers and for this reason provides this General Privacy Policy. It contains information on the personal data we gather from users, the way in which we process this data, the purposes of the processing, 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 Pronovias 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.

1. PRONOVIAS AND THE USER OR CUSTOMER

Personal data supplied by the User or Customer will be processed by:

The company San Patrick, S.L.U. (hereinafter “Pronovias”), 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 www.pronovias.com (hereinafter the “Website”). Hence Pronovias is the controller of the Website.

The company Pronovias Online, S.L.U. (hereainfter “Pronovias Online”) incorporated in accordance with Spanish law, with offices at Calle Om 16, Polígono Industrial Manso Mateu, s/n., 08820 El Prat de Llobregat (Barcelona) and holder of Tax Identification Code number B-66875535 is the company responsible for the activity of purchase and sale of Pronovias Products by way of the SHOP ONLINE section of the Website. Therefore Pronovias Online is the company responsible for online sale of Pronovias products available in the SHOP ONLINE section of the Website. We inform you that the online store of Pronovias products is only available in the following countries and territories: Spain (only mainland and Balearic Islands), France (continental, except Overseas Departments), United Kingdom (except the Isle of Man and the Channel Islands), Italy (except San Marino, Liviano, Campione d´Italia and the waters of Lake Lugano), Portugal (with the exception of the autonomous regions of Madeira and Azores), Germany, Belgium and Poland.

Pronovias and Pronovias Online as data controllers  form part of the international corporate group Pronovias, which includes all companies affiliated under the “Pronovias” brand, and which may be consulted at any time in Pronovias Group companies. 

And as will be set out in the course of this General Privacy Policy, some of our Pronovias 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 Pronovias 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 Conditions of use, the General Conditions of Purchase and the Cookies Policy, and any Specific Privacy Policies included in the data gathering forms, the set of rules governing use of the Website and the relation between Pronovias and the Customer and the online purchase of Pronovias products.

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 PRONOVIAS GATHER FROM USERS AND PROCESS?

Pronovias 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.  
• 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 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 gather, store and process all personal information and contact details you supply us with when you log on to the Website, when you visit a Pronovias store or when you contact Pronovias for any reason (asking for an appointment, registering for an event or even making a claim, contacting customer service or contacting us by way of chat online).
  
  The personal and contact data we gather is that requested in the various contact, registration or user profile forms, etc. such as, for example, full name, address, address for deliveries, telephone numbers, email, date of event, etc. or any data Pronovias requests in order to attend to and process any consultation or request you make of 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 Pronovias, 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 favourites”, 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 Pronovias store and which you agree to being processed for the purposes indicated at the time.
    
    As a general rule the fields to be completed in the data gathering forms contained in the Website; answering the questions in any surveys you take part in; or completing your Customer profile, are voluntary. However in some cases there may be compulsory data (for example, an address if you make a purchase, or an email address if you agree to receive commercial mailings in this way) in which case you will be duly informed. Fields included in the forms and marked with an asterisk (*) are strictly necessary for dealing with your order or creating your Customer account, the inclusion of the other data being voluntary.
    
    We also gather information which you publish and /or supply when you interact with Pronovias outside the Website, for example in the blog or when you visit one of our stores, when you contact us by way of Telephone Customer Service or send us an email or letter. We may also process the information you publish or provide when you interact with platforms, forums, social networks, applications or websites in which Pronovias has a presence (hereinafter “Forums and Social networks”). In this respect we inform you that, without prejudice to the respective policies and conditions of use and registration of these Forums and Social networks, when you interact with Pronovias using these channels you authorise us to process the information you publish and/or provide for the compatible purposes indicated in each case, such as processing a claim or handling an enquiry or request.
    
    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 Pronovias 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 Pronovias store. Where Pronovias 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.
    
    If you book an appointment in a country in which Pronovias does not offer this service free of charge, Pronovias will gather and process the information and personal data related to the method of payment you choose, bank details (gathered directly from the secure payment services platform Adyen NV, hereinafter “Adyen”. More information is available at https://www.adyen.com, contact details, billing information, 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 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. Please refer to section 7 below for more information on this. You can find the terms and conditions for this promotion here. 

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. 

When you acquire any of our products by way of the SHOP ONLINE section of the Website, Pronovias Online may gather the following information:

• Contact, purchase, delivery and billing information.
  
  When you buy any of our products in the SHOP ONLINE section of the Website we gather and process information and personal data relating to the methods of payment you choose, always by way of the secure payment services platform Adyen NV (you can obtain more information at https://www.adyen.com), method of delivery chosen, products acquired, contact details, delivery details, billing information, etc.
  
  Pronovias will not gather or process the payment data entered, including the full number of your credit card, although some data will be kept as evidence of the transaction, in accordance with the regulations on payment services or banks (for example, we may preserve part of the number of the card, but never the full number or the CSC).
• Information on your interaction with Pronovias Online and your preferences.
  
  In order to process the purchase and improve and offer our Users products in line with their needs and preferences in an increasingly personalised way, we gather, store and process all information you supply to us on acquiring our products by way of the SHOP ONLINE section of the Website.
  
  We gather information on your preferences by way of the registration form of the purchase process when you click on the types of article you are interested in, when you choose a preferred method of delivery or payment, when you select a preferred language, when you select the Pronovias products you purchase online, etc.
  
  This information is stored in the Customer account controlled by San Patrick, S.L.U..

At Pronovias we are always trying to improve our services, and hence the personal data and information we ask for may vary over time. We confirm however that the personal data on Customers that we compile will be stored and processed by Pronovias and Pronovias Online respectively and will be used solely for the purposes referred to in this General Privacy Policy and specifically in the Privacy Policy made available to the user in each of the forms.

• Information on your career and CV.
  
  We gather, store and process all personal information, academic, professional and curriculum vitae information and contact data you provide us with when you apply for a job or present yourself as a candidate for any position or vacancy published on the Website by way of the online forms available in the WORK WITH US section of the Website.
  
  You must not send Pronovias any curriculum vitae information or job application by any means other than the online forms available in the WORK WITH US section of the Website. Any curriculum vitae information or job application received by Pronovias by any means other than the online forms available in the WORK WITH US section of the Website will be automatically erased by Pronovias.
  
  The personal, academic, professional, curriculum vitae and contact data we gather is that which you provide us with by way of the online forms available in the WORK WITH US section, such as, for example, your CV, previous job experience, training and academic data, preferred working times, and any information we obtain from you in interviews (in person, by telephone or any other means), or by way of any tests we ask you to take.
• Information on business partners.
  
  Our website contains various spaces for communication for our business partners, i.e. franchisees, agents or associates of any other kind. If these channels gather data they will include their own privacy policy.

3. PREPARATION OF PROFILES

As stated above at Pronovias 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 Pronovias (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 favourites” 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 Pronovias 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 advertsing 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 Pronovias 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 Pronovias 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.