PRIVACY POLICY AND DATA PROTECTION 

INTRODUCTION

Browsing the INÊS FRANCO website and registering as a customer in the online store implies understanding and accepting the present Privacy Policy and Data Protection.

INÊS FRANCO maintains a constant concern for the defense of the privacy of personal data and a preventive action regarding the security of the site and the protection of data of its customers and visitors.

In order to reinforce the guarantees of confidentiality of personal data, new data protection measures have been implemented, both in terms of verifying the legitimacy of the use of the personal data processed, and in terms of guaranteeing compliance with the rights recognized to the holders of such data. In this context, and through the specialization of customer support channels, INÊS FRANCO aims to promote clearer and more objective communication of the purposes underlying the processing of personal data and transparency in the processing operations.

Thus, the information contained in this text aims to convey, in a clear and unequivocal manner, the content of the privacy and personal data protection policy that will be subject to processing in accordance with the provisions of the current General Data Protection Regulation (hereinafter GDPR) and as delimited by the content of the commercial relationship to be established between the data subject and INÊS FRANCO.

 

TYPES OF PERSONAL DATA COLLECTED

In general terms, personal data is collected in three situations directly resulting from INÊS FRANCO's activity:

 

USER REGISTRATION
Creation of the INÊS FRANCO customer account and purposes of data processing

For the purpose of creating the customer account, a personal area is provided where the customer must enter the necessary data for their identification as a customer. The completion of the first purchase will depend on the provision of additional personal data, essential for the processing of the order and its delivery.

The mandatory fields in the forms available for those registration phases are marked with an asterisk (*).

 INÊS FRANCO is committed to protecting the customer's data, and these will never be made available to third parties without the knowledge or consent of the owner, as legally required.

When processing the customer's order, it is possible that certain personal data (such as address and postal code) may be disclosed to third parties for the sole purpose of fraud prevention and detection, and always following an appeal for this purpose by the competent authorities.

Furthermore, when making a purchase on the website, data regarding the delivery address and payment details will also be requested, in order to ensure the most effective delivery and compliance with delivery times.

The provided data will be stored for the strictly necessary period, which usually corresponds to the lifespan of the customer account. For this reason, when the customer cancels the customer account, the personal data will be permanently deleted, except for the data necessary to fulfill legal obligations, which will be archived in a database specifically for this purpose and for the absolutely necessary time. If the customer wishes to place a new order on the website, they must proceed with a new initial registration, subject to the terms and conditions in force at the time.

We may also collect other information about the customer's experience on the website solely for the purpose of improving the service provided to the customer, which we will do after confirmation of knowledge and, when necessary, after the express consent of the data subject. The completion of the customer's registration will trigger a registration confirmation to the email address associated with the customer account.

Regarding the update of customer data, whenever the customer wishes to verify the data provided to INÊS FRANCO, they can do so in their personal area. The customer must keep the access data to their account secure, as any action or request made through their account will be their responsibility, provided that the customer's identity validation procedures described below are followed.

RWe recommend that the customer does not save their password in the browser, as another person with access to their computer may access their personal information. 

For what purpose are the collected data used?

Customer data is processed in the context of actions such as order processing, notifying the customer of any changes made to the website's features, conducting surveys, and evaluating interactions for statistical purposes.

We may also periodically send you information about products and services, campaigns, promotions, and special offers by email. If the customer does not wish to be contacted for these purposes, they can unsubscribe from the newsletter.

 

CLIENT CONTACT WITH INÊS FRANCO

Whenever the customer, on their own initiative, contacts INÊS FRANCO with the aim of obtaining information about products, the purchasing process, the status of their order, or to report any situation related to the website, INÊS FRANCO may need to collect additional personal data for various purposes that will be specifically communicated in the particular case, but which generally fall into the following situations:

1. Confirming the identity of the customer and the reason for contact. 
   To ensure that the contact is indeed being established by the data subject, INÊS FRANCO has implemented measures to reinforce the confirmation of the identity of the caller for cases where contact is made by telephone.

Therefore, from May 25, 2018, the operator will only proceed with the call after communicating, in clear and objective terms, the purpose and conditions of identity validation of the customer and obtaining the express confirmation from the customer of the intention to continue the contact under such conditions.

In this context, the operator will first request authorization from the customer to access the purchase history of the last 6 (six) months and then ask the customer to indicate one or more products purchased in previous orders.

Whenever communications are exchanged between the customer and the Customer Support service and once the situation that prompted the customer's contact with INÊS FRANCO is considered resolved, an email message will be sent to the customer confirming the update of the status of the complaint/request for information. The personal data included in the process associated with the initial contact will be retained for a period of 30 months, after which they will be permanently deleted. Also, for exclusively statistical purposes, if the customer consents, their opinion regarding the satisfaction level with the service provided will be recorded. This record will not involve the archiving of any personal data but only the level of evaluation through pseudonymization.

CLIENT CONTACT WITH INÊS FRANCO

In the context of processing a specific order, there may arise the need for INÊS FRANCO to contact the customer to:

i) Confirm or rectify any of the personal data necessary for the completion of the delivery process (e.g., delivery address). In these cases, the contact will be made to the mobile phone number listed in the customer's profile, and once the connection is established, the operator will proceed to confirm the identity of the caller following, if necessary, the procedure described in point 2.2.2./i) above.

ii) Inform the customer that a message has been sent to their message box in the customer account due to the stock shortage of one or more items in the respective order and that, as an alternative to the unavailability of the products, a refund of the paid amount or replacement with similar products may be arranged, as provided in point 1.4. of the General Sales Conditions.

COOKIES AND OTHER MARKETING TOOLS 

COOKIE CLASSIFICATION AND DESCRIPTION

Regarding the type:

Essential – Allow navigation on the site and the use of its features. Without these cookies, requests cannot be processed.

Functionality or Performance – Collect information about how the user uses the site to improve its functionality. They allow to identify areas of greater interest for the customer, measuring the effectiveness of promotional campaigns. In this way, INÊS FRANCO can understand which products and promotions best suit the interests and needs of the customer through: the preparation of statistics based on the non-individualized behavior of the customer and the consequent use of the site; measuring the effectiveness of advertising campaigns; the introduction of improvements in navigation, etc., for the sole purpose of improving the performance and responsiveness of the site. For this reason, performance cookies provided by authorized third parties are also used within the limits of the purposes indicated here.

Analytics – Used anonymously for statistical purposes and to improve the functioning of the site, without ever collecting personal information. They allow highlighting items that may be of interest to customers or visitors, monitoring the site's performance, determining the most effective method of linking between pages, or even the reason why some pages are receiving error messages.

Regarding validity:

Permanent – Stored on the customer's computer or device between browser sessions to maintain settings or preferences and to improve the use of the site on the next visit. Some of these cookies are provided by authorized third parties and are limited to the following purposes: presenting campaigns and products that may be of interest to the customer; retargeting (advertising INÊS FRANCO products on partner websites or social networks without storing personal data or user profiles, so it does not imply the transmission of any personal data to third parties because the advertising is completely anonymous).

Session – Limited to each of the sessions initiated by the user, so they expire whenever a session in the browser is terminated. They may aim to indicate products previously placed in the shopping cart, identify problems, and ensure a better browsing experience. Some session cookies may also ensure enhanced security.

 

ACTIVATE AND DEACTIVATE COOKIES AND SIMILAR TECHNOLOGIES

Newsletters and other communications may, for statistical purposes, contain information that allows to know if they are opened and check clicks through links within them. However, customers are always given the option to unsubscribe from the newsletter or email communication through the specific option mentioned therein.

In addition, in the Help menu of the browser used, the customer can manage the use of cookies and other similar technologies. As indicated in the message visible at the top of this page, access to the INÊS FRANCO online store presupposes the use of cookies, and deactivating them may affect browsing on the site.

 

LIMITATION OF PURPOSES, ACCESS, AND STORAGE

INÊS FRANCO undertakes to use the personal data of its customers and visitors for purposes strictly necessary for the pursuit of its activity, within the limitations resulting from its scope or the extent of the consent expressly granted by the respective owner. This also means that data will not be transmitted to any third party without the knowledge and/or authorization of the same in cases where INÊS FRANCO is legally obligated to do so.

In this sense, INÊS FRANCO also ensures that access to such data by its employees is only done to the extent necessary for the execution of the action in question, being identified and tracked according to the functions and tasks assigned to them within the contractual relationship that binds them.

 

RIGHTS OF DATA SUBJECTS 

RIGHT TO INFORMATION AND ACCESS TO PERSONAL DATA
At any time, the customer can request information about the stored personal data, including the category of personal data concerned, the origin and recipient(s) of such data, the duration of the retention period, the underlying purposes, as well as the identification of the data controller, the data protection officer, and their respective contacts.

In the event of manifestly unfounded or excessive exercise of the right to information, INÊS FRANCO may make the obligation to respond subject to the payment of an appropriate fee. This amount must be settled within five working days from the receipt of the payment instructions, which will be sent by written message to the email address provided by the data subject and/or by SMS to the mobile contact registered in their customer account or indicated in the request for the provision of the relevant information. 

RIGHT TO RECTIFICATION AND RIGHT TO ERASURE OF PERSONAL DATA
If you wish to exercise your right to rectify data, you must send your request, identifying the data to be modified and the new statement thereof, by email to loha@inesfranco.com or by registered letter sent to the data controller: Inês Franco, Rua Rodrigues de Daria, Ed.I, 1st Floor, Room 1.01F 1300-501 Lisbon, Portugal. The same procedure should be followed if you wish to exercise your right to erase personal data. In both cases, the customer will receive confirmation, through the same channel used, that their request has been responded to as requested.

 

RIGHT TO OBJECT AND WITHDRAW PRIOR CONSENT
In support of the principle of transparency in the processing of personal data and communication with the customer, INÊS FRANCO allows the customer to modify the data processing permissions granted for each of the specified purposes at any time.

CHANGES TO THE PRIVACY POLICY AND CONTACTS 

Any changes made to this Privacy and Data Protection Policy will be published on the INÊS FRANCO website, with all previous versions available here.

For the purposes of the GDPR, INÊS FRANCO UNIPESSOAL LDA, with tax identification number 509713149, headquartered at Rua Rodrigues de Faria, EdI, 1st Floor, Room 1.17, 1300-501 Lisbon, Portugal, is the Data Controller.

Any irregularities, instances of non-compliance, and any security restrictions regarding the processing of personal data should be promptly reported to the Data Protection Officer of INÊS FRANCO by sending an email to: loja@inesfranco.com.