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PRIVACY POLICY

PRIVACY POLICY AND DATA PROTECTION

TRENT uses your data to provide an optimal service.

Data forms the basis for us to offer an excellent service. TRENT’s top priority is also to protect user data and use it only in the manner they expect from us. Our Data Protection Policy informs you about the processing of your personal data and your rights in relation to this processing according to the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016 (“GDPR”) and other current data protection laws. Respecting the provisions of current legislation, TRENT (hereinafter also the Web Portal) is committed to adopting the necessary technical and organizational measures, according to the appropriate security level for the collected data’s risk.

IDENTIFICATION

TRENT’s Privacy Policy

In accordance with current regulations, the data controller for the personal data provided during access, browsing, and use of the website www.trent.es (hereinafter, the “Portal” or the “Website”), as well as all data provided during your relationship with TRENT, will be processed by TRENT, a brand of LIM APP 710, SOCIEDAD LIMITADA, holder of Tax ID (NIF) B05385315, Trafalgar Street, No. 6, principal 2ª, 08010 Barcelona, Registered in the Mercantile Registry of Barcelona Sheet: 562731, Volume 47804, Folio 1. Email: info@trent.es; phone +34 649006756 (hereinafter, TRENT). Therefore, if you use the Portal, you agree to the applicable conditions of use that can also be consulted through this link.

BASIC INFORMATION ON TRENT’S DATA PROTECTION

Responsible:

TRENT, a brand of LIM APP 710, SOCIEDAD LIMITADA, holder of Tax ID (NIF) B05385315, Trafalgar Street, No. 6, principal 2ª, 08010 Barcelona, Registered in the Mercantile Registry of Barcelona Sheet: 562731, Volume 47804, Folio 1. Email: info@trent.es; phone +34 649006756

Main purposes:

  • Web browsing.
  • Client registration and management as a user. Responding to queries and orders.
  • Subscription to Commercial Communications.
  • Managing digital services offered by TRENT.
  • Compliance with TRENT’s legal obligations.

Legitimation:

  • Legitimate Interest.
  • Contract Execution.
  • User Consent.
  • Compliance with TRENT’s legal obligations.

Recipients:

  • National police agencies and other competent authorities and administrations.
  • Service providers and suppliers of TRENT.
  • TRENT’s collaborators for providing administration services, system support, and for conducting relevant reports among them.

Rights:

You have the rights of access, rectification, erasure, objection, and portability of data, and the right to object to processing at any time, for reasons related to your particular situation, in case the processing is based on legitimate interest.

Data Source:

The User and owner provide them, if they are also obtained regarding browsing behavior and sources accessible to the public in the case of business data.

If you have any doubts or requests related to the processing of your data, you can contact us at any time, in writing to TRENT at the following address: Trafalgar Street, No. 6, principal 2ª, 08010 Barcelona (hereinafter, TRENT) or by Email: info@trent.es

You can access TRENT’s Privacy Policy through this link.

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TRENT Privacy Policy

Identification

In compliance with current regulations, the data controller for the personal data provided during access, browsing, and use of the website www.trent.es (hereinafter, the “Portal” or “Website”), as well as all data provided during your relationship with TRENT, will be processed by TRENT, a brand of LIM APP 710, SOCIEDAD LIMITADA, holder of Tax ID (NIF) B05385315, Trafalgar Street, No. 6, principal 2ª, 08010 Barcelona, Registered in the Mercantile Registry of Barcelona Sheet: 562731, Volume 47804, Folio 1. Email: info@trent.es; phone +34 649006756 (hereinafter, TRENT). Therefore, by using the Portal, you agree to the applicable terms of use, which can also be consulted through this link.

In case of doubts or inquiries related to the processing of your data, you can contact us at any time, in writing to TRENT at the following address: Trafalgar Street, No. 6, principal 2ª, 08010 Barcelona (hereinafter, TRENT) or by Email: info@trent.es

Laws incorporated into this privacy policy

This privacy policy is adapted to the current Spanish and European regulations concerning the protection of personal data on the internet. Specifically, it complies with the following rules:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, regarding the protection of individuals concerning the processing of personal data and the free movement of such data (GDPR).
  • Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).
  • Royal Decree 1720/2007, of December 21, approving the Regulation for the development of Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).
  • Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSI-CE).

Registration of Personal Data: Data collection, purpose, and legitimization

In compliance with the GDPR and the LOPD-GDD, we inform you that the personal data collected by TRENT, through the forms extended on its pages, will be incorporated and processed in our file in order to facilitate, expedite, and fulfill the commitments established between TRENT and the User or the maintenance of the relationship established in the forms filled out by the user, or to address a request or query from the user. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is maintained that specifies, according to their purposes, the processing activities carried out and the other circumstances established in the GDPR.

When using TRENT’s website, the following data is automatically recorded through your device (computer, mobile phone, tablet, etc.) and temporarily stored as log files without your intervention:

  • IP address currently used by your device
  • Date and time of access
  • Name and URL of the file accessed
  • Type of browser and operating system of your device
  • Website / application from which the access was made (referral URL)
  • Name of the access provider.

The purpose of collecting the aforementioned data by TRENT is to:

  • Carry out internal solutions operations, data analysis, research, development, and service improvement, as well as for security control and system stability, with the legitimizing basis of TRENT’s legitimate interest; the basis legitimizing the processing is compliance with TRENT’s legal obligations.
  • Allow you to create an account on our Portal.
  • Manage your access to your account on the Portal.
  • Process and manage orders placed with TRENT or its partners within the framework of using our Portal.
  • Ensure the delivery of the products and services you request.
  • Ensure the security of online transactions, prevent fraud, payment incidents, and manage collections, particularly through the automated processing of your data.
  • Trace and manage product collection and withdrawal.
  • Provide a personalized shopping experience as close as possible to your tastes and preferences.
  • Perform statistical analyses to develop direction, measurement, and reporting tools with the aim of adapting and improving our commercial and marketing activities.

Subject to consent:

  • Send you information about special offers, news, and events through the communication channels you have selected.
  • Offer you a personalized interface or a customized presentation of our offers in our emails.
  • Retain your bank card data (excluding the CVV) to facilitate your future purchases.

We process your personal data collected when filling out the client registration form, during future commercial transactions, as well as during actions to update your data with the purpose of, in addition to the aforementioned purpose:

  • Management, maintenance, and administration of the subscribed contractual relationship, including, among other purposes, issuing access and user keys to register in our services and/or purchase products on the TRENT platform, as well as to purchase our products and, where applicable, to process the order and delivery of TRENT products correctly. The processing of your data for this purpose is based on Article 6.1.b) of the GDPR (contract execution).
  • Analyze and expand the contractual relationship with the User and client. Consequently, market studies and opinion surveys will be carried out via email, SMS, telephone, fax, or postal mail, as well as analysis and segmentation of profiles (for example, turnover, repeated purchases, or purchase dates) using TRENT’s own databases derived from the contractual relationship with you to improve it. The processing of your data for this purpose is based on Article 6.1.f) of the GDPR (legitimate interest).
  • If previously authorized, send you communications about products, services, advertising campaigns, and marketing of TRENT that may be of interest to you, as well as about products, services, or marketing campaigns of TRENT’s collaborating companies in the fashion product sector without this latter implying a transfer of your data to these companies. These commercial communications may be sent by postal mail or electronic means. The processing of your data for this purpose is based on Article 6.1 a) of the GDPR, express consent, which you can withdraw at any time. Withdrawal of consent does not affect the lawfulness of the processing prior to its withdrawal. In the event that commercial communication is carried out by email, the links to our newsletters may contain a tracking pixel that allows us to know their opening. The following data will be collected: email address, content of the sent newsletter, link clicked, and date and time of opening.
  • Comply with TRENT’s legal obligations arising from the existing contractual relationship with you. The processing of your data for this purpose is based on Article 6.1.c) of the GDPR (legal obligation applicable to TRENT). In the event that the data subject provides third-party data, they declare to have the consent of these parties and undertake to convey the information contained in this clause, releasing TRENT from all liability for information.
  • Manage your subscription to receive our commercial newsletter in which we inform about TRENT’s products and/or services. The processing of your data for this purpose is based on Article 6.1.a) of the GDPR (

Personal Data Collected by TRENT

As part of our activities, we may collect some data directly from you for the purposes detailed in the previous section of this policy. The information we collect includes:

  • Personal data you provide when creating your member account, such as your identity, email address, and password.
  • Your contact details, particularly your phone number, date of birth, and billing and delivery addresses for your orders.
  • Your personal preferences related to the products we sell on our site.
  • Information regarding your orders, such as the products and services you request.
  • Information regarding your payment methods when placing an order on our site.

Please note: Your banking data is not transmitted unencrypted on TRENT’s servers. Payments are made through a secure payment platform, compliant with PCI-DSS standards, and complemented by control measures to ensure the security of purchases made on the site and to combat fraud. The data of your bank card communicated when placing your order always transit encrypted through the network: they are encrypted using the TLS (Transport Layer Security) protocol. When registering your bank card data with our company to facilitate your future purchases, TRENT securely stores a portion of your bank card numbers: the first 6 digits corresponding to your bank’s code, and the last 4 digits. These two series of numbers are recorded in separate and secure files. TRENT cannot reconstruct your entire bank card number in any way from these digits. Additionally, we do not retain the CVV of your bank card (the 3 numbers on the back of your card). The last 4 digits of your bank card will be visible in your member account.

  • Information you may need to provide to our Customer Service in managing your information requests or complaints.
  • Information you enter when leaving a review about a product or service on our site.
  • In the case of registration through Facebook: data from your Facebook profile such as your name, date of birth, and email address. You have the option not to transfer some of this data.

Legitimization of Processing and Legal Bases:

  • Contract Execution: The processing of your data is necessary for the execution of the contract between you and TRENT when creating an account on the Site or placing an order, to ensure payment, delivery, order tracking, and manage your relations with our Customer Service.
  • Legitimate Interest: TRENT may have a legitimate interest in processing your data. For instance, sending emails announcing new products to its members, preventing and combating fraud on the Site, managing returns of products, recovering unpaid orders, or analyzing member navigation to improve offers and services, perform statistical studies on the products/services sold, and protect digital media (websites, applications, etc.).
  • Consent: TRENT conducts processing after obtaining your explicit consent, which you can withdraw at any time. This applies, for example, to sending brand alerts, linking your bank card data to your TRENT account to avoid entering them in future orders, or creating a commercial profile about you based on the data obtained through your navigation on the Site.
  • Compliance with Legal Obligations: TRENT may carry out processing in compliance with its legal obligations, such as possible product withdrawal procedures, or accounting treatment of orders.

Management of Inquiries, Suggestions, and/or Complaints

Users can submit inquiries through the customer service contact form on the Web Portal, as well as by making calls for assistance or receiving responses via email, only in cases expressly requested. The processing of your data for this purpose is based on what is set forth in Article 6.1.b) of the GDPR (contract execution).

The data provided by the User when making any inquiries, suggestions, and/or complaints may be transferred to related companies to manage the same. This transfer will be necessary in some cases to process your inquiry, suggestion, or complaint.

Obligation to Provide Data

The personal data requested in the various forms are mandatory, except where expressly indicated otherwise. Therefore, refusal to provide them will make it impossible to carry out the aforementioned purposes. In case the data subject provides third-party data, they declare to have the consent of those third parties and undertake to convey the information contained in this clause, releasing TRENT from any liability for information.

Data Processed by TRENT

TRENT will process the following categories of data, in addition to those indicated above:

New customer registration:

  • Identifying data: name, surnames (name and surnames of authorized buyers), ID/NIF, user codes, signature, etc.
  • Contact data: postal address, telephone number, email address, etc.
  • Personal characteristic data: date of birth, gender, etc.
  • User codes and passwords

Newsletter subscription form:

  • Contact data: email address.

Contact form or customer service request:

  • Identification data: name, surnames (name and surnames of authorized buyers), ID/NIF, user codes, signature, etc.
  • Contact data: telephone number, postal address, email address, and any other data provided through formulating the query, complaint, and/or claim.

Retention Periods of Personal Data

Personal data will only be retained for the minimum time necessary for the purposes of their processing and, in any case, only during the following general period: 18 Months, or until the User requests their deletion. At the time personal data is obtained, the User will be informed about the period during which the personal data will be retained, or if that is not possible, the criteria used to determine this period.

In summary, your data will be retained for the following periods:

  • For the management, maintenance, and administration of the subscribed contractual relationship, your data will be retained during the existing contractual relationship and, even after, until any responsibilities derived from the contractual relationship are prescribed.
  • For analyzing and expanding the contractual relationship with you, your data will be retained for the entire contractual relationship or until you object to the processing.
  • To send you communications about advertising and marketing campaigns that may be of interest to you, your data will be retained until you revoke your consent. The consent can be revoked at any time. In any case, the withdrawal of your consent will not affect the legality of the treatments carried out previously.
  • To comply with legal obligations arising from the contractual relationship, your data will be retained for the legally prescribed periods.
  • For managing your inquiry, suggestion, complaint, and/or claim, your data will be retained for the entire time of managing your inquiry and, even after, until any responsibilities derived from the inquiry are prescribed.
  • For managing your digital account, your data will be retained until you request the deletion of the online account or until the contractual relationship with TRENT ends, and even after, until any responsibilities derived from the contractual relationship are prescribed.
  • For managing your subscription to receive our newsletter, your data will be retained until you revoke your consent.

Recipients of Personal Data

The User’s personal data will not be shared with third parties except as detailed below and previously mentioned.

In any case, at the time personal data is obtained, the User will be informed about the recipients or categories of recipients of the personal data.

  • The State Tax Administration Agency for compliance with TRENT’s tax obligations, as well as any other public administration.
  • Banks and financial entities for the execution of the contract between the customer and TRENT.
  • Judges and Courts in cases provided by law. To carry out the aforementioned purposes, we use, in accordance with Article 28 of the GDPR, providers as data processors.

To carry out the mentioned purposes, we use, in accordance with Article 28 of the GDPR, providers as data processors among others:

  • Data hosting service providers.
  • Web development and maintenance service providers.
  • Technological service providers.
  • Printing service providers.
  • Support service providers for sending emails and SMS.
  • Telephone contact service providers.
  • Marketing service providers and advertising printing.
  • The user.

Guarantee of Truthfulness and Security of Personal Data

The User guarantees to be over 18 years old and that the data provided to TRENT is true, accurate, complete, and up-to-date. The User is responsible for the accuracy of all communicated data and will keep the provided information properly updated to reflect their real situation. By registering, they guarantee compliance with the requirements necessary to be a user and client of TRENT.

The User ensures that they have informed any third parties whose data they provide, if applicable, about the aspects contained in this document. Additionally, they guarantee that they have obtained their authorization to provide their data to TRENT for the stated purposes. The User will be responsible for any false or inaccurate information provided through the Web Portal and for any direct or indirect damages caused to TRENT or third parties.

Confidentiality and Security of Personal Data

TRENT undertakes to adopt the necessary technical and organizational measures, according to the appropriate level of security concerning the risk of the collected data, to guarantee the security of personal data and prevent the accidental or unlawful destruction, loss, or alteration of transmitted, stored, or otherwise processed personal data, or unauthorized access or communication of such data.

The Web Portal has an SSL certificate (Secure Socket Layer), ensuring that personal data is transmitted securely and confidentially, as the data transmission between the server and the User, and vice versa, is completely encrypted or encoded.

However, since TRENT cannot guarantee the invulnerability of the internet or the total absence of hackers or others fraudulently accessing personal data, the Data Controller undertakes to promptly inform the User in the event of a personal data security breach that may likely entail a high risk to the rights and freedoms of individuals. As defined in Article 4 of the GDPR, a personal data security breach is any breach of security resulting in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data.

Personal data will be treated as confidential by the Data Controller, who commits to informing and ensuring, through a legal or contractual obligation, that such confidentiality is respected by its employees, associates, and anyone to whom the information is made accessible.

Rights Derived from the Processing of Personal Data

The User has and can therefore exercise against the Data Controller the following rights recognized in the GDPR and Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights:

[…]

Rights to access, rectification, deletion, limitation of processing, data portability, objection, withdrawal of consent, filing a complaint with the competent control authority, and not being subject to decisions based solely on automated processing, including profiling.

Therefore, the User may exercise their rights by written communication addressed to the Data Controller with the reference “GDPR – TRENT,” specifying:

[…]

This request and any other attached document may be sent to the following address and/or email:

Postal address: C/ Trafalgar nº6, Ppal 2ª. 08010 Barcelona.

Email: info@trent.es

Links to Third-Party Websites

The Web Portal may include hyperlinks or links that allow access to third-party websites other than TRENT, and therefore not operated by TRENT. The owners of such websites will have their own data protection policies, being themselves, in each case, responsible for their own files and privacy practices.

Complaints to the Control Authority

If the User considers that there is a problem or infringement of current regulations in the way their personal data is being processed, they will have the right to effective judicial protection and to file a complaint with a control authority, particularly in the State where they have their habitual residence, workplace, or the place of the alleged infringement. In Spain, the control authority is the Spanish Data Protection Agency (http://www.agpd.es).

ACCEPTANCE AND CHANGES IN THIS PRIVACY POLICY

The User must have read and agreed to the conditions on the protection of personal data contained in this Privacy Policy and must accept the processing of their personal data for the Data Controller to proceed with it in the manner, for the periods, and for the purposes indicated. The use of the Web Portal implies acceptance of its Privacy Policy.

TRENT reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by legislative, jurisprudential, or doctrinal changes of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. It is recommended that the User periodically check this page to stay informed about the latest changes or updates.

This Privacy Policy was updated to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on the protection of individuals concerning the processing of personal data and the free movement of such data (GDPR) and Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights.

This Privacy Policy document is drafted on 25/10/2021.