Aguas de Victorio Lucchino Privacy Policy

Last update January 2020

Welcome to our website www.aguasdevictorioylucchino.com (the “Website”). Please read our Privacy Policy carefully.

1. Our commitments

Everyone has the right to protection of his/her Personal Data. We respect users' right to be informed regarding the collection of and other operations involving their Personal Data. In using data that may directly or indirectly identify you personally, we will apply a principle of strict necessity. For this reason, we have designed the Website in such a way that the use of your Personal Data will be kept to a minimum and will not exceed the purposes for which your Personal Data was collected and/or processed; we do not process your Personal Data when we can provide you with services through the use of anonymous or traffic data (such as marketing research made for improving our services, browsing data processed to provide you with customised contents or offers adapted to your preferred language, your location, etc.) or by other means which allow us to identify you, apart from when it is strictly necessary or upon request by competent public authorities or the police (for example, in case of traffic data or your IP address).

For the purposes of the Data Protection Legislation (as defined below), ANTONIO PUIG S.A.,(“APSA”) with registered address at Plaça Europa, 46-48 08902 Hospitalet de Llobregat (Barcelona), holder of Tax Identification Number B-64.797.129, recorded with the Commercial Registry of Barcelona at volume 40.696, folio 197, sheet number B-371.911.and/or any companies of the PUIG Group that may need to have access to and process the Personal Data collected on the Website for one of the purposes listed below shall be considered as the controller of your Personal Data (hereinafter, jointly referred as to the “Company”).The Company hereby undertakes to treat any and all information provided online by a user as strictly confidential.

This Privacy Policy relates to personal information identifying any user when accessing our Website, using its services and/or filling in forms on our Website with or without purchasing any product (“Personal Data”). This Privacy Policy helps you understand how the Company collects and uses your Personal Data and for which purposes and lists your rights in relation to your Personal Data.

By using this Website, you accept the practices described in this Privacy Policy. If you do not want to accept the practices described in this Privacy Policy, please do not use the Website. You must communicate to our Customer Service any changes to Personal Data in order to ensure that the information contained in our files is, at all times, up-to-date and accurate. You are responsible, in all cases, for the accuracy of the Personal Data provided, and we reserve the right to suspend or interrupt the provision of the requested services should you provide inaccurate Personal Data, without prejudice to any action allowed by law. For any issues or questions relating to this Privacy Policy you can contact to our Customer Service.

2. Applicable law

Any and all Personal Data sent to the Company through the Website will be collected and/or processed by the Company pursuant applicable data protection law, including the EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation or GDPR) without prejudice however to any applicable local mandatory laws benefitting to consumers, in accordance with EU Regulation 593/2008 (“ROME I”) of 17 June 2018, or any other conflict of laws rules applicable as the case may be (together, “Data Protection Legislation”).

3. Who collects and processes Your Personal Data, how and for which purposes?

The Company may collect and process your Personal Data for a variety of different purposes.

Your Personal Data may be processed to provide the e-commerce services you subscribed to or reserved for registered users, notably to fulfill orders that you have placed for goods or services through the Website, to contact you in relation to any issues with your order or where we need to provide your Personal Data to our service providers in relation to your orders of products (herein the "Commercial Purposes"). The PUIG Group Company, which is acting as a seller, as the case might be, according to the relevant Terms and Conditions of Sale included in this Website, shall be considered as the controller of your Personal Data collected and processed on the Website for Commercial Purposes, as it will determine the purposes and means of processing Personal Data for such Commercial Purposes.

Your Personal Data may also be processed for marketing purposes, notably to send to users, also through newsletter, commercial communications, information and updates on our products, offers, exclusive sales, promotional campaigns and on events and similar initiatives organized by ANTONIO PUIG S.A. and/or any companies of PUIG Group, or to facilitate your navigation on the Website (herein the "Marketing Purposes"). ANTONIO PUIG S.A. shall be considered as the controller of your Personal Data collected and processed on the Website for Marketing Purposes, as it determines the purposes and means of processing Personal Data for such Marketing Purposes. For the Commercial Purposes only, ANTONIO PUIG S.A. has appointed certain entities that will also process Personal Data relating to the Website’s Users (herein the "Processors").

The above-mentioned service providers and Processors have been chosen because of their experience in processing Personal Data and they provide sufficient guarantees regarding compliance with Data Protection Legislation (including the technical security measures governing the processing to be carried out). In processing the Personal Data for Commercial Purposes, the Processors shall act only under the instructions from ANTONIO PUIG S.A.. We regularly check that our Processors comply with our instructions and that they continue to provide sufficient guarantees regarding their full compliance with Data Protection Legislation on Personal Data processing.

The Processors of your Personal Data for Commercial Purposes are:

• Customer Service, for purposes related to shipping, delivering and returning products purchased on the Website and Customer Care services to the Website’s users;
• Reseller Group Networks SL for purposes related to the housing of ANTONIO PUIG’S servers;
• Ingenico ePayments for purposes related to payment method;
• FedEx for purposes related to shipping services.

Your Personal Data is mostly processed by electronic means and, in some circumstances, by paper-based means, such as when the processing of your Personal Data is required for preventing fraud on the Website. Your Personal Data shall be stored in a way which allows us to identify you for the period necessary for the purposes which the data was collected for and subsequently processed and, in any case, in accordance with Data Protection Legislation. Your Personal Data shall not be disclosed to third-parties other than us for purposes which are not permitted by law or without your consent.

Aside from the Processors appointed for Personal Data processing, your Personal Data will be made available also to third-parties, autonomous controllers, for purposes related to supplying services requested by Users (for example, for purchase transactions) or for purposes of third-parties. For more information on the matter, see section 5 (To Whom Your Personal Data Will Be Disclosed).

For the Marketing Purposes, we may process your Personal Data as well as browsing data ("Traffic data") resulting from the use of the Website and of our services by any User, in order to provide Users with customized contents and offers on our services or to deliver any newsletter they subscribed to, subject to their discretionary right to withdraw their subscription to such newsletter or to oppose or object to the receiving of any advertising or marketing content which we think is of interest to a specific User. For Marketing Purposes, Personal Data and Traffic data is mostly processed by electronic means and shall be stored for us in any case, in accordance with Data Protection Legislation and available to our Processors. Moreover, your Personal Data may be disclosed to the public authorities (e.g. police, judicial) according to applicable laws and upon a formal request by such entities, for example in the event we need to prevent fraud on the Site (anti-fraud services).

Data processors will also have access to your Personal Data as stated in section 3 for the specific purposes stated therein. In all the above circumstances, your consent for data processing is not required as Personal Data Processing would be necessary for the performance of Commercial Purposes.

The reasons for collecting Personal Data will be expressly listed in the information of privacy statement that we will present from time to time on the page asking the User to provide his or her Personal Data, be it for Commercial Purposes or for Marketing Purposes. We may have access to third-parties' Personal Data which was directly disclosed by its Users, for example when a User bought a product to be sent to a friend, when the User paying for the product is different from the recipient of the product, or when a User wishes to recommend to a friend a service of the Website or the sale of a particular product.

In all of the above cases, please make sure you receive the consent of such individuals before disclosing their Personal Data to us and make sure you inform them about this Privacy Policy; you will be the only person liable in connection with the disclosure of information and data regarding such third-parties if they have not provided you with their prior explicit consent for it and for any improper and unlawful use of that information. In any event, we shall fulfil any obligation to inform third-parties required by law and, when necessary, shall request their explicit consent upon registering in their archives the Personal Data of the User indicated.

4. What Happens if You Do Not Disclose Your Personal Data to us?

Granting your Personal Data to us (in particular, your personal details, your e-mail address, your address, your Credit/Debit Card numbers and bank code and your telephone number) is necessary for processing your order for the purchase of products on the Website, supplying other services provided on the Website upon your request, or when your Personal Data is needed to fulfil obligations required by law or regulations. The refusal to provide us with some of your Personal Data necessary for performing the above purposes may consequently prevent us from processing your order for the purchase of products sold on the Website or fulfilling obligations required by law and other regulations. Therefore, failing to provide Personal Data may constitute, in some cases, a legitimate and justified reason for not processing your order for the purchase of products sold on the Website or not providing the Website’s services. Disclosure of further Personal Data to us other than that required for fulfilling legal or contractual obligations and to be properly browse our services with necessary traffic data is, on the contrary, optional and does not have any effect on the use of the Website and of its services or on the purchase of products on the Website. We will inform you at every step whether disclosing your Personal Data to us is compulsory or optional by marking with an appropriate symbol (*) the information that is compulsory or data needed for the purchase of products on the Website.

5. To whom your Personal Data will be disclosed?

Personal Data will be disclosed to third-party companies that provide, on behalf of the Company, specific services as data Processors or to other recipients of Personal Data collected by us that process your Personal Data only for the Commercial Purposes and, in any case, according to applicable laws and regulations.

Your Personal Data is also intended to the companies belonging to PUIG’s Group, with registered offices in EU countries or non-EU countries, for their own Marketing Purposes. Notwithstanding the foregoing, Personal Data will not be disclosed to any other third-parties or disseminated or transferred without informing our Users of such disclosure/dissemination/transfer, and, in any case, in accordance with the applicable laws.

6. Security Measures and length of conservation

We have adopted security measures to protect Personal Data against accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure or access, and against all other reasons for data processing that do not comply with our Privacy Policy.

For the best possible protection of your Personal Data outside the limits of our control and management of the same, it is advisable that your computer be provided with software devices that protect network data transmission/receipt (such as updated antivirus systems) and that your Internet service provider take appropriate measures for the security of network data transmission (such as, for example, firewalls and anti-spam filtering). We will only hold your Personal Data for so long as is necessary for us to fulfil the purposes set out in this Privacy Notice. Where we no longer need to process your Personal Data for the purposes set out in this Privacy Notice, then we will delete your Personal Data from our system.

7. Transfer of your Personal Data to other countries

The Personal Data we collect from you is currently held within the European Union (‘EU’). However, it is possible that in the future such Personal Data may be transferred, stored and/or processed outside the EU. By submitting your Personal Data, you agree to this transfer, storing and/or processing. You should be aware that countries outside the EU may not offer the same level of data protection as the EU. However, we will take reasonable steps to ensure that your Personal Data is given equivalent protection in accordance with the Data Protection Legislation, in particular by implementing adequate contractual conditions in our agreements with business partners dealing with transfer of Personal Data to ensure that Personal Data are processed according to our instructions, and in such a way to maintain their integrity and security.

8. Your right in relation to your Personal Data

We set out below a summary of the rights available to you in connection with your Personal Data.

For your convenience, and without prejudice to certain formal requirements set out in the Data Protection Legislation, you can exercise any of these rights by contacting us at consumercare@puig.com.

• Right to withdraw your consent:

You may at any time withdraw the consent you give to the Company for processing your Personal Data. Please note, however, that where you do withdraw your consent or otherwise object to our processing of your Personal Data then this may impact on our ability to provide you with goods and services or affect the functionality of our Website. In addition, if you want to stop receiving future marketing messages, communications and materials at any time, you can do so alternatively by clicking the 'unsubscribe' link which is included in all of our email marketing messages.

• Right to access your Personal Data in our possession:

You are entitled to obtain, at any time, confirmation from us as to whether or not we are processing your Personal Data and, where that is the case, access such Personal Data.

Moreover, you are entitled to receive from us information on the source of your Personal Data; the purposes and way of processing your Personal Data; the logic involved in any electronic data processing; details of the data controller and of the data processors; the names of the entities and categories of entities to whom your Personal Data may be disclosed or who may access your Personal Data, for example, as a data controller or a party so appointed.

• Right to have inaccurate Personal Data rectified:

You have the right to obtain from us without undue delay the rectification of inaccurate Personal Data that we hold and which concerns you. The includes the right to request that incomplete Personal Data is completed.

• Right to erasure:

You have the right to obtain from us the erasure without undue delay of Personal Data that we hold and which concerns you, in the circumstances as provided by Data Protection Legislation.

• Right to restriction of processing:

You have the right to restrict the way we process your Personal Data in the circumstances as provided by Data Protection Legislation.

• Right to data portability:

You have the right to receive from us the Personal Data concerning you which you have provided to us, in a structured, commonly used and machine readable format and have the right to transmit those data to another controller without hindrance from us. This right shall include the right to require us to transmit the relevant Personal Data to another controller on your behalf, where technically feasible. This right only applies to personal data that: (i) we gain your consent to process; or (ii) we obtain in order to perform our contractual obligations to you, and in each case to the extent we process your Personal Data by automated means.

• Right to lodge a complaint about us:

You are entitled to exercise your right to lodge a complaint with a competent supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal data infringes Data Protection Legislation.

9. Opt-in/Opt out

Each time your consent is required, the Company will inform you in advance and will give you the option to either provide or refuse your consent for the use of your Personal Data, including your e-mail address, for the above purposes, by ticking the appropriate boxes.

We wish to inform you that we may process your Personal Data also without your consent in certain circumstances, such as when such processing is necessary for performing a legal obligation to which we are subject or when such processing is necessary for performing obligations undertaken in contracts with the users.

10. Contacts

You may contact the Company at any time at the following email address consumercare@puig.com and/or at the following telephone number: [] , for any concern or question regarding this Privacy Policy and your Personal Data provided to the Company, or of you wish to receive further information on how we process your Personal Data.

11. Amendments and updating of this Privacy Policy

We may amend or simply update all or part of this Privacy Policy, including when amendments are made to legal provisions or regulations which govern data protection and protect your rights. The amendments and the updating of the Privacy Policy shall be binding as soon as they are published on the Website in this section. Therefore, you are requested to regularly access this section in order to check the publication of the most recent and updated Privacy Policy.

 

PRIVACY STATEMENT-CALIFORNIA

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in Privacy Policy and applies only to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer	Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	NO
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	NO
G. Geolocation data.	Physical location or movements.	NO
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA's scope, like:
• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy

Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from our customers or their agents. For example, from information that our customers provide in order to facilitate the purchase of our products.
• Indirectly from our clients or their agents. For example, through information we collect from our customers in the course of providing products to them.
• Both directly and indirectly from activity on our website.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. For example, if you provide us with your address, we will use this information to ship products to you.
• To provide you with information, products or services that you request from us.
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
• To improve our website and present its contents to you.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A:	Identifiers.
Category B:	California Customer Records personal information categories.
Category C:	California Protected Class information
Category D:	Commercial Information

We disclose your personal information for a business purpose to the following categories of third parties:

• Our affiliates.
• Service providers.
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have not sold any personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
7. Comply with a legal obligation.
8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Email : consumercare@puig.com

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to change this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Website: aguasdevictorioyluchino.com

Email: consumercare@puig.com

Postal Address: Plaza Europa, 46-48, 08902 L’Hospitalet de Llobregat, Barcelona, Spain.

This Privacy Policy has been updated in January 2020.

© ANTONIO PUIG S.A., 2019. All rights reserved.