PRIVACY POLICY
Information on personal data processing (art. 13 of Legislative Decree 196/2003)
Pursuant to art. 13 of Legislative
Decree of 30 June 2003, No 196 “Code implementing provisions regarding personal
data protection” (“Code”), Ropar - Fabrico de Calçado Ortopédico, S.A., with registered
office at Travessa de Santa Eufémia, 851, 4485-060 Vila do Conde, Portugal and
owner of brand “Easy Walk Experience” (hereinafter
called “ROPAR”), in its capacity as data processor in accordance with art. 4 of
the Code, provides to the users of site www.easywalkexperience.com (the “Site”)
information on the use of the following personal data.
a) Type and source of the processed
data
The personal data processed by
ROPAR are collected directly from the users of the Site, through their
registration to the services offered (for example to the shop-on-line service).
The mere navigation within the site, without registration to any online service,
may include the acquisition of data in a completely anonymous manner. In fact,
the site uses tracking systems to collect information on the modalities of use
of the webpages by the users. Through the tracking systems, information (such
as, for example: the type of browser used, if the user clicks on a ROPAR banner,
the pages that are visited, the nationality of the server used by the computer)
is collected with the purpose of making the navigation within the site more
efficient.
b) Data processor
The data processor Ropar - Fabrico
de Calçado Ortopédico, S.A., with registered office at Travessa de Santa Eufémia, 851,
4485-060 Vila do Conde, Portugal
c) Purpose of
the data processing
The personal data collected in the forms
of registration to the services of the Site and/or to the services that may be collected
in the context of the process of navigation
within the site, including any sensitive data that come into the possession of Ropar
on the initiative of the customer concerning specific operations or special services
required by the customer (for example, for the registration to newsletters), shall
be processed for the following purposes:
(i) fulfilment of the obligations provided for by the law, regulations, Community
rules, as well as instructions from the authorities and supervisory bodies;
(ii) management and execution of the precontractual and/or contractual relationships
with customers/users, through the introduction of the data provided in Ropar IT
systems
(iii) sending of information and commercial promotions, based on the
consumption choices and on the preferences
expressed, by telephone, SMS, MMS and e-mail, concerning the offer of Ropar products
and services, as well as for market research, surveys and personalised or
statistical analysis. To this end, the information obtained through navigation
within the site and through other services offered can be used by means of electronic
processing.
Pursuant to articles 24.1.b) and 43.1.b) of the Code, no authorisation shall be
required for the processing in relation with the purposes indicated in points
(i) – (ii). On the contrary, the person concerned shall express, in the
corresponding field of the registration form, his/her authorisation for the data
processing (excluding sensitive data) for the purposes indicated in point (iii).
d) Modalities of processing
As regards the modalities indicated in point c), data processing, which will
include the operations related with the definition of “processing” defined in art. 4 of the Code
(as, for example, the collection, registration, drawing up, extraction, comparison,
communication and cancellation), shall
be made by using manual and automated instruments, for which Ropar has adopted
adequate security measures in order to guarantee the data integrity and privacy.
e) Compulsory/optional provision
Data provision is optional. However
non-provision of the data indicated in the registration form of the services,
or of other personal data that may be requested for the implementation of the contractual
relationship, may prevent Ropar from commencing and/or continuing, in the whole
or in part, the contractual relationship, i.e., from meeting the requests for
the provision of services.
f)
Category of individuals to whom data may be communicated or who may have access
to the data
Personal
data may possibly be communicated to:
(i) other companies that have a group
relationship with Ropar (after the introduction of the data in company’s the IT
system);
(ii)(ii) external firms that can be used by
ROPAR within the context of the management of the contractual relationship with
its customers, to meet organisational requirements of Ropar and of its activity,
which may possibly be specialised in: (a) bank, financial and insurance services,
including the individuals who intervene in the management of payment systems;
(b) services of data acquisition, registration and processing; (c)
communication printing, transmission, packaging, transport and selection activities;
(d), archives services of the documentation concerning the contractual relationships;
(e) services of credit recovery; (f) IT services and services of management of
Ropar IT system and of the telecommunications networks (including e-mail); (g) offices
or companies within the context of assistance or consultancy relationships; (h)
individuals who perform operations of control, revision and certification of
the activities carried out by Ropar; (i) services of call centre and agencies and/or
agents charged with the promotion of the goods and services provided by Ropar;
(l) market analysis and communication services for the presentation of commercial
offers, including customised offers. These individuals shall process the
customers’ personal data as autonomous data subjects or may have access to the
data as external processors, in case they are specifically appointed in
accordance with art. 29 of the Code. Personal data shall also be accessed by
workers and employees, including external workers, specifically charged with
the processing (with selected access based on the function), belonging to services
and central offices and/or to the sales network of Ropar, who perform
technical, support and control activities within the company. The list of external
companies which are processors, or the indication of those that operate in full
autonomy as separate processors, shall be updated by Ropar Privacy Department and
shall be made available at its headquarters.
g) Rights in accordance with Art. 7 of the
Code
As regards personal data processing, based
on no art. 7 of the Code, the data subjects shall be entitled, at any time, to
obtain confirmation of the existence of the data, to know their content and origin,
to check their accuracy or to request their integration, update or correction.
In accordance with the same article, they
are entitled to request deletion, transformation into anonymous form or
blocking of data processed in breach of the law, as well as to oppose, in any
way, for legitimate reasons, their processing.
The requests under art. 7 of the Code should
be sent to Ropar - Fabrico de Calçado Ortopédico, S.A. | Privacidade site
Easy Walk Experience, Travessa de Santa Eufémia, 851, 4485-060 Vila do Conde.
Legal and corporate information
Ropar - Fabrico de Calçado
Ortopédico, S.A.
Registered office: Travessa de
Santa Eufémia, 851, 4485-060 Vila do Conde, Portugal
Share capital 1.000.000,00
euros,
VAT No - 500235660
INTELLECTUAL PROPERTY RIGHTS
The domain name,
Easywalkexperience brands and the contents available within this site are owned
by Ropar- Fabrico de Calçado Ortopédico, SA.The reproduction, modification,
distribution, transmission, publication and, in general, any use of the
intellectual property rights that is not expressly mentioned shall be punished in
accordance with the law.