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 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.