Privacy Policy

PRIVACY AND COOKIES POLICY

SUMMARY OF OUR PRIVACY POLICY

WHO WE ARE. We are Pinguim Sub and we process your personal data as joint controllers. This means that we are jointly responsible for the way we treat and protect your data.

WHAT WE USE YOUR DATA FOR. We will use your data (collected online or in person), among other purposes, to manage your registration as a user, to manage your purchases of products or services, to answer your questions and, if you wish, to send you personalized communications.

WHY WE USE YOUR DATA. We are legitimate to process your data for several reasons. The main reason is our need to process your data to execute the contract you agree to enter into with us when you register and when you make a purchase or enjoy any of our services or features. We also use your data for other reasons, such as to answer your questions or to send you newsletters, which you have requested.

WITH WHOM WE SHARE YOUR DATA. We share your data with service providers that provide us with assistance or support, these being companies that are part of the Inditex Group or third party suppliers, inside and outside the European Union.

YOUR RIGHTS. You have the right to access, rectify or delete your personal data. In certain cases, you are granted other rights, such as, for example, the right to object to the use of your data or the transfer of your data, as explained in more detail below.

We advise you to read our Privacy and Cookie Policy in its entirety, which is described below, in order to better understand how we use your personal data and what your rights in relation to your data are.

BEFORE YOU BEGIN… • In this Privacy and Cookie Policy you will find all the relevant information regarding your use of the personal data of our users and customers, regardless of the channel or means (online or in person) of PinguimSub that you use to interact with us.
• We are transparent about our use of your personal data, so that you understand the implications of how we use your data and the rights you are granted with respect to your data:
o We permanently make all the information included in this Privacy and Cookie Policy available to you, which you can check when you see fit and, in addition,
 you may also find additional information regarding our use of your data as you interact with us.
• The following are some of the terms we regularly use in this Privacy and Cookie Policy:
When we refer to our Platform, we generally refer to any of the channels or media, digitally or in person, that you may have used to interact with us.
The main ones are:
▪ Our website, www.pinguimsub.pt
▪ In person, at any of our PinguimSub.

WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR DATA?
The controllers of your data are: Pinguim Sub.
, a company currently operating in Portugal selling Intouchbiz branded products on Postal address: Urbanização da Raminha Lote 1 8500-579 Portimão Portugal. o Data Protection Officer's email address: tek@pinguimsub.pt

In other words, PinguimSub. (together “We”, or “Joint Controllers”), are Joint Controllers of the data. This means that we regulate and are jointly responsible for the processing and protection of your personal data.

WHY WE PROCESS YOUR PERSONAL DATA Depending on the purpose for which we process your data at any given time, as explained above, we need to process some data which, in general, will be, depending on each case, the following:

▪ Your identification data (eg your name, surname, language and country from which you interact with us, contact details etc.);
▪ economic and transaction information (eg your payment or card details, information regarding your purchases, orders, returns, etc.);
▪ connection, geolocation and/or navigation data (if you interact with us via your mobile phone, for example):
▪ commercial information (for example, if you have subscribed to our newsletter),
 ▪ information about your tastes and preferences. Remember that when we ask you to fill in your personal data to give you access to any functionality or service on the Platform, we will mark certain fields as mandatory, as these are the information we need to be able to provide you with the service or give you access to the functionality in question. Please note that if you decide not to provide such data, you may not be able to complete your user registration or you may not be able to enjoy these services or features. In specific cases, a third party may provide us with information about you using a feature or service on the Platform, for example, sending you a gift card or sending an order to your address. In such cases, we only process data where relevant to this feature or service, as indicated in this Privacy and Cookie Policy. Depending on how you interact with our Platform, that is, depending on the services, products or features you want to enjoy, we will process your personal data for the following purposes:

GOAL
info
To manage your registration as a user of the Platform
If you decide to become a registered user of our Platform, we need to process your data to identify you as a user of the Platform and to give you access to its various features, products and services that are available to you as a registered user. You can cancel your registered user account by contacting us via Customer Service
For the development, fulfillment and execution of the purchase or services agreement entered into with us on the Platform
This purpose includes the processing of your data, in particular: ▪ To contact you regarding updates or informational communications related to the features, products or services contracted, including quality surveys and to establish a degree of customer satisfaction with the service provided; ▪ To manage payment for the products you have purchased, regardless of the payment method used. For example: ▪ If, when purchasing any of our products via the Website or the App, you choose to activate the functionality of saving your card data for future purchases (whenever this feature is available), we will have to process the data indicated for activation and development of this functionality. The consent to activate this functionality allows the automatic filling of your payment data to appear in subsequent purchases so that you do not have to re-enter them in each new process, and this data will be considered valid and valid for subsequent purchases. You can change or cancel your cards at any time via the payment information section, either from your registered user account on the Site, or from the App Wallet feature of www.intouchbiz.com ▪ If you use the App Wallet feature to pay for your purchases in person, we need to process your data to activate it, so you can start your purchases in the physical stores of PinguimSub.
 (“physical stores”) appointed for such purpose. ▪ Activate the necessary mechanisms to prevent and detect unauthorized uses of the Platform (for example, during the purchase and returns process and also to prevent potential fraud committed against you and/or us. If we consider that the transaction may be fraudulent, or if we detect abnormal behavior that indicates an attempt to fraudulently use our features, products or services, this processing may result in consequences such as blocking the transaction, or deleting the user account. ▪ In order to manage any returns or exchanges after your purchase and manage requests for information on availability of items, product reservations through the Platform, depending on the availability of such options at any given time.
For billing purposes and to provide you with receipts and invoices for purchases made through the Platform. ▪ In order to ensure that you can use other available features or services, such as purchasing, receiving, managing and using the Gift Card, or Gift Voucher, and to provide you with access to and use of the Wi-Fi that we make available to our customers in Physical Stores.

To satisfy requests or requests made through the Customer Support channels
We only treat personal data that are strictly necessary to manage or resolve your request or order. If you contact us via telephone, the call may be recorded for quality purposes and so that we can respond to your request.
 For marketing purposes.
This purpose includes the processing of your data, mainly, to: ▪ Customize the services we offer you and allow us to provide you with recommendations based on your interactions with www.fpfsistemas.com on the Platform and an analysis of your user profile (eg based on your shopping and browsing history). ▪ If and when you subscribe to our Newsletter, we will process your personal data to manage your subscription, including sending personalized information about our products or services through various means (such as by email or SMS). We may also make this information available to you via push notifications. if you have activated them on your mobile device. ▪ Therefore, bear in mind that the aforementioned data processing involves analyzing your user or customer profile to establish your preferences and, therefore, which products and services best suit your style when we send you information . For example, based on your shopping and browsing history (ie depending on the items you clicked on), we will suggest items that we think might interest you and, if you are a registered user, we will provide you with the "Cart Recovery" functionality.
Remember that you can unsubscribe to the Newsletter at any time without any cost through the "Newsletter" section of the Platform, in addition to unsubscribe using the instructions we provide you with each communication. If you do not wish to receive push notifications, you can disable this option on your mobile phone. ▪ Show you internet advertisements that you can see when you visit websites and apps, for example, on social networks. The advertising you will see may be random, but on occasion it may be advertising related to your preferences or shopping and browsing history. ▪ If you use social media, we may provide companies with which we collaborate with certain information so that they can show you ZARA advertising and, in general, offer you and users like you advertising that can take into account your profile in profiles of the so-called social networks. If you would like information about the use of your data and how advertising works on social media, we recommend that you review the privacy policies of the social media pages on which you have profiles. ▪ We also use your data to perform segment analysis and measure the advertising we show users on some of our contributors' platforms. To this end, we collaborate with these third parties who provide us with the necessary technology (eg cookies, pixels, SDK) to use these services. Please keep in mind that although we do not provide personally identifiable information to these contributors, we do provide them with some form of identifier at a time (for example, an advertising ID associated with the device, an identifier associated with a cookie, etc.). If you would like to receive more information in this regard, please consult our Cookies Policy. Likewise, you can delete your advertising ID or disable personalized advertising on your device (if you have our App installed on an iOS device you can configure your preferences in Settings/Privacy/Advertising. If your device is Android, go to Settings /Google/Advertising). ▪ Data enrichment: When we gather your personal data from a variety of sources, we may consolidate it under certain circumstances in order to improve our understanding of your needs and preferences related to our products and services (including for purposes of analyses, generating user profiles, marketing studies, quality surveys and improving our interactions with our customers). This refers, for example, to how we combine your information if you have a registered account and, using the same email linked to your account, make a purchase as a guest, or to information that is automatically compiled (such as, for example, IP and MAC addresses or metadata) that we may link to the information you have provided us directly through your activity on the Platform or in any of our stores (for example, information related to your purchases, whether in physical stores or online, your preferences , etc.).

Carry out promotional actions (for example, to organize competitions or to send the list of saved articles to the email address you have indicated)

. By participating in any promotional action, you authorize us to process the data you have made available to us depending on the promotional action and to communicate them through various means such as social networks or on the Platform itself. In each promotional action that you participate, you will have available the terms and conditions through which we will give you more detailed information about the treatment of your personal data. ▪ Disseminate on the Platform, or through our channels on social networks, photographs or images that you have shared publicly, whenever you give us your express consent to that effect.

Functionality and quality analysis to improve our services
If you access our Platform, we inform you that we will treat your browsing data for analytical and statistical purposes, that is, to understand how users interact with our Platform and with the actions we implement on other web pages and apps, so that we can improve our services. In addition, we will occasionally carry out quality surveys and actions aimed at finding out the degree of satisfaction of our customers and users and detecting areas where we can improve.

HOW ARE WE LEGALLY AUTHORIZED TO HANDLE YOUR DATA?

The legal grounds that allow us to process your personal data also depend on the purpose for which we process them, as explained in the following table:

Goal
Legitimacy
 Manage your registration as a Platform user
The processing of your data is required in accordance with the terms that govern the use of the Platform. In other words, in order to register as a user on the Platform, we need to process your personal data, otherwise we would not be able to manage your registration.
Development, fulfillment and execution of the purchase or service agreement
The processing of your data is necessary for the conclusion of the purchase or service contract with you. Certain data processing related to the purchase process is activated only because you request or authorize it, such as storing payment data (card) for future purchases, or processing data necessary to read receipts via the section App Wallet, or to provide you with the I'll Be Back / I'll Be Back Now features (where such features are available). In these cases, our data processing is based on your own consent. We consider that we have a legitimate interest to carry out the necessary checks to detect and prevent possible fraud or fraudulent uses of the Platform, for example, when making a purchase or return. We understand that the processing of this data is positive for all parties involved: For you, as it allows us to create measures to protect you against fraud attempts perpetrated by third parties; for us, as it allows us to prevent unauthorized uses of the Platform; for all our customers and society as it also protects their interest by ensuring that fraudulent activities are discouraged and detected when they occur.

Client support
We believe that we have a legitimate interest in responding to requests or questions that you put to us through the various contact channels that exist. We understand that the processing of this data is also beneficial to you, as it allows us to provide you with adequate assistance and answer your questions. When contacting us, in particular, to manage incidents related to your order or the item/service purchased through the Platform, the processing of your data is necessary for the conclusion of the purchase contract. When your request is related to the exercise of the rights about which we inform you below, or to complaints related to our products or services, we are legally authorized to process your data for the purposes of compliance with our legal obligations.

. Marketing
We are legally allowed to process your data for marketing purposes once you give us your consent, for example, when you accept to receive personalized information through different channels, when you accept to receive push notifications on your mobile phone or configure the settings of your mobile device to allow personalized advertising, or when you accept the terms and conditions to participate in a promotional action or to publish your photographs on the Platform or on our social media channels. To provide you with personalized services, or to show you personalized information, whether on our Platform, or on that of third parties, and also to engage in data enrichment, we consider that we have a legitimate interest in performing a profile verification with the information we have about you (such as browsing history, preferences or purchases) and the personal data you have provided to us such as age range or language, as we understand that processing this data is also beneficial to you once that allows you to improve your user experience and access information according to your preferences.

Functionality and quality analysis
We believe that we have a legitimate interest in analyzing the functionality of the Platform and the degree of user satisfaction, as we believe that the processing of this data is also beneficial to you, since the purpose is to improve the user experience and offer a service with more quality.

HOW LONG WILL WE KEEP YOUR DATA?
The period of retention of your data will depend on the purposes for which we process them, as explained below:

Goal
conservation period
Manage your registration as a Platform user
We will treat your data for as long as you remain a registered user (that is, until you decide to cancel your subscription).
Development, fulfillment and execution of the purchase or service agreement
We will process your data for as long as is necessary to manage the purchase of the products or services you have purchased, including possible returns, complaints or claims associated with the purchase of the product or service in question. Sometimes we will only process the data until you decide, as is the case with the payment data (card) that you have asked us to store for future purchases (whenever such feature is available).
. Client support
We will process your data for as long as necessary to fulfill your request or order.
Marketing
We will process your data until you unsubscribe from the newsletter. Therefore, we will show you personalized advertising until you change your mobile phone or browser settings, for example, if permission to do so is revoked. If you participate in promotional actions, we will retain your data for a period of six (6) months from the end of the action.
Functionality and quality analysis
We will treat your data sporadically during the time that we carry out a certain action or quality inquiry or even anonymize your browsing data.

Regardless of whether we process your data for the time strictly necessary to fulfill the corresponding purpose, we will subsequently keep them properly stored and protected for as long as responsibilities arising from the processing may arise, in accordance with the legislation in force at each time. When each of the possible actions prescribes, we will delete personal data.

DO WE SHARING YOUR DATA WITH THIRD PARTIES?

In order to fulfill the purposes indicated in this Privacy and Cookie Policy, it is necessary for us to give access to your personal data to entities of the Inditex Group and to third parties that support us in the services we offer you, namely:
▪ financial institutions,
 ▪ Anti-fraud prevention and detection entities,
▪ Providers of analytical and technological services,
▪ Service providers and service partners for logistics, transport and delivery and/or partner establishments,
▪ service providers related to customer support,
▪ Service providers and employees related to marketing and advertising, such as social media pages, advertising agencies or advertising partners. For reasons of service efficiency, some of the aforementioned providers are located in territories located outside the European Economic Area that do not provide a level of data protection comparable to that of the European Union, ie the United States. In such cases, we inform you that we transfer your data with adequate guarantees and always maintaining the security of your data:
 ▪ Some providers are certified under the Privacy Shield, a certification that can be consulted at the following link: https://www.privacyshield.gov/welcome
▪ With other providers, we have entered into standard contractual clauses approved by the Commission and whose content can be consulted at the following link: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside- eu/modelcontracts-transfer-personal-data-third-countries_en

e-mail to (geral@fpfsistemas.com), indicating only the reason for your request and the right you wish to exercise. In case we consider it necessary for us to identify you, we may request a copy of an identification document. In particular, regardless of the purpose or legal basis for which we process your data, you are entitled to:
• Request access to your personal data that we have. We remind you that, if you are a registered user on the Platform, you can also consult this information in the section corresponding to your online account.
• Request that we rectify the data we have. Remember that if you are a registered user of the Platform, you can also access the section corresponding to your personal data in your account to change or update your personal data. In any case, please note that by actively providing us with your personal data in any way, you guarantee that they are authentic and accurate and you undertake to notify us of any changes or alterations to them. Any loss or damage caused to the Platform or to the person responsible for the Platform or to any third party resulting from a wrong, inaccurate or incomplete communication of information in the registration forms, will be the exclusive responsibility of the user. Remember that, as a general rule, you should only provide us with your own personal data, not that of third parties, unless otherwise permitted in this Privacy and Cookie Policy.
• Request that we delete your data to the extent that it is no longer necessary for the purpose for which we need to continue processing it, as explained above, or when we are no longer legally authorized to process it.
• Request that we cancel or limit the processing of your personal data, which means that in certain cases you can ask us to temporarily suspend the processing of data or its retention beyond the necessary time. If you have given us your consent to process your data for any purpose, you also have the right to withdraw it at any time. Some of the ways in which you can revoke your consent are detailed in section 2, in which we explain the purposes for processing your data. For example, if you do not want us to send information to third parties to show you advertising, you can change your preferences on your mobile phone by resetting your advertising ID or disabling personalized advertising on your device. If you have our App installed on an iOS device, you can change your preferences in Settings/Privacy/Advertising. If your device is Android, go to Settings/Google/Advertising. If you are visiting the website, you can change the cookie settings on your browser. When we obtain legitimacy to process your data through your consent or for the purposes of the contract, as explained in section 3, you will also have the right to request the portability of your personal data. This means that you will have the right to receive the personal data that you have made available to us in a structured, current use and automatic reading form, so that you can transmit them directly to another entity without any kind of impediment on our part. Furthermore, as the processing of your data is based on your legitimate interest, you also have the right to challenge the processing of these. Finally, please note that you have the right to file a complaint with the data protection supervisory authority, namely the
▪ Spanish Data Protection Agency https://www.agpd.es/portalwebAGPD/index-ides-idphp.php
 ▪ The authority of the country in which the retail company is located: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

WHAT HAPPENS WHEN YOU PROVIDE US WITH THIRD PARTY DATA OR IF A THIRD PARTY HAS PROVIDED US WITH THEIR DATA?

We have features or services that require us to process the personal data of a third party that you, as a user or customer, must provide to us, for example, in the case of activating and sending the Gift Card or managing the application for the Gift Voucher (whenever such features are available), or when authorizing a third party to pick up an order from our stores or partner establishments. If you provide us with personal data from third parties or if it is necessary for us to have to ask a third party to collect an order on your behalf, you confirm that you have informed them of the purposes and the way in which we process your personal data. If a third party has provided us with your data, or if you have provided it yourself as a result of a feature or service requested by one of our users, we will use it to manage the feature or service in question in each case, within the limits of the purposes listed in this Privacy and Cookie Policy, a link to which is always included in our communications.

CHANGES TO THE PRIVACY AND COOKIES POLICY

We may make changes to the information set out in the Privacy and Cookie Policy, when we deem it necessary. If we make these changes, you will be notified by various means through the Platform (for example, through a banner, a pop-up or a push notification) or by message to your email, when the changes in question are relevant to your privacy, so that you can review them, evaluate them and, if applicable, contest or cancel any service or functionality. In any case, we advise you to periodically review this Privacy and Cookie Policy if small changes are made or some interactive improvements are introduced, remembering that it will always be available on our website and in our App.

INFORMATION ABOUT COOKIES

We use cookies and similar devices to facilitate your browsing on the Platform, understand how you interact with us and, in certain cases, be able to show you advertising based on the analysis of your browsing habits. Please read our information about Cookies to fully understand these and similar devices we use, their purposes and other information of interest.

Cookies Policy

Before starting...

In this Cookies Policy you will find information about the use we make of cookies and similar devices that are installed on the terminals of our clients and users. Occasionally, the use of cookies may be related to the processing of personal data, so you should consult our Privacy Policy, accessible on our Platform, if you want information on how we use the personal data of our customers and users, on how to exercise your rights or the terminology we use to refer to our Platform (Site, App or Physical Stores).

What is a Cookie?

A Cookie is a small text file that a website, app or other platform stores on your computer, tablet, smartphone or any other similar device, with information about your browsing or use, such as a tag that identifies your device. Cookies are necessary, for example, to facilitate navigation and to know how users interact with platforms, in order to improve them. They are also very useful to offer advertising, according to the user's preferences, as well as for other purposes described below. Cookies do not damage your computer or device. When we speak of "Cookies" we also mean other similar technologies for installing and/or collecting information on your device or about your device (such as flash cookies, web beacons or bugs, pixels, HTML5 [local storage] and technologies SDK for app formats). In addition, the term “Cookies” is also applicable to the use of fingerprinting techniques, that is, information combining techniques that help us to identify your device. Occasionally, these technologies work together with cookies to compile and store information, either to provide you with certain features or services on our Platform, or to show you advertising on third-party platforms, taking into account your browsing experience. This explanation is a general sample of what is meant by Cookies, for informational purposes only. The Cookies that we use specifically are described in the cookie configuration panel, accessible on our Platform.

What types of cookies are there?

This section provides an overview of the types of Cookies that can be used in an online environment. Depending on their owner, Cookies can be classified into:
The. Own cookies: These are those that are sent to the user's computer or device from a device or domain managed by the publisher and from which the platform or service requested by the user is offered.
B. Third-party cookies: These are those that are sent to the user's computer or device from a device or domain that is not managed by the publisher, but by another entity that processes the data obtained through cookies.

Depending on their purpose, Cookies can be classified into:

The. Strictly necessary (technical) cookies: These are those that allow the user to navigate through a website, platform or application and use the different options or services that exist on them, such as, for example, controlling traffic, identifying data or the session, accessing to restricted access sections or content, remembering the elements of an order, carrying out the process of purchasing an order, managing payments, controlling fraud related to the security of the service, using security elements while browsing, requesting registration or participation in a event, storing content for video or sound broadcasting, enabling dynamic content (for example, loading animation of a text or image) or sharing content via social networks. Technical cookies, being strictly necessary, are downloaded by default when they allow you to show the platform or provide the service requested by the user.
 B. Functionality or personalization cookies: These are those that allow you to remember information so that the user can access the service or the platform with certain characteristics that can differentiate their experience from that of other users, such as, for example, the language, the number of results a show when the user makes a search, the appearance or content of the service depending on the type of browser used by the user or the region from which he accesses the service, etc. Failure to accept these Cookies may lead to slow website performance or poorly tailored recommendations.
ç. Analysis cookies: These are those that allow you to quantify the number of users, the sections visited on the platform and the way they interact with it, in order to carry out the measurement and statistical analysis of the use made by users, in order to introduce improvements in function of the analysis of the usage data of the users of the platform or service.
d. Behavioral advertising cookies: These are those that store information on the behavior of users, obtained through the continuous observation of their browsing habits, which allows the development of a specific profile to display advertising based on it. These cookies allow the management, as efficiently as possible, of advertising spaces that, if applicable, have been included directly by the publisher or in collaboration with third parties.

What are Cookies used for on our Platform?

Cookies are an essential part of how our Platform works. The main purpose of our Cookies is to make your browsing experience more convenient and efficient. For example, they are used to remember your preferences (language, country, etc.) during browsing and on future visits. We also use our Cookies to continually improve our services and the Platform, as well as to be able to offer you personalized advertising, according to your browsing habits. The information collected in Cookies also allows us to improve our Platform through estimates on statistical data and usage patterns (number of visits, most visited sections, visit time, etc.), to know statistically how users interact with the Platform for the improvement of our services, as well as the adaptation of the Platform to your individual interests, the acceleration of researches, etc. Occasionally, we may use Cookies to obtain information that allows us to display, from our Platform, third-party platforms, or by any other means, advertising based on the analysis of your browsing habits (visited products, consulted sections, etc.). In any case, in the Cookies we use, we never store sensitive information such as passwords, credit or debit card data, etc.

How can I manage the use of Cookies on this Platform?

In the Cookies configuration panel, accessible at all times on our Platform, you can obtain all the information about the Cookies used by this Platform, together with information about the purpose, duration and management (own or by third parties) of each of them , so you can manage the activation and deactivation of the use

Cookies that are not strictly necessary for the functioning of the Platform. Alternatively, if you are browsing the internet, you can disable the use of Cookies in your browser. We show you how to do this in the most popular browsers:

 • Google Chrome
• Internet Explorer
• Mozilla Firefox
 • Safari

This possibility to avoid the use of Cookies can be carried out at any time. Please note that both your management of the Cookies configuration panel and your option to refuse Cookies is specific to each browser you are using. Therefore, if you choose to set Cookies in a way on one device and you want your option to apply in a similar way to another device, you must enable the same option for that other device. Additionally, in relation to third-party Cookies for the purpose of providing interest-based advertising, you should note that certain third parties may be members of any of the following online behavioral advertising self-regulation programs, with the corresponding voluntary opt-out options:
 • Network Advertising Initiative (NAI) - http://www.networkadvertising.org/choices/
• Google Analytics - https://tools.google.com/dlpage/gaoptout

Who uses the information stored in Cookies?

The information stored in the Cookies on our Platform is used exclusively by us, with the exception of Cookies identified in section 2 as "Third Party Cookies", which are used and managed by external entities to provide us with services for the purpose of improving our services and the user experience when browsing our Platform. More information on the Cookies configuration panel, accessible at all times on our Platform. For more detailed information about the treatment of your personal data in our collaboration with third parties and those who are subject to international data transfers, you should read our Privacy Policy, accessible on our Platform, and the privacy policies / privacy settings of these third party collaborators, accessible through their platforms.