PRIVACY AND COOKIE POLICY

Who is responsible for processing your data?

ISALORI, with tax identification number NL005425178B70, is responsible for processing the personal data collected and processed on our platforms (where platforms refer to the use of the website as well as data resulting from your relationship with ISALORI). You can contact us via the following means:

Postal address: Oderweg 1 Unit 2920, 1043 AG Amsterdam
Phone 0620646421
Email: info@isalori.com

ISALORI has appointed a Data Protection Officer whom you can contact and/or report any issue related to the processing of your personal data by sending an email to info@isalori.com.

What type of personal data does ISA LORI collect and process?

ISALORI may directly collect the following data and/or categories of data from your relationship and use of our services: i) identification and contact data; ii) data about personal characteristics; iii) economic data such as credit card (PAN+CVV2) in accordance with PCI DSS standards, which will be used for payment processing if you purchase one of our items or, in case of returns for transfers, the account number to which we should process the refund of your purchase; iv) data observed during the purchase of our products and the consumption habits and preferences of our customers; v) data about the use of ISALORI's platforms.

For what purpose do we process your personal data and what is the legal basis?

The purposes for which ISA LORI may process your personal data are as follows:

A) CREATION OF A USER ACCOUNT

Managing your registration will lead to the creation of an ISA LORI user account. This account allows you to centralize all queries related to your user status and gives you access to certain features available and reserved for this consideration. For example, a user account allows you to save certain information that can be used for future purchases and/or interactions with ISALORI.
The legal basis justifying the processing of your data for this purpose is the performance of a contract, which includes the accepted terms of sale.
When creating an account, the processing of your data is necessary to fulfill the obligations and rights stipulated in the terms of sale.

B) PURCHASE OF ISA LORI PRODUCTS

Processing the purchase of items through the various purchase channels enabled by ISALORI. This settlement involves performing all appropriate actions to manage your purchase and, if applicable, ensure the correct delivery of your order, as well as performing any management related to the sale of the item, such as managing and issuing documents that accredit the purchase, such as the simplified electronic invoice, the receipt or Tax Free voucher, and, if applicable, handling the return of items.

To this end, we may send you information about the status of the purchase via email, SMS message, and/or any other channel available at any time.

The legal basis justifying the processing of your data for this purpose is the performance of a contract, which includes the terms of sale accepted upon purchase of the items. The processing of your data is necessary to ensure compliance with the obligations and rights provided in the terms of sale.

Management of the ISALORI gift card.
- The legal basis justifying the processing of your data for this purpose is the performance of a contract, which includes the terms of use accepted at the time of card purchase. The processing of your data is necessary to comply with the obligations and rights provided in the terms of use.

In connection with the processing of the online order, ISALORI, as the data controller, will take appropriate actions for the prevention, detection, and combating of abuse and fraud in the use of our services, for which automated decisions may be made.

These automated decisions involve analyzing behaviors during the payment process, generally using data from the purchase process and the history of purchases made, to determine whether the transaction can be considered fraudulent. This information allows us to detect and attempt to prevent fraudulent behavior in payment transactions, which may lead to order rejections and thus protect both you and the interested party (in case of phishing), or ISALORI as a service provider and responsible party.

The processing of your data to achieve this purpose is justified by the legitimate interest of ISALORI to analyze all transactions occurring in the payment process of the products it markets to ensure that no economic fraud takes place that could have a negative reputation for itself or its customers. In this sense, we believe that there is also a general interest insofar as the processing contributes to generating, improving, and maintaining public confidence in economic relations conducted through the payment methods offered by ISALORI in its online shop to prevent them from being suspected due to fraud or fraudulent activities.
We hereby inform you that ISALORI has compelling legitimate grounds in this case that allow the processing of your data for this purpose and that ISALORI cannot respond to your right to object in accordance with the provisions of Article 21.1 of the General Data Protection Regulation.
You can obtain more information about this assessment by requesting it directly from our Data Protection Officer.

If you are registered as a user and order one of our items through our platforms, we may perform the following processing:
- Save your credit card details so they can be used for future purchases.
  - The legal basis justifying the processing of your data is the express consent you have given, in the sense that we store this information so that it can be used for future purchases, without prejudice to the fact that the use of your credit card data is justified within the framework of the performance of a contract in accordance with what has been discussed in the previous point. This consent can be withdrawn at any time without the withdrawal affecting the lawfulness of processing based on consent before its withdrawal.

C) SHAPING YOUR RELATIONSHIP WITH ISA LORI AS A BRAND

Newsletter: management and sending of commercial information about exclusive offers and the latest articles tailored to your profile, sending of posts via digital platforms and messages related to clothing and accessories still in your shopping bag via email, SMS message, letter, or any other communication channel and/or digital platform. This also includes promotional activities, such as managing contests or raffles organized by ISALORI. If you agree to receive commercial messages through different channels, certain personal data may be used to personalize communication in digital media.
- The legal basis justifying the processing of your data is the express consent you have given and which can be withdrawn at any time without the withdrawal affecting the lawfulness of processing based on consent before its withdrawal.

Management of the notification service regarding the availability of clothing and accessories on our platforms.
- The legal basis justifying the processing of your data for this purpose is the express consent you have given and which can be withdrawn at any time without the withdrawal affecting the lawfulness of processing based on consent before its withdrawal.

Responding to the exercise of rights recognized in data protection regulations.
- The legal basis justifying the processing of your data is the compliance with a legal obligation regarding the management of the exercise of rights in accordance with the obligation stipulated in the General Data Protection Regulation.

Handling questions, requests, and any complaints you make or submit through customer service contact channels.
- Depending on the reason why you contact ISALORI, the legal basis justifying the processing of your data may differ. In this sense:
  - We believe that ISALORI has a legitimate interest in correctly resolving and handling the suggestions, questions, or requests you submit through the channels provided by customer service. This is understood that your rights and/or freedoms are in no way affected or prejudiced by the fact that the request you have submitted is responded to.
  - If we handle questions related to an order that need to be brought to attention for the formalization of the purchase, the processing of your data is justified by the performance of a contract, which includes the terms of sale.
  - If your data is processed for the handling of a complaint submitted through the channels provided by customer service, your data is processed to comply with a legal obligation stipulated in consumer protection law.

After the provision of one of our services, sending quality surveys aimed at finding out your opinion and your level of satisfaction with your relationship with ISALORI. Based on the information provided by the survey, we can develop and improve our services and procedures, which is of great importance to us to gain experience.

Creation of profiles based on behavioral and usage data collected through your browsing, your interactions with the brand, and data derived from your purchase history to prioritize showing you recommendations or content on our platform, depending on your preferences, and to send you commercial messages tailored to your profile, as long as you have given us permission for this.
- Taking into account the characteristics of profiling and after the corresponding assessment of your interests as a data subject, as well as ISALORI as the controller, it has been established that the legal basis justifying the processing of your data is the legitimate interest, as it is considered to be in the interest of all involved parties that items that may be of interest to the consumer are shown with priority. In this way, by prioritizing the display of items that may reflect the user's priorities, ISALORI can offer you a higher quality service and a much more positive user experience. At the same time, ISALORI's reputation benefits from users having a good experience browsing and shopping on our platforms.

Taking into account the characteristics of profiling and after the corresponding assessment of your interests as a data subject, as well as ISALORI as the controller, it has been established that the legal basis justifying the processing of your data for creating your consumer profile to send you commercial messages tailored to the interests, tastes, and preferences of consumers is the legitimate interest, as it is considered to be in the interest of all involved parties that commercial messages tailored to your profile are sent to you. The fact that ISALORI is able to tailor commercial messages to the user's profile ensures that ISALORI can offer you a higher quality service, as you will only receive messages whose content may be of interest to you. This way, you will not receive generic messages that could be excessive or unattractive to the parties involved. This increases your level of satisfaction, and ISALORI simultaneously benefits, as it allows the company to send more effective commercial messages. This can attract new customers, increase the loyalty of existing customers, and improve the company's image.

The profiling algorithm does not make recommendations on actions to be taken (neither at segment level nor at individual level) nor does it apply automated decisions, but is limited to analyzing behavioral and consumption data of customers and potential customers to learn about their interests, tastes and preferences and to infer the behavior of the interested party in the future. Based on this information, a marketing manager decides on the best strategy for that segment, customer or potential customer.

You can obtain more information about the legitimate interest assessment by contacting our Data Protection Officer directly.

How long do we store your personal data?

To ensure that personal data are adequate, relevant, and limited to what is necessary for the purposes for which they are processed, ISALORI will only store your personal data for the period necessary to achieve the purpose for which they were collected. This takes into account the need to respond to problems that arise, resolve issues, make improvements, activate services, and comply with the requirements of applicable legislation. This means that your personal data may be retained for a reasonable period, even after you no longer use ISALORI's services or no longer use the website/app. After this period, your personal data will be blocked from all ISALORI systems, with the sole purpose of retaining and making them available to the competent authorities to comply with any administrative or judicial responsibilities and the exercise or substantiation of claims. After the period for blocking personal data has expired, they will be permanently deleted.

With whom do we share your personal data?

Your personal data may be shared with companies belonging to ISALORI for internal administrative purposes based on legitimate interest.

Your personal data will only be communicated to third parties in accordance with the legal obligations applicable in each case. This may happen, for example, to government services and/or public bodies when required by tax, labor, social security or other applicable legislation.

If you place an order through our platforms, your data may be disclosed, where applicable, to financial institutions and payment service providers, fraud detection and prevention organizations such as Signifyd, logistics, transport and delivery companies. These communications are strictly necessary for the delivery of your order.

We also inform you that ISALORI may enter into an agreement with third parties who have access to your data originating from the provision of services, after this relationship has been regulated. These third parties may provide us with technological services, customer service or marketing and advertising services, among others, and will in any case process your data according to ISA LORI's instructions and never for their own purposes.

ISALORI will under no circumstances sell your personal data to third parties.

International transfers

International data transfers may occur if the companies with whom ISALORI shares your data are located outside the European Economic Area, which will be lawful because adequate safeguards are in place to protect your personal data. In cases where the country for which the data is intended is not considered to have an adequate level, ISALORI will regulate the relationship with the third recipient of the data by signing the relevant standard contractual clauses adapted by the European Commission, the content of which can be consulted at the following link: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_enhttps://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc-en..

In any case, third parties with whom certain personal data are shared must demonstrate in advance that they have taken appropriate technical and organizational measures to ensure the proper protection of that data.

Data not collected directly from the data subject

For some of the services offered through our platforms, such as gift cards, a user may provide personal data about the recipient. In this case, ISALORI will also comply with its obligations in accordance with the provisions of the data protection regulation and use the data solely for the purpose for which they were provided to us.

How does ISA LORI protect your personal data?

Our platforms use data security techniques such as network and application firewalls, systems that protect against automated attacks, access control procedures, and cryptographic mechanisms. All of this is aimed at preventing unauthorized access to the data and ensuring its confidentiality. In addition, security checks are regularly performed for routine checks and risk assessments. To achieve these goals, you agree that ISALORI obtains data for the corresponding authentication of access controls.

Furthermore, every transaction carried out through our platforms is executed through secure payment systems. The confidential payment data is transmitted directly and encrypted to the relevant institution.

ISA LORI declares that the company has taken all necessary technical and organizational measures to guarantee the security and integrity of the personal data it processes and to prevent its loss, alteration and/or unauthorized access by third parties.

What are your rights regarding your personal data?

You have the rights listed below. You can exercise these rights via the email address info@isalori.com. To process your request to exercise your rights, we may ask you to provide proof of your identity.

Right of access	You have the right to obtain confirmation as to whether or not ISALORI is processing personal data concerning you and to access the personal data ISALORI holds about you.
Right to rectification	You have the right to request ISALORI to correct personal data when it is inaccurate or incomplete. If you have a user account, you must correct your data directly through the 'My data' section of your profile.
Right to erasure	You can request us to delete personal data when, among other things, they are no longer necessary for the purposes for which they were collected.
Right to restriction	You have the right to request the restriction of the processing of your data. In this case, we will only keep them for the exercise or defense of legal claims.
Right to portability	You have the right to receive your personal data in a structured, commonly used and machine-readable format and to transmit them to another controller if the processing of your data is based on consent or derived from the performance of a contract, provided that this is carried out by automated means.
Right to object	You can object to the processing of your personal data based on the public or legitimate interest pursued by ISA LORI, including profiling. In such a case, ISALORI will no longer process the data, unless there are compelling legitimate grounds or if they are necessary for the exercise or defense of possible legal claims. You also have the right to object to the processing of data for direct marketing purposes.
Automated individual decision-making	Where applicable, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. However, it is not possible to exercise this right if the decision is necessary for entering into, or performance of, a contract between you and ISALORI; is authorized by law applicable to ISALORI, provided that it lays down suitable measures to safeguard your rights, freedoms and legitimate interests; or is based on your explicit consent.
Right to lodge a complaint	You have the right to lodge a complaint with the competent local supervisory authority, which in the Netherlands is the Dutch Data Protection Authority (https://www.autoriteitpersoonsgegevens.nl/).

Changes to the Privacy Policy?

This privacy policy will always be available. However, if we make significant and relevant changes to its content, we will notify you through our platforms or via your email address, to comply with the GDPR's information obligation. This way, you can exercise your rights as a data subject if you wish.

Cookie Policy

The user commits to the proper use of the website's content. They are obliged to (i) provide truthful and accurate information about the data requested in the registration or order form and to keep it updated each time they use the website; (ii) not engage in activities that are unlawful, illegal, or contrary to good faith or public order; (iii) not disseminate racist, xenophobic, discriminatory advertising or propaganda based on race, gender, ideology, or religion, or that in any other way infringes on morality, public order, fundamental rights, civil liberties, honor, privacy, or the image of third parties and, in general, valid legislation; (iv) not cause damage to the physical and logical systems of the website, ISALORI's suppliers, or third parties, or introduce or spread computer viruses on the internet or other physical or logical systems susceptible to causing the aforementioned damage; (v) not use the website's content or the information on it to advertise or send messages for another commercial purpose, nor to collect or store personal data of third parties; (vi) not attempt to access and, if applicable, use email accounts of other users or manipulate their messages.

ISALORI reserves the right to apply appropriate changes to its website without prior notice. In doing so, the company may change, remove, or add both the content and services provided through the website, as well as the way these are presented and located on the portal.

What are cookies and how are they used?

All intellectual and industrial property rights of the website and its content, including but not limited to photos, sound, audio, video, designs, texts, graphics, logos, icons, color combinations, structure, buttons, as well as software, trade names, brands, works, illustrations, photos or industrial drawings and any other sign susceptible of industrial and commercial use are the property of ISALORI or of legitimate third parties who have expressly authorized their publication on the website.

Reproduction, distribution, and public communication, including making available all or part of the website's content for commercial purposes, on any medium or by any technical means, without ISALORI's consent, is expressly prohibited.

The user undertakes to respect ISALORI's intellectual and industrial property rights. The user may use the website and its content for personal and private use. Any other use is prohibited and requires ISALORI's express prior written consent. The user may not delete, alter, circumvent or manipulate any security systems installed on the website.

What are the cookies on our website NOT used for?

ISALORI is in no case liable for damages of any kind that may be caused by, but not limited to: errors or omissions in the content, lack of availability of the portal or the transmission of viruses or malicious or harmful programs in the content, despite having taken all necessary technological measures to prevent this.

It is possible that the customer's website refers to the content of third-party websites. Since the provider cannot always control the content entered by third parties on their websites, the provider accepts no liability with regard to such content. In any case, the provider declares that he will immediately remove any content that could violate national or international law, morality or public order, immediately withdrawing the referral to this website and informing the competent authorities of the content concerned.

ISALORI is not responsible for the information and content stored, including but not limited to, in forums, chats, blog generators, comments, social media or any other medium that allows third parties to independently publish content on the website. Nevertheless, ISALORI makes itself available to all users, authorities and security services and actively cooperates in the removal or, if applicable, blocking of all content that could affect or violate national or international law, the rights of third parties or morality and public order. If the user believes that there is content on the website that qualifies for this classification, they are requested to immediately notify the website administrator.

The website has been checked and tested for its proper functioning. In principle, it can be guaranteed that it works properly 24 hours a day, 7 days a week, all year round. However, ISA LORI does not exclude the existence of certain programming errors, nor the occurrence of force majeure, natural disasters, strikes or similar circumstances that make access to the website impossible.

It is forbidden to include hyperlinks for commercial purposes on websites that do not belong to ISALORI and that allow access to the website, without prior permission from ISALORI. ISALORI is not responsible for the use or content of third-party websites that may link to isalori.com.

Who uses the data stored in the cookies?

The information stored in the website's cookies is used by ISALORI, with VAT number: NL005425178B70

Postal code: 1043 AG
E-mail: info@isalori.com

What types of cookies does ISA LORI use?

Cookies are files installed on the user's computer, smartphone, tablet or any other device to record their activities during the time they browse this website and/or mobile app of ISA LORI (hereinafter referred to as "website/app"). By using cookies, the server where the website/app is located can recognise the web browser used by the user. For example, registered users can access parts and services of the website without having to log in again each time they visit, and their preferences for language, country, etc. are remembered for future visits. Cookies are also used to measure the number of visitors and traffic parameters, and to monitor progress and the number of entries.

How to disable cookies on all major browsers

We do not store sensitive identifiable personal data such as your address, password, etc. in the cookies we use.

Retention periods

The information stored in the cookies of the website/app is used by ISALORI, with VAT number NL005425178B70

Postal address: Odeweg 1 unit 2920, Amsterdam
Postal code 1043 AG
E-mail: info@isalori.com

Data transfers to third countries

Below you will find the types of cookies used on the ISALORI website/app, depending on their purpose and the entity that manages them (own cookies or third-party cookies).

Purpose	Description
Performance cookies	These are cookies that allow us to count the number of visitors to the website/app and traffic sources, quantify the number of users, and thus perform the measurement and statistical analysis of how users use it.
Functional cookies	These are cookies that allow the user to access the service with certain general characteristics that are predefined based on a series of criteria, such as the language, the type of browser used to access the service, the regional configuration from which the service is accessed, etc.
Strictly necessary cookies	These are cookies that are strictly necessary for browsing and the proper functioning of our website/app. These can, for example, control traffic and data communication, access restricted areas, carry out the ordering process, use security elements, store content for displaying videos or sounds, or share content via social media.
Targeted cookies	These are cookies that store information about users' browsing behaviour while they browse the website/app to show them advertisements related to their browsing profile.
Social media cookies	These are cookies set by a series of social media services that we have added to the website to enable you to share our content with your friends and networks.

Management
Own cookies	These are cookies created and managed by ISALORI itself, as the party responsible for the website/app.
Third-party cookies	These are cookies managed by service providers not affiliated with ISALORI. The third parties are listed in the "Set cookies" screen.

How to manage your consent preferences

You can allow, block, or delete the cookies installed on your computer by configuring your internet browser options. If you block them, some services that require their use may not be available to you.

Below you will find links to information on how to activate your preferences in the main browsers: