1. NICOL SPOSA AND THE USER OR CUSTOMER
Personal data supplied by the User or Customer will be processed by:
The company Nicol Sposa, S.L.U. (hereinafter “Nicol Sposa”), incorporated in accordance with Spanish law, with offices at Polígono Industrial Mas Mateu, s/n., 08820 El Prat de Llobregat (Barcelona) holder of Tax Identification Code number B-63523609 and owner of the website www.verawangbride.com (hereinafter the “Website”). Hence Nicol Sposa is the controller of the Website.
Nicol Sposa is part of the international corporate group Nicol Sposa, which includes all those companies affiliated under its various brands, among others: “White One”, “Nicol Sposa”, “St. Patrick” and “La Sposa”, companies that you can consult at any time at [see link].
Accessing the Website, using any channel of communications with us, or visiting a store, are some of the ways to acquire the status of User or Customer (hereinafter the “Customer”).
2. WHAT DATA DOES NICOL SPOSA GATHER FROM USERS AND PROCESS?
• Newsletter registration form.
• User account.
• Appointment booking.
• Payment for appointment.
• Registration for events and/or presentations.
• Participation in competitions, draws or promotions.
• Participation in web surveys or satisfaction surveys.
• Adding products to “My favourites”.
• Chat online.
• Visit to store.
• Processing of data in third party applications.
• Social media interactions, including requesting permission to use your content and interactions.
• Providing us with pictures and information about your wedding via our website Real Brides’ photographs and wedding information page.
Each time we gather data from our Customers by any of the above channels a Customer account is created. This account covers all services of Nicol Sposa and contains all information concerning the interaction of Nicol Sposa with our customers.
Our website also provides spaces for requesting information on our business partners, and the possibility of job seekers entering staff selection processes both for offices and stores.
For these reasons we set out below the type of information we may gather at different times:
• Personal and contact information.
We gather, store and process all personal information and contact details you supply us with when you log on to the Website, when you visit a Nicol Sposa store or when you contact Nicol Sposa for any reason (asking for an appointment, registering for an event or even making a claim, contacting customer service or contacting us by way of chat online).
The personal and contact data we gather is that requested in the various contact, registration or user profile forms, etc. such as, for example, full name, address, address for deliveries, telephone numbers, email, date of event, etc. or any data Nicol Sposa requests in order to attend to and process any consultation or request you make of us.
Information on your devices and the use you make of the Website.
We gather, store and process information on the devices from which you access the Website (e.g. whether it is a mobile telephone or a pc, the operating system of the device you use to access the Website, your IP address, etc.) and on the Internet browser you use for this.
We also gather, store and process information on the use you make of the Website such as, for example, how you have reached the Website, which levels or sections of the Website you visit, what processes you have initiated and in what phase you have abandoned them, which websites you browse when you leave the Website, etc.
Generally we obtain this information by using Cookies, and its being processed will depend on whether you have accepted these. Further information is available in the Cookies Policy
Information on your interaction with Nicol Sposa and your preferences.
For us it is very important to know our Customers as it is in this way we can improve offering you products and services increasingly in line with your needs and preferences, improve our services and update or alter the Website. You will find further information on the profiles we prepare, based on all of this information, in the following section.
For this, and to process and handle any request or interaction you have with Nicol Sposa, we gather, store and process all information on your likes and preferences you provide on interacting with us. For example we will keep relevant information in telephone contacts, on using the Website, on booking an appointment, filling in the registration form in the Website, your adding our products to “My favourites”, taking part in surveys in the website or satisfaction surveys, choosing a language of preference, using customer service or chat online, and any data you voluntarily provide on visiting any Nicol Sposa store and which you agree to being processed for the purposes indicated at the time.
As a general rule the fields to be completed in the data gathering forms contained in the Website; answering the questions in any surveys you take part in; or completing your Customer profile, are voluntary. However in some cases there may be compulsory data (for example, an address if you make a purchase, or an email address if you agree to receive commercial mailings in this way) in which case you will be duly informed. Fields included in the forms and marked with an asterisk (*) are strictly necessary for dealing with your order or creating your Customer account, the inclusion of the other data being voluntary.
We also gather information which you publish and /or supply when you interact with Nicol Sposa outside the Website, for example in the blog or when you visit one of our stores, when you contact us by way of Telephone Customer Service or send us an email or letter. We may also process the information you publish or provide when you interact with platforms, forums, social networks, applications or websites in which Nicol Sposa has a presence (hereinafter “Forums and Social networks”). In this respect we inform you that, without prejudice to the respective policies and conditions of use and registration of these Forums and Social networks, when you interact with Nicol Sposa using these channels you authorise us to process the information you publish and/or provide for the compatible purposes indicated in each case, such as processing a claim or handling an enquiry or request.
Likewise in cases in which it is possible for the Customer to register or access the Website by way of a user account in a Forum or Social network, by using this option you authorise Nicol Sposa to gather and process information accessible in the user account of the Forum or Social network. These options are already configured by the Forums and Social Networks themselves and are offered as a service both to their users and to third parties to facilitate registration or access without the user having to enter his or her data or credentials. The data is transferred from the Forum or Social Network for the purposes referred to at the time and in accordance with the rules applicable in the Forum or Social Network, and respecting at all times the configuration the user has determined in them. We will keep you duly informed of the information we gather from Forums and Social Networks at the time of the request for data.
In some cases we may need to know your location when you use the Website, for example to book an appointment for you at your nearest store. Where Nicol Sposa wishes to know your location we will ask for your consent in advance, particularly if you have not activated the tracking function in the device from which you access the Website.
Contact, payment and billing information.
If you book an appointment in a country in which Nicol Sposa does not offer this service free of charge, Nicol Sposa will gather and process the information and personal data related to the method of payment you choose, bank details (gathered directly from the secure payment services platform Adyen NV, hereinafter “Adyen”. More information is available at https://www.adyen.com, contact details, billing information, etc.In the event that you contract the appointment service in a country where Nicol Sposa does not offer this service free of charge, Nicol Sposa may collect and process information and personal data related to the payment method you choose, bank details, contact details, billing details, etc.
Images and social media profile information
Information on business partners.’Real Brides’ photographs and wedding information
We have created a page on our website where our customers can upload photographs from their wedding and tell us the story behind their relationship and wedding by completing a number of fields and Pronovias may then choose to publish the photographs and information you provide us with. None of these fields are mandatory and no customers is in any way obliged to provide us with this information. Should you wish to, we will ask for your consent to process the data you have provided us with. If you provide us with any personal data that is related to someone else, we ask that you request permission and seek consent from them first. For example, your partner’s name or wedding photographer’s name. You can find the terms and conditions for this promotion here. Should there be other people in your image, we require that you ask them for consent in line with this policy and those terms before agreeing to our request. Please refer to section 7 below for more information on this.
You may withdraw your consent to the publication of your picture and processing of your information on your wedding at any time simply by sending an email to the email@example.com email address, or by postal mail addressed to PRONOVIAS, Calle Om, 16, Polígono Industrial Mas Mateu, s/n, 08820 El Prat de Llobregat (Barcelona), attaching in either case a copy of your personal identity documentation or passport and indicating “Ref. Data Protection” as reference on the envelope (in case of opting for postal mail) or in the subject line (if you opt for email), stating that you wish to revoke your consent to the publication of your picture and processing of your information on your wedding.
3. PREPARATION OF PROFILES
As stated above at Nicol Sposa we prepare profiles of the Customers who interact with us, creating a user or customer account containing all of the information gathered using the various data gathering channels both physical and online. The profile may be complete or incomplete depending on the type of interaction. We prepare these profiles on the basis of our legitimate business interests, which include knowing our customers and improving our services on the basis of their preferences and needs.
We set out below the various profile options depending on your relationship with us and any options you have selected:
3.1. Profile in store or customer service: We may ask you in our stores or by way of our telephone customer service to supply us with personal data, for reasons including maintaining a commercial relationship, providing personalised attention or handling bookings for appointments. For this we create a Customer file where we store all relevant information such as for example preferred styles of clothing, colours, whether you are interested in a wedding dress or a party dress, etc. This information helps us to adapt the service we provide and keep you informed of news or events in the stores you have visited (e.g. arrival of new collections or new colours, trunk shows or private sales, etc.), the store continuing direct mailing in addition to any information we send from Nicol Sposa (e.g. by email if you have consented to this).
And if you visit our stores we may send you satisfaction surveys both on the quality of the service received and on our products. This helps us to improve on a day-by-day basis. These satisfaction surveys may be sent electronically even if you have not agreed to receive commercial mailings, as it is not advertising, it is the best way we have of ensuring we have given you the best in-store service in line with the quality standards of the Pronovias Group, and we thus have a legitimate interest in processing your contact and mailing data for these purposes. If you think the service was inadequate we may contact you by telephone or any other means of mailing you have indicated to deal with any incident which may have occurred during your visit to the store.
3.2 Online profile: The new technologies allow us to prepare much more precise profiles analysing not just the preferences you expressed in our stores but also the following:
• Information provided on booking an appointment, e.g. the date of an event, including your wedding; the type of environment in which the event or your wedding will be held; your preferences on the shape or neckline of the dress; your budget for the dress;
• Information provided at the time of creating a user account, e.g. identification or contact data or your address;
• Purchases you have made by way of our online store, by which we can deduce your style and preferences;
• Behaviour in the web site (content you access, type of dresses visited, favourite colours, how often you visit the website …), which helps us to understand what you like;
• Behaviour in relation to our newsletter (what type of content makes you click or open the newsletter; how often you open our communications, );
• Relevant information based on the dresses you include in the “My favourites” section (type of dress, colours, and other characteristics which help us to understand your preferences in our products).
These profiles may be combined when you contact Nicol Sposa either by physical channels (visiting a store or customer service) or online via the website, app, social networks, etc.
3.3 Use of the information generated in user profiles: Any information we gather on our customers is used for various purposes which may be put in two main groups, (i) purposes relating to a personalised service adapted to our customers, and (ii) purely advertising purposes.
As regards personalised service knowing your preferences means that all of our stores can anticipate your needs and hence offer added value in our services. For example knowing your dress preferences means staff can not just show you dresses which match those preferences (e.g. long or short party dresses, with a particular neckline or colour, etc.), if you have booked an appointment they can make a prior selection of all the dresses or products which might match, including available sizes and colours. If you have a coming event, particularly in the case of your wedding, knowing the date means we can see the dresses available for fittings and the availability of sizes and types of dress.
The generating of these profiles also allows us to improve our advertising as we can personalise and adapt the content of our advertising to your interests, the type of advertsing we send you or the regularity with which we send it.
For example if we know of your interest in our new collections we will inform you each time they are presented and put on sale. And if you have shown an interest in our events, for example the presentation of new collections, we can invite you to them also taking into account your location and where the presentation is being held.
All contacts can be made both electronically, as stated above, and by telephone, both directly from Nicol Sposa by way of Customer Service and directly from the store, in order to inform you of the arrival of new dresses, confirm future visits or bookings or generally preserve our ties with you.
Personalisation of the content means we can ensure we send information which will be of interest to you. For example if we know you have a preference for long dresses we will prioritise news or promotions of this type of dress.
And depending on your interaction with us we can offer you special promotions, competitions or participation in events exclusively for customers.
In the following section on Mailings you can obtain further information on how we send mailings, the channels used and the platforms we work with to improve our advertising capacity.
All of the information contained in the Customer account, and therefore all information on your profile and preferences, is accessible by stores, which use it to improve the personalised service at the store. All data is at all times the property of Nicol Sposa, S.L.U., although the store, particularly in the case of franchises, may ask you for additional data for its own use during your visit to the store.
4. COMMERCIAL MAILINGS
At Nicol Sposa we will process the data you supply us with in order to send you commercial mailings where we have obtained your prior consent for this. If you give your consent we will send you information, advertising, surveys, invitations to events or promotions concerning products or services relating to the activity of Nicol Sposa. At the moment of data being gathered you may as a Customer decide whether or not you wish to receive this type of mailing from us, and you may always withdraw your consent at any time.
If you agree to us sending you commercial mailings electronically (email, SMS, instant messaging or social networks among others), you must bear in mind that all mailings sent by Nicol Sposa may be adapted and personalised according to your interests, either on the basis of the products and services you have ordered or for example any data we can deduce or obtain from your browsing habits, interest in particular content or reaction to our mailings, as explained in the section above “Preparation of Profiles”.
This personalisation is partially automated in the sense that Nicol Sposa determines the parameters of the personalisation but it is the technological platform which generates the Customer profile. As a general rule we do not send general mailings not segmented by way of this process as we think it is in the interests of both Nicol Sposa and our Customers to send and receive information which is relevant, and because not segmenting would not alter the number of mailings received, only their content. In this regard if you do not wish to be segmented for advertising purposes we would ask you not to subscribe to Nicol Sposa mailings or the Newsletter.
All newsletters and commercial mailings will be sent by NICOL SPOSA, S.L.U., including on behalf of other companies of the PRONOVIAS Group, as the company in charge of the Group’s advertising and communications.
The commercial mailings sent electronically referred to above may be sent by the following channels:
• Mailings by email, SMS or MMS o direct messaging (whatsapp, telegram, Facebook Messenger, direct messages in forum or social network applications, etc):
If we have the relevant information (email, mobile telephone number, etc.) we can send you commercial mailings by these means. As a general rule the channel of communication will be just email, wherever possible, although some messages may be sent by another of the means indicated (e.g. the sending of reminders, events or surveys).
• Commercial mailings in third party platforms (e.g. social networks):
Some third party platforms (i.e. websites, communities or applications, for example) allow other advertisers, such as Nicol Sposa, to use the platforms to advertise directly to Nicol Sposa customers who also have a user account in the platform.
For this the platform may require the advertiser (Nicol Sposa) to prove the identity of its Customers, providing basic identification data such as for example an email address or a telephone number in an encrypted form protected by way of tools provided by the platform itself.
Once the identity of the Customer and the existence of a user account in the platform have been established Nicol Sposa can create what is commonly known as a “personalised public” with those customers who have agreed to receive advertising in the platform, with Nicol Sposa advertising appearing directly in the user profile.
For example in social networks this type of activity can be found in Facebook (Custom Audience), Twitter (Personalised audiences) or Google (Customer Match).
The purpose of this activity is essentially one of advertising and hence your data is only used if you have agreed to receive our mailings.
These third party platforms may also allow advertisers such as Nicol Sposa to use their tools to identify users who, within their platform, have a “similar profile” to Nicol Sposa customers.
The procedure for identifying and proving the identity of customers is the same as above.
For example in social networks this type of activity can be found in Facebook (Lookalike Audience), Twitter (Personalised audiences) or in Google (Similar Audiences).
In this case, as the data is not used directly for advertising to our Customers, being aimed at persons who are not customers but have a profile similar to our customers, we will use the basic data of all of our Customers (and not just those who have agreed to receive advertising) to identify potential customers in the platform. In this way the advertising will be sent only to those potential customers who have given their consent to the platform in question for the sending of advertising. This processing is carried out on the basis of our legitimate interest in expanding our customer base, but you may object to your data being processed for these purposes at any time.
As stated above these services only ask for basic identification data, i.e. we do not supply all of your personal data, or any preferences we are aware of, we merely provide an email account or telephone number which is shared in encrypted form and protected by tools provided by the platforms themselves, sufficient for the social network to identify you in its database.
Secure communication techniques are also used, including the encryption of data before uploading it, to ensure the confidentiality and security of the information.
Finally we do not obtain data about you directly from these third party platforms, i.e. we may obtain anonymous and statistical information but never precise information on your interests or whether you have seen a particular advertisement, unless you interact with us or the particular advertisement.
If you do not wish us to use your data for advertising purposes in third party platforms you may contact us at the email and postal addresses given below. If we are already using it in these platforms we will erase it in the following update of the data supplied.
You may withdraw your consent to the sending of electronic commercial mailings at any time simply by following the instructions given at the foot of all electronic mailings sent by Nicol Sposa or by sending an email to the address firstname.lastname@example.org or writing to Polígono Industrial Mas Mateu, s/n., 08820 El Prat de Llobregat (Barcelona) enclosing in both cases a copy of your identity document or passport and indicating “Ref. Data protection” on the envelope (if you are using post) or in the reference field (if you are using email) and stating that you wish to withdraw your consent to the sending of electronic commercial mailings.
5. WHAT INFORMATION DO WE SHARE WITH THIRD PARTIES?
Your data will not be assigned, sold, hired out or in any other way made available to any third party, except for service providers of Nicol Sposa who provide certain services for us (for example the sending of the newsletter, marketing or customer service suppliers, data and database storage or handling, transport or logistics suppliers, Forums or Social Networks in which we advertise, etc.), but not for their own purposes. Our stores may also access the data but not use it without our consent or without following the instructions given by Nicol Sposa.
Notwithstanding this, Nicol Sposa inform you that if you acquire our products or order certain services by way of the Website (such as, for example, booking an appointment) it may be necessary to communicate all or part of your personal data to third parties in order to process the purchase or service, for example:
• your personal and contact data, which it may be necessary to send to the store where you have made the booking in order for them to contact you and conform the appointment, and inform you of any incident in relation to the same;
• your contact, address and delivery data, which it may be necessary to send to transport and messenger companies for them to be able to process the product purchases you make with us and deliver them to where you indicate; or
• your personal data and/or method of payment data, which are processed directly by the secure payment services platform Adyen, which processes it in its own name to process the transactions you carry out with us. This may include exchange of information with other companies and organisations for protection against fraud and reduction of credit risk.
In particular your data may be communicated or assigned to stores you are interested in using (e.g. attending events or booking an appointment), which may be operated by companies of the Pronovias Group in the case of own stores, or other companies (for example in the case of franchises or wholesalers managed by third parties). You will find the basic information on these third parties in the form. The third parties will only process your data to handle your enquiry, attendance at an event or appointment, although they may ask for your consent to additional processing.
In accordance with current regulations Nicol Sposa will only send the personal data of Customers which is strictly necessary, and the third parties receiving the same may only process your personal data to process the purchase of the product or service in question unless we expressly inform you of any additional processing.
• Standard clauses approved by the EU: These are contracts approved by the European regulator and which provide sufficient guarantees that the processing complies with the requirements laid down in the European Data Protection Regulation.
Other than in the circumstances referred to above or any others which are legally valid, Nicol Sposa will not disclose, assign, sell or hire out to third parties any personal information you supply to us by way of the Website, except where the disclosure is required by law, by court order or by the public authorities, and where we must communicate data logically indispensable for the supply of the service or where it is expressly requested and your express consent to communication to third parties is obtained in advance.
6. DURATION OF PROCESSING AND PRESERVATION OF DATA
As a general rule we process the data for the time necessary for the maintenance of the appropriate commercial relation.
For example your Customer Account will be preserved for a period of 5 years from your last interaction in Nicol Sposa, which includes use of our website, reading our electronic communications or visiting any of our stores.
If you have subscribed to our commercial mailings your personal data will be preserved until you cancel the subscription or you expressly request that your data not be used in third party platforms (being eliminated from the same), or we decide or ascertain by any means available in the technology of the time that our mailings do not interest you, for example because you do not browse the website or you do not open our emails.
Nicol Sposa will inform you of the preservation time of your data in the various forms in which personal data is requested, without prejudice to your data being preserved for a longer period duly anonymised for statistical or market research purposes, wherever possible or blocked to comply with legal obligations (for example the Consumer Protection Act and commercial or tax regulations may oblige us to preserve certain data for a specific period of time).
7. YOUR OBLIGATIONS AS A CUSTOMER
On sending your data to Nicol Sposa by any medium (by email, telephone, instant messaging applications, Forums and Social Networks or by way of any of the data gathering channels available in the Website), you undertake to Nicol Sposa that the data you are supplying corresponds to your true identity and that the said data is updated, truthful, accurate and complete at the time at which you supply it. You are solely responsible for the truthfulness, accuracy and completeness of the personal data you supply and hence you must inform Nicol Sposa as quickly as possible of any change or alteration of any personal data you have provided us with. Remember also that personal data is the property of each person, and it is thus totally prohibited to supply to Nicol Sposa any third party data or information without their prior consent (for example, if you give the address of a relative as the address for the delivery of an order you must tell them you are passing their data to Nicol Sposa, and that they can access this Policy in our website).
As a Customer you will be solely liable for any direct or indirect damage or loss caused to Nicol Sposa and/or third parties as a result of breach on your part of the obligation to provide truthful, accurate, complete and updated information corresponding to your true identity.
If you register on the Website remember your password is secret, personal and non-transferable and that you as the Customer are solely responsible for maintaining its confidentiality and secrecy. For this reason Nicol Sposa recommends you pay particular attention when entering your personal data, especially bank data, and that you do not share your registration code or password with third parties. Any damage or loss caused directly or indirectly to Nicol Sposa or to third parties under your password and registration code will be solely your responsibility.
8. YOUR RIGHTS AS A CUSTOMER
As a Customer you are entitled to access your information, to correct it if the data is incorrect, to object to the processing of your data, to erase it, restrict processing or request the portability of your data. You may also withdraw any consent previously given. Please bear in mind that if you exercise certain rights this may prevent the supply of a service which is pending, e.g. delivering a product to your home if you ask us to erase your data.
To exercise your rights of access, correction, erasure, restriction or portability in relation to any data you have supplied to any company of the Pronovias Group you just have to contact Nicol Sposa, which will centralise handling of the rights exercised in relation to the processing of your data, either by email at email@example.com or by writing to Polígono Industrial Mas Mateu, s/n., 08820 El Prat de Llobregat (Barcelona) enclosing in both cases a copy of your identity card or passport and indicating “Ref. Data protection” as a reference on the envelope (if you use post) or the reference field (if you use email) and clearly explaining the right you wish to exercise and the data necessary for such exercise.
9. DATA SECURITY
The Website contains the appropriate safeguards and uses technology based on the industry standards to improve the security, integrity, confidentiality, availability, exhaustiveness, accuracy and protection of the personal data it has compiled, and has taken reasonable precautions to protect this information from possible loss or misuse. The rules on data protection and security of Nicol Sposa are reviewed on a regular basis and improved where necessary, with reasonable measures being adopted to ensure that only authorised persons are able to access the information you supply.
If the form of payment you choose on making a purchase online in the Website is a credit or debit card, the charge will be made online, i.e. in real time, by way of the secure payment services platform Adyen. All information on confidential methods of payment sent to the Website is encrypted and, therefore, protected from third parties. Nicol Sposa will not have access to or preserve in any way the complete data of the method of payment used by the Customer.
This sensitive information is sent in encrypted form in order to protect the information you send us from unauthorised third parties. The security and confidentiality standards used by Nicol Sposa in purchases at the online store or registration are those normal in the industry, taking into account at all times the regulations applicable to card payments.
Despite this, although at Nicol Sposa we make an effort and use all means at our disposal to ensure the security, confidentiality, availability, inviolability and integrity of your data, Nicol Sposa is not able absolutely to guarantee technical security as a medium like the Internet is not impregnable and malicious actions on the part of third parties may occur which are beyond the control of Nicol Sposa.
10. COOKIES POLICY