Politique de confidentialité

Information on Data Protection

Responsible for processing: TOPMODEL CLUB S.L. (hereinafter TOPMODEL)

Purposes of processing:

  • Informative web page.
  • Execution of the purchase contract.
  • Manage the registration and access to the private area of Topmodel.
  • Sending promotions.
  • Management of queries, requests and/or requests through the Customer Service channels.
  • Management of personnel selection processes.

Legitimacy of the treatment

  • Express consent of the data subject.
  • Execution of a contract or application of pre-contractual measures.
  • Legitimate interest for data processing.
  • Fulfillment of legal obligations.

Retention of data

The data will be kept for the time strictly necessary to fulfill the collected purposes; as long as the interested party does not revoke his consent, as well as for the fulfillment of legal obligations.

Recipients

Personal data collected through the website will not be transferred to third parties. Without prejudice to those third parties that provide services to Topmodel Club S.L., its subsidiaries or franchises, for the purpose of managing the sale of Topmodel products, the contractual and/or pre-contractual relationship with the interested parties or to process requests made by them.

Rights of the interested parties

Access, rectify and delete data, as well as other rights, as explained in the additional information.

Additional information

You can consult the additional and detailed information on Data Protection in the attached clauses below.

Topmodel Club S.L., committed to transparency and legality in the processing of the personal data of its customers and/or users, informs you that it processes your personal data in accordance with the provisions of REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter "GDPR").

Who is responsible for the processing of your personal data?

Topmodel Club S.L., markets its products in Spain under the trademark Topmodel. Therefore, the personal data that you have provided us through any of the domains of Topmodel's website, its social networks or through any other communications maintained with you will be subject to the Register of Processing Activities of responsibility of Topmodel Club S.L.

What is your presence in social networks?

Topmodel Club S.L., has the following profiles on the main social networks on the Internet (Youtube, Instagram, Snapchat and Facebook).

Topmodel Club S.L. is recognized as responsible for the processing of data of its users, followers, or people who make comments through them. Also, Topmodel Club S.L. disclaims any liability for comments from users and followers on their social networks.

Topmodel Club S.L., may use the profiles described above to inform its users of topics it considers of interest.

What personal data do we collect?

The personal data that the user can provide:

  • Identification data: Name and surname, date of birth.
  • Contact information: E-mail address, postal address, telephone number.
  • Financial and transactional information: Payment or card details, information about your purchases, orders and/or returns.
  • Connection and navigation data: Language, country from which you interact with us, etc.
  • Academic and employment data.
  • Images.
  • Information about your tastes and preferences.

The completion of certain data is mandatory in order to enter into a purchase contract with us. Failure to provide the requested personal data or not accepting this data protection policy means the impossibility of purchasing our products.

Why and for what purpose do we process your data?

Depending on the purposes we will need to treat some data or others, which in general will be, depending on the case, the following:

  • The website is entirely informative about the products offered by Topmodel Club S.L..
  • The collection and automated processing of data through the website will be done to collect all the data necessary to contract with us, and depending on the circumstances, to enjoy services and / or exclusive promotions for members of the loyalty program Partners in Crime or Invite a Friend program.
  • To manage eventual selection processes through the "Work with us" section.
  • For commercial and marketing purposes, in order to manage subscriptions, send personalized information, show you advertising of your interest through the Internet and, in general, offer recommendations based on your interaction with us.
  • For analytical and statistical purposes on navigation, accessibility and user experience of the website.

We inform that the personal data obtained as a result of the formalization of the contract of sale of Topmodel products, as well as any other data entered by you to access the services and / or exclusive promotions of Topmodel will be part of a Register of Activities and Processing operations (RAT), which will be updated periodically in accordance with the provisions of the applicable regulations and that all appropriate security measures have been taken in this regard.

The user is informed of the possibility of withdrawing consent in the event that consent has been granted for any specific purpose, without affecting the lawfulness of the processing based on consent prior to its withdrawal.

What is the legitimacy for the processing of your data?

The processing of your data may be based on the following legal bases:

  • Express consent by users when contacting us through electronic means by any of the channels provided for this purpose. We may contact you via email, telephone calls, sending SMS or other equivalent electronic means of communication in relation to products, updates, incidents or informative communications related to the functionality of our website.
  • Necessary for the execution of the purchase contract with us. The personal data you provide will be processed in order to identify you as a user on our website and manage the development, implementation and execution of the contract of sale of the products you have purchased. The data will be kept as long as our business relationship is maintained, and once concluded, will be kept blocked for a period of 4 years to address potential claims. The legal basis for the processing of this data is the fulfillment of the contractual obligations you assume when purchasing our products.
  • Express consent in relation to the sending of communications when subscribing to any of our loyalty programs. So that we can inform you about the advantages of belonging to our Clubs such as: accumulate points for purchases made, enjoy free arrangements in seasonal clothing, be informed of events (own and third parties) as well as scoops, promotions, congratulations and personalized details according to your tastes. The non-acceptance of this purpose means that you will not be able to enjoy these advantages. The personal data provided will be kept as long as you do not ask us to unsubscribe, since until then we will understand that you are still interested in belonging to the club.
  • Express consent to send commercial communications about products and news and for the generation of user profiles. Your personal data may also be processed for the purpose of generating user profiles, (for this we will use segmentation procedures based on gender, interests or purchasing behavior) and to send you, by electronic, postal and telephone (including SMS alerts, or other similar means of messaging) personalized commercial information that may be of interest about products or services related to those offered by Topmodel Club S.L. or any of its subsidiaries or franchises as long as you have given your consent by checking the box to subscribe to our newsletters. The legal basis for the processing of data for this purpose is the consent you give us by checking the corresponding subscription box, so it is necessary to check the authorization box if you want us to process your data for this purpose.
  • Fulfillment of legal obligations for fraud prevention, communication with Public Authorities and third party claims.

How long do we keep your data?

The processing of data for the purposes described will be kept for the time necessary to fulfill the purpose of its collection, as well as for compliance with legal obligations arising from the processing of data. Notwithstanding that the conservation is necessary for the formulation, exercise or defense of potential claims and / or whenever permitted by applicable law.

Topmodel Club S.L. undertakes to cease the processing of personal data when the retention period has expired, as well as duly block them in our databases.

You can object to the processing of your data for commercial purposes, by sending an email to the address: dataprotection@Topmodel.club You can also request to UNSUBSCRIBE from commercial communications through a link that appears in each newsletter you receive. Once the cancellation of your data has been requested, they will be blocked for a period of 3 years, available only to Public Administrations, Courts and Tribunals for possible claims, after which the data will be deleted.

To which recipients is your data communicated?

In general, Topmodel Club S.L. will not transfer personal data to third parties, except in those situations where the same may be transferred to other subsidiaries or franchises of the Topmodel Club group, or other collaborators that provide services to the group, in order to manage the provision of services, the contractual and/or pre-contractual relationship with the interested parties or to process requests made by them.

Both Topmodel Club S.L., as well as its subsidiaries and franchises, endeavor to guarantee the security of personal data when it is sent outside the company and ensure that third party service providers respect confidentiality and have adequate measures in place to protect personal data. These third parties are obliged to ensure that the information is handled in accordance with European data privacy regulations. In some cases, personal data may be required by law to be disclosed to public bodies or other parties, only what is strictly necessary for the fulfillment of such legal obligations will be disclosed.

Where is your data stored?

In general, the data is stored within the European Union (Madrid) in ERP.

What rights do you have and how can you exercise them?

You can send your communications and exercise your rights by means of a written communication to the following email address: dataprotection@Topmodel.club

Under the provisions of the regulations on data protection you can request:

  • Right of access: you can request information about the personal data we have about you.
  • Right of rectification: you can communicate any change in your personal data.
  • Right of deletion and oblivion: you can request the deletion after blocking of personal data.
  • Right to limit processing: this means restricting the processing of personal data.
  • Right of opposition: you can withdraw your consent to the processing of data, opposing further processing.
  • Right to portability: in some cases, you may request a copy of the personal data in a structured, commonly used and machine-readable format for transmission to another controller.
  • Right not to be subject to individualized decisions: you may request not to be subject to decisions based solely on automated processing, including profiling, that produce legal effects or significantly affect the data subject.
  • In some cases, your request may be refused if you request deletion of data necessary to comply with legal obligations. Also, if you have a complaint about the processing of your data, you can lodge a complaint with the data protection authority.

Who is responsible for the accuracy and veracity of the data provided?

The user is solely responsible for the veracity and accuracy of the data communicated to the company, exonerating Topmodel Club S.L. of any responsibility in this regard. Users guarantee and respond, in any case, the accuracy, validity and authenticity of the personal data provided, and undertake to keep them updated. The user agrees to provide complete and correct information. Neither Topmodel Club S.L. nor any of its subsidiaries and/or franchises are responsible for the veracity of the information that is not of their own elaboration and of which another source is indicated, so neither assumes any responsibility for hypothetical damages that may arise from the use of such information.

What security measures do we apply to protect your personal data?

Both Topmodel Club S.L. and its subsidiaries and franchises have adopted the security levels of protection of personal data legally required, and tries to install those additional technical means or measures at its disposal to prevent the loss, misuse, alteration, unauthorized access and theft of personal data provided to Topmodel Club S.L.

How do we use cookies?

The websites and RRSS of Topmodel Club S.L. use cookies, for the purpose of optimizing and customizing your navigation through it. Cookies are physical information files that are hosted on the user's own terminal, the information collected through cookies is used to facilitate user navigation through the portal and optimize the browsing experience. The data collected through cookies can be shared with the creators of the same, but in no case the information obtained by them will be associated with personal data or data that can identify the user. However, if the user does not want cookies to be installed on your hard drive, you can configure your browser to prevent the installation of these files. For more information, please see our Cookie Policy.

Internal security policy

Security breaches can be caused by employees, third parties or computer errors. We are therefore legally obliged to notify data subjects if their personal data has been seriously compromised within 72 hours. In addition, users will be notified as soon as the security breach is resolved.

Modification of the privacy policy

This privacy policy is subject to change. We recommend that you review the privacy policy from time to time.