PRIVACY AND COOKIE POLICY
PRIVACY AND COOKIE POLICY BRIEF OVERVIEW
WHO ARE WE. We are SLIDER, D.O.O. BELGRADE and chiccode.rs., and we process your personal data as joint controllers. This means that we are jointly responsible for the way we process and protect your data. See more.
FOR WHAT PURPOSE WE USE YOUR DATA. We use your information (collected online or in person) to, among other things, manage your registration as a user, manage your purchases of products or services, respond to your inquiries and, if you prefer, send you customized communications. See more.
WHY WE USE YOUR DATA. We have a legal basis for processing your data for various reasons. The main reason is that we need to process your data in order to perform the contract you accept with us when you register and make a purchase or use any of our services or features. We also use your information for other reasons, for example, to respond to your inquiries or to send you newsletters that you have requested from us. See more.
WHO WE SHARE YOUR DATA WITH We share your data with service providers who provide us with help or support, which are companies within the Inditex Group or independent service providers. See more.
YOUR RIGHTS. You have the right to access, correct or delete your personal data. In certain cases, you also have other rights, such as the right to object to our use of your data or the transfer of your data, as explained in detail below. See more.
We advise you to read our entire Privacy and Cookie Policy below to understand in detail how we use your personal data and your data rights.
BEFORE YOU START…
In this Privacy and Cookie Policy, you can find all important information regarding our use of personal data of our users and customers, regardless of the channels or means (online or live) you use to communicate with us.
If you would like to receive information about how we use cookies and similar means that may be installed on the devices of our customers and users, we recommend that you view the Cookie Policy.
We are transparent about what we do with your personal data, to help you understand what our use of your data entails, and the rights you have in relation to your data:
o We provide you with the availability of all information attached to this Privacy and Cookies Policy at all times, which you can check when you need, and in addition, you can also find additional information about how we use your data in your interaction with us.
There are certain provisions that we regularly use in this Privacy and Cookies Policy:
o When we talk about our Platform, we generally mean all channels
Our website.
Our Application, which includes both the mobile application you have installed on your device and others that we may use on our Platform.
In person at any of our physical stores.
WHO IS THE HANDLER OF YOUR DATA?
Your data controllers are:
SLIDER, D.O.O. BELGRADE, a company that is currently headquartered in Serbia and deals in the sale of CHICCODE (“CHICCODE”) brand products:
o Postal address: Bulevar Mihajla Pupina 10D/51 11070, Belgrade, Serbia. o Email address of the data protection officer: info@chiccode.rs
WHY DO WE PROCESS YOUR PERSONAL DATA?
Depending on the purpose for which we process your data from time to time, as explained below, we need to process one or another type of data, which will generally be as follows on a case-by-case basis:
your identification data (your name, surname, picture, email address, address, telephone, language and market from which you communicate with us, contact information, ID number or other document for tax reasons in the case of a refund.);
economic data and transaction data (your payment or card data, data about your purchases, orders, returns.);
connection, geolocation and/or browsing information (location data, device identification number or advertising ID.);
commercial information (if you have subscribed to our newsletter),
information about your style and preferences.
Please remember that when we ask you to enter personal data to provide you with access to any feature or service of the Platform, we will mark certain fields as required, as this is data that is necessary for us to be able to provide the service or to give you access to that feature. Please note that if you choose not to make that information available to us, you may not be able to complete your user registration or may not be able to use the services or features provided.
In special cases, a third party may provide us with information about you, using a feature or service available on the platform, for example in order to send you a gift card or deliver an order to your address. In such cases, we process only that information of yours that is essential to us for that feature or service, as set out in this Privacy and Cookie Policy.
In other cases, we may collect information passively because we may use tracking tools such as browser cookies and other similar technologies on our Platform and as part of communications with you.
Depending on how you interact with our Platform, ie. depending on the services, products or features you wish to use, we will process your personal data for the following purposes:
| PURPOSE | More information |
| 1. To manage your registration as a user of the Platform | If you choose to become a registered user of our Platform, we must process your data to identify you as a user of the Platform and to grant you access to its various features, products and services available to you as a registered user. You may cancel your Registered User account by contacting us through Customer Service. We hereby inform you that the data we collect about your activities, which are collected through the various channels of the Platform and include purchases, will remain associated with your account in order to enable unified access to all information. |
| 2. To develop and implement purchase or service contracts that you have entered into with Us on the Platform | This purpose includes the processing of your data mainly for the following reasons: To contact you to notify you of updates or informational notices related to contracted features, products or services, including quality surveys, and to determine customer satisfaction with the service provided. To manage the payment of the products you buy, regardless of the applied payment procedure. For example: If, when purchasing any of our products through the website or app, you choose to activate the function of saving your payment and shipping address information for future purchases, we must process the indicated data for the activation and development of the given function. Opting to activate this feature allows your auto-populated payment information to appear on subsequent purchases so you don’t have to enter it each time you process it, and the information provided is considered valid and effective for subsequent purchases. You can change or cancel your card payment information at any time through the payment information section, either through a registered user account on the Website or in the My Account section of the Application. To activate mechanisms to prevent and identify unauthorized use of the platform (for example, during purchases and refunds as well as potential fraud committed to your and/or our detriment. If we believe that a transaction resembling fraud has occurred or if we determine unusual behavior that points to an attempt to abuse our options, products or services, such processing may result in the blocking of the transaction or the deletion of your user account. |
| 3. To fulfill requests or application requirements that you make through customer support channels | We only process personal data that is strictly necessary to manage and process your requests or applications. If you contact us by phone, the call may be recorded for quality assurance purposes and to enable us to respond to your request. Subject to availability, if you choose to use WhatsApp as a channel to communicate with customer support, we will share your phone number with WhatsApp Inc. (located in the US) to verify that you are a user of this service. We recommend that you review your privacy settings and read WhatsApp’s privacy policy for more detailed information on how WhatsApp uses users’ personal data. Subject to availability, if you choose to communicate with customer support through a social network chat service or other contributor, some of the personal information, such as name or username, is imported from the social network account or contributor. Also, please note that information you submit through this service is available to the social network or affiliate and is subject to their privacy policies. Accordingly, we recommend that you review your privacy settings and read the privacy policies of the social network or contributors to obtain more detailed information about how they use personal information when you use their services. |
| 4. For marketing purposes. | This purpose includes the processing of your data mainly for the following reasons: If and when you subscribe to our newsletter, we process your personal data to manage your subscription, including sending you customized information about our products or services in various ways (via email or text messages). We may also make this information available to you via push notifications in case you have activated them on your device. If you use social networks, we may provide certain information to the companies we work with so that they can show you our brand ads and, generally, offer you and users like you ads that take into account your profile on such social networks. If you want to know more about the use of your data and the principles of advertising on social networks, we advise you to read the privacy protection rules of the social networks where you have your profiles. To personalize the services we offer you and offer recommendations based on your interactions with us on the Platform and analysis of your user profile (for example, based on your previous purchases and browsing history). We also use your data to measure and segment the ads we show users on some of our partners’ platforms. To achieve this, we work with such third parties that provide us with the necessary technology to use such services (for example, cookies, pixels, SDKs). Please note that while we do not provide personally identifiable information to such contributors, we do provide them with some form of identifier each time (for example, an ad ID associated with a device, an identifier associated with a cookie, and the like). If you would like to know more about this topic, please read the Cookie Policy. You can also reset your Ads ID or disable personalized ads on your device by adjusting your preferences in the Settings section of your device. Data enrichment: We may, in certain circumstances, aggregate your personal data collected from various sources in order to improve our understanding of your needs and preferences related to our products and services (as well as for the purposes of analysis, user profiling, market research, quality testing and improving our interactions with customers). This, for example, refers to the way in which we can connect your data if you have a registered account and shop as a guest, using the same email address associated with your account, that is, with data that is automatically collected (for example, IP and MAC addresses or metadata), which we can connect with the data that you have provided us through your activity on the platform or in any of our stores (for example, data related to your purchases, in stores or online, your preferences and the like). |
5. Analysis of usefulness and quality | If you access our Platform, we inform you that we will process your search data for analytical and statistical purposes, i.e. to understand how users interact with our Platform and to make improvements to the Platform. In addition, we periodically conduct quality and action surveys to gain insight into customer and user satisfaction levels and to identify areas for improvement. |
- HOW ARE WE LEGALLY ALLOWED TO PROCESS YOUR DATA?
The legal basis on which we are allowed to process your personal data also depends on the purpose for which we process it, as explained in the following table:
| Purpose | Legal basis |
| 1. To manage your user registration on the Platform | We process your data because it is necessary in accordance with the provisions governing the use of the Platform. In other words, in order for you to be able 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. We believe we have a legitimate interest in associating your account with purchases and data about your activities collected through various channels on the Platform. |
| 2. Development, execution and conclusion of purchase or service contracts | We process your data because it is necessary for us to be able to enter into a purchase or service contract with you. Certain types of data processing related to the purchase process are only activated because you request or approve them, such as payment information for future purchases or data processing necessary to scan a receipt through the Wallet section of the App or to provide you with Coming Soon/Returning Soon features. In these cases, our processing of your data is supported by your consent. In addition, we process location data when you give us consent in order to offer you certain services through the application when you visit some of our physical stores. We consider that we have a legitimate interest to carry out the necessary checks to detect and prevent possible fraud or abuse of the platform, for example, when you make a purchase or return, or to analyze the effectiveness of some services on the platform, such as the size recommendation tool. We consider that the processing of this data is positive for all parties involved: for you because it allows us to implement measures that protect you from fraudulent attempts by third parties; for us because in this way we avoid unauthorized use of the platform; for our customers and society, because by preventing and detecting fraudulent activities, we also protect their interests. |
| 3. Customer support | We consider that we have a legitimate interest in responding to requests or consultations made by you through the existing various contact channels. We consider that the processing of such data is also useful for you to the extent that it allows us to provide you with assistance in an adequate manner and to provide an answer to the consultation referred. When you contact us, in particular for the purpose of managing incidents concerning your order or products/services you have purchased through the Platform, the processing of your data is necessary for the execution of the purchase contract. When your inquiry is related to the exercise of the rights we notify you of below or to requests for our products or services, we are legally permitted to process your data to comply with legal obligations. |
| 4. Marketing | We are legally permitted to process your data for marketing purposes based on the prior explicit consent you have given us, for example when you accept the receipt of customized data through multiple channels, when you approve the sending of push notifications on the device, when you configure them in the privacy settings of the device, when you give consent through cookie settings or when when you accept the legal terms and conditions for participating in a promotion or for publishing your images on the Platform or on our social network channels. In order to show you customized information, we consider that we have a legitimate interest to perform profiling based on the information we have about you (such as your search, selection or purchase history) and personal data that you have provided to us, such as age or language, given that we consider that the processing of this type of data is also beneficial to you as it allows you to improve the user experience and to access information according to your choices. |
| 5. Analysis of usefulness and quality | We consider that we have a legitimate interest in analyzing the usefulness of the Platform and the level of user satisfaction, because we consider that the processing of this data is also useful for you because the purpose is to improve the user experience and to provide a higher quality service. |
- HOW LONG WILL WE KEEP YOUR DATA?
The retention time of your data depends on the purpose for which we process it, as explained below:
| Purpose | Data retention time |
| 1. To manage your user registration on the Platform | We process your data while you are a registered user (that is, until you decide to cancel your subscription). |
| 2. Development, execution and conclusion of purchase or service contracts | We process your data for as long as necessary to manage your purchase of products or services, including potential returns, complaints or requests related to the purchase of those products or services. Sometimes we’ll only process data until the time you specify, such as payment data you’ve asked us to store for future purchases. |
| 3. Customer support | We process your data for as long as necessary to fulfill your requests or applications. |
| 4. Marketing | We process your data until you unsubscribe or cancel your newsletter subscription. We will also serve you personalized ads until you change your device, browser and/or cookie settings to revoke your permission for such actions. If you participate in promotional actions, we store the data for six (6) months from the end of the action. |
| 5. Analysis of usefulness and quality | We process your data from time to time during periods when we conduct special actions or quality assessment surveys or until we anonymize your search data. |
Regardless of the fact that we process your data for the time that is strictly necessary to achieve the given purpose, we subsequently keep it stored and protected in an appropriate way during the period when the duty to process it may arise, from time to time in accordance with the applicable law. When the time limit for each potential action expires, we delete the personal data.
- DO WE SHARE DATA WITH THIRD PARTIES?
In order to fulfill the purposes set out in this Privacy and Cookies Policy, we must provide ChicCode entities and third parties with access to your personal information that supports us in the services we provide to you, i.e.:
financial institutions,
fraud detection and prevention entities,
providers of technological and analytical services,
providers and partners of logistics, transport and delivery services and/or their partner institutions,
to service providers regarding customer support,
to service providers and collaborators in the field of marketing and publicity, such as social networking websites, advertising agencies or advertising partners.
For purposes of service efficiency, some of these service providers are located in territories outside the European Economic Area that do not provide the same level of data protection as the European Union and may not be on the list of countries that provide an adequate level of data protection issued by the competent data protection authority in Serbia. In such cases, we inform you that we transfer your data with the application of appropriate security measures so that your data is always safe and to this end we use more appropriate tools for international data transfer, in accordance with standard contractual clauses and other relevant supplementary measures. You can review the content of such standard contractual clauses at the following link: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.
In the event that we sell or transfer our business or resources in whole or in part to another company within or outside the Inditex Group or if we carry out some other business action as a result of a company reorganization, we may disclose your personal information to a person who acquires said business or resources in the future. If such a sale or transfer occurs, we will use reasonable efforts to direct the transferee to use the personal information you have provided to us in a manner consistent with our Privacy and Cookie Policy. In that case, we consider that we have a legitimate interest consisting in the reorganization of the company’s structure.
In addition, if you choose to use our Platform in different markets (ie, if you create user accounts in different markets with the same email address), we may need to disclose or transfer information related to your account or activities to brand companies operating in those markets, to the extent that they are directly involved in achieving some of the purposes described in Section 2. We believe this is necessary in accordance with our mutual interests and choices.
- WHAT ARE YOUR RIGHTS WHEN YOU MAKE YOUR DATA AVAILABLE TO US?
We take responsibility for keeping your personal data confidential and for enabling you to exercise your rights. You can exercise your rights free of charge by sending us an email to our email address (info@chiccode.rs), in which you will simply inform us about your request and the right you want to exercise. If we consider it necessary to be able to identify you, we may ask you to provide us with a copy of a document proving your identity.
In addition, we may offer you the ability to exercise your rights and configure your privacy settings when using some of our services or make certain channels available to you on our Platform.
First of all, regardless of the purpose or legal basis we rely on to process your data, you have the following rights:
To request access to your personal data that we hold. We remind you that if you are a registered user of the Platform, you can also check this information in the corresponding section of your online account.
To request that we correct the personal data we have. Please note that if you are not a registered user of the Platform, you may also access the appropriate personal information section of your online account to change or update your personal information. In any case, please note that by actively making personal data available to us through any process, you warrant that it is true and accurate and undertake the responsibility to notify us of any change or alteration of the data. You are responsible for any loss or damage to the account of the Platform or the person in charge of the Platform or any third party by reporting wrong, inaccurate or incomplete information in the registration forms. Please remember that, as a general rule, you must provide us with only your own data and not third-party data, except to the extent otherwise permitted in this Privacy and Cookie Policy.
To request that we delete your personal data to the extent that it is no longer necessary for the purpose for which we have to continue to process it, as explained above, or when we are no longer legally permitted to process it.
To 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 the data or to keep it longer than necessary.
If you have given us your consent to process your data for any purpose, you also have the right to withdraw that consent at any time. Some of the circumstances in which you can withdraw your consent are set out in section 2 where we explain the purposes for which we process your data.
If you do not want us to send information to third parties in order to serve you ads, you can do so in several ways, for example, by changing your device, browser and/or cookie settings, reviewing the privacy policies and settings of the social networking sites on which you have profiles, or by emailing us at the above email address and informing us of your request.
Where we are legally permitted to process your data based on your consent or for contractual purposes, as explained in section 3, you also have the right to request the portability of personal data. This means that you have the right to receive the personal data that you have made available to us in a structured, commonly used and machine-readable format, so that it can be transferred to another entity directly without hindrance from us.
In addition, where the processing of your data is based on our legitimate interest, you also have the right to object to the processing of your data.
Finally, we inform you that you have the right to submit a complaint to the competent regulatory authority for data protection, and in particular:
– to the competent authority of the market where the trade retail company is located: Commissioner for Information of Public Importance and Protection of Personal Data of the Republic of Serbia (Bulevar kralja Aleksandra no. 15, Belgrade).
- WHAT HAPPENS WHEN YOU PROVIDE US WITH THIRD PARTY DATA?
We provide features or services that require us to process third-party personal data that you must provide, such as managing a Gift Voucher application. If you provide us with the personal data of third parties, you confirm that you have informed them of the purposes and manner in which we have to process their personal data.
If a third party provides us with data about you or you provide it to us because of an option or service requested by one of our users, we will use it in any case to manage such an option or service, within the scope of the purposes specified in these Privacy and Cookies Policy, and we will always provide links to them in our communications.
- HANGES TO DATA PROTECTION AND COOKIES POLICY
We may make changes to the information contained in this Privacy and Cookie Policy at our sole discretion. If we do so, we will notify you in various ways through the Platform (for example, via a banner, pop-up or push notification) or we may even send you a notification to your email address when a given change is important to your privacy, so that you can review the changes, access them and, if applicable, object to or opt out of any service or feature. In any case, we suggest that you review this Privacy and Cookies Policy from time to time in case we make minor changes or introduce any improvements to the interaction, so that you always have the possibility to receive information on our website or in our application.
- INFORMATION ABOUT COOKIES
We use cookies and similar means to facilitate your browsing on the Platform, to gain insight into how you interact with us, in certain cases, so that we can show you advertisements according to your browsing habits. Read our Cookie Policy to understand in more detail the cookies and similar tools we use, their purpose, how to manage your preferences, and other information that may be of interest.FIRST OF ALL…
Cookie Policy
In this Cookie Policy you will find information about how we use cookies and similar tools that are installed on the devices of our customers and users. In some cases, the use of cookies is related to the processing of personal data, so we recommend that you review the Privacy Policy available on our platform if you want to know how we use the personal data of customers and users, as well as how you can exercise your rights or if you want to review the terminology we use to refer to our platform (website, application or physical stores).
INFORMATION ABOUT COOKIES
1. What is a cookie?
A cookie is a small text file with information about your browsing or usage, which a website, application or other platform stores on your computer, tablet, smartphone or any similar device, as a tag that identifies the device. Cookies, for example, are necessary for easier browsing of pages and enable understanding of the communication between the user and the platform in order to further improve it. They are also very useful for serving ads that are in line with the user’s preferences, as well as for other purposes detailed below. Cookies do not harm your computer or device.
By the term “cookie” we also include technologies that are similarly installed on your device and/or that similarly collect data from and about the device (such as flash cookies, tracking or error web images, pixels, HTML5 (local storage) and SDK technologies for application formats. Likewise, the term “cookie” also refers to the use of digital fingerprinting techniques, that is, those data combining techniques that help us identify your device. Sometimes these technologies work together with cookies for the purpose collecting and storing data, either to provide you with certain features or services on our platform, or to show you advertising on third-party platforms based on your browsing.
This explanation is a general representation of what is meant by the term cookie for informational purposes only. The cookies we specifically use are described in detail in the cookie configuration menu available on our platform.
What types of cookies are there?
Please review this section which provides a general overview of the types of cookies that may be used in the online environment. According to ownership, cookies can be divided into:
personal cookies: these are cookies that are sent to the user’s computer or device from a device or domain managed by the publisher itself and through which the platform or service requested by the user is provided.
third-party cookies: these are cookies that are sent to the user’s computer or device from a device or domain that is not controlled by the publisher, but by a third party that processes the data collected by the cookies.
According to the purpose, cookies can be divided into:
strictly necessary (technical) cookies: these are cookies that allow the user to browse the website, platform or application and use the various options or services that exist on them, such as traffic control, data or session identification, access to restricted access sections or contents, remembering the elements that make up the order, executing the order, managing payments, controlling fraud related to the security of the service, using security elements when browsing, requesting registration or participating in an event, storing content for playing videos or sound, enabling dynamic content (eg text or image loading animation) or sharing content via social networks. Since they are strictly necessary, technical cookies are downloaded according to the default settings when they enable the display of the platform or the provision of the service requested by the user.
functional cookies and personalization cookies: these cookies enable data to be remembered in order for the user to access the platform with certain properties due to which his experience may differ from that of other users, such as language, the number of results displayed when searching, the appearance or content of the service according to the browser the user uses or according to the region in which he accesses the service, etc. Failure to accept these cookies may result in slow website performance or poorly tailored recommendations.
cookies for analysis: those that allow determining the number of users and visited sections on the platform, as well as how the user interacts with them in order to perform measurements and statistical analysis of user use for the purpose of improvement based on that analysis of data on user use of the platform or services.
cookies for targeted advertising: those that store data about the user’s behavior that is collected by permanently tracking browsing habits, which allows the development of a specific profile in order to show the user advertisements that are in line with him. These cookies make it possible to manage, in the most efficient way possible, the advertising space that the publisher has included, where appropriate, independently or in cooperation with third parties.
- For what purpose are cookies used on our platform?
Cookies form a significant part of the operation of our platform. The main purpose of our cookies is to make your browsing experience as pleasant and efficient as possible. For example, they are used to remember your personal preferences (language, country, etc.) when browsing and on future visits. We also use cookies to improve the Services and the Platform, and to be able to offer you ads that are tailored to your browsing habits.
The data collected by cookies also allows us to improve the platform by evaluating statistical data and usage patterns (number of visits, sections you visit most often, duration of visits) in order to statistically learn how users interact with the platform in order to improve our services and adapt the platform to individual user interests, faster searches, etc.
We may sometimes use cookies to collect data that allows us to show you ads on our platform, on third-party platforms or in any other way based on an analysis of your browsing habits (viewed products or sections, etc.).
In any case, the cookies we use will never store sensitive data such as passwords, credit or debit card details, etc.
- How can I manage the use of cookies on this platform?
In the cookie configuration menu, which is available at all times on our platform, you can get all the information about the cookies used on this platform, as well as information on the purpose and duration of each of them and the management of cookies (personal or third-party cookies), so that you can manage the enabling or disabling of those cookies that are not strictly necessary for the correct operation of this platform.
When you disable cookies, if possible, the related cookies are deleted from the browser, and in any case, when you reject a cookie and deletion is not possible, we always block it. Accordingly, we never use cookies that you reject and we do our best to delete them (note that certain deletion mechanisms are beyond our control as they depend on the third parties responsible for the cookie).
If you browse the Internet, you can also disable the use of cookies on your browser, also when it comes to third-party cookies that you have accepted and subsequently decided to reject. Below you can find instructions on how to disable it on the most popular browsers:
Google Chrome
Internet Explorer
Mozilla Firefox
Safari
This possibility of disabling the use of cookies can be carried out at any time.Please note that the management of the cookie configuration menu and the option to disable the use of cookies are unique to each browser you use. Accordingly, if you configure cookies in a certain way on one device and want to apply similar settings on another device, you will need to set the same options on that other device.
As an additional step related to third-party cookies whose purpose is to provide ads that are tailored to your interests, please note that some third parties may be members of some of the following self-regulatory targeted advertising programs with appropriate opt-out options:
Network Advertising Initiative (NAI) – http://www.networkadvertising.org/choices/
Who uses the data stored by cookies?
Google Analytics – https://tools.google.com/dlpage/gaoptout
Target – https://www.youronlinechoices.com/
The data stored by cookies on our platform is used exclusively by us, except for the cookies listed in section 2 as “third-party cookies”, which are used and managed by external entities in order to provide services for the purpose of improving our services and the user experience when browsing our platform. More information is available in the cookie configuration menu which is available at all times on our platform.
For more detailed information on the processing of your personal data in our cooperation with third parties and those subject to international data transfer, we advise you to read the Privacy Policy available on our platform, as well as the privacy policy / privacy settings of those third parties available on their platforms.
These are the most relevant third parties that we allow to set cookies on our platform. Learn more about how these third parties process your information:
Google site for enterprise security
Microsoft
Target
Pinterest