FOR WHAT PURPOSES AND ON WHAT BASIS ARE YOUR PERSONAL DATA PROCESSED?

Your personal data is collected and processed within the scope of the services provided by CLASH on its website and its network of stores. In particular, we collect and process your personal data to:

Process your payments, if you purchase our products, to allow you to access the status of your order, deal with your questions and requests, and evaluate and deal with any complaints;

To process and respond to your requests or to contact you to answer your questions and / or requests;

To develop and improve our products, services, communication methods and the functionality of our websites;

For the purposes of contests or promotions in which you have participated;

To communicate information to you via email, SMS and other equivalent forms of electronic communication, and to manage your registration and / or subscription to our newsletter or other communications;

To manage our daily business needs regarding your participation in our contests, sweepstakes or promotional activities;

To authenticate the identity of individuals who contact us by telephone, electronic or other means;

For information and quality assurance purposes;

To understand and assess consumers’ interests, desires, and changing needs, to improve our website, our current products and services, and / or to develop new products and services; and

To provide you with personalized products and communications, as well as targeted advertising and product recommendations.

We also proceed to the definition of profiles through the analysis of information about your online browsing, research and shopping habits, through the construction of segments (creation of groups that share common characteristics) and placement of your personal data in one or more of these segments, provided that you have given us your consent, for example, by accepting the placement of cookies in your internet browser or subscribing to the receipt of CLASH newsletters in your email, or the receipt of SMS or other equivalent form of electronic communication. You can withdraw your consent at any time to prevent the use of your personal data in this way, or even cancel the subscription to use your email address or mobile phone number, if you have registered on one of our websites or subscribed to an advertising newsletter, or registered as a store customer. In order to provide a service as complete as possible to its customers, CLASH maintains partnerships with third party external service providers that perform functions on behalf of CLASH, such as companies that host or operate the CLASH website, process payments, analyze data, provide customer services, postal or delivery services, and sponsors or other third parties who participate or manage our promotions, so that your personal data may be used and / or processed by those third parties for purposes strictly linked to the services provided on the website. Access to your personal data by third parties is limited, being carried out solely to satisfy an order, make a payment, process a delivery, or support the customer. In addition, these third parties must process your personal data in accordance with this Privacy Policy and in accordance with applicable law. Your personal data may also be used by CLASH for internal reasons, mainly for commercial and operational purposes. As we continue to develop our business, we may sell or acquire assets, subsidiaries or business units. In this type of transaction, your personal data is generally one of the commercial assets transferred, but remains subject to the guarantees provided in any pre-existing Privacy Policy (except, of course, if you have consented otherwise). If another entity acquires us, our business, all or a substantial part of our assets, or assets related to the CLASH website, your personal data will be disclosed to that same entity as part of the legal audit process and will be transferred to that entity as one of the transferred assets. In addition, if any insolvency or reorganization proceeds or is imposed on us, all your personal data will be considered as an asset that belongs to us and, as such, it is possible that they will be sold or transferred to third parties. When we collect and process your personal data for the purposes described above or for other purposes, we inform you in advance or at the time of collection, in order to obtain your consent when necessary to legitimize the processing of your data. However, there may be some cases in which it is not your consent that legitimizes the processing of your personal data, but one of the following grounds:

When processing is necessary to conclude a contract with you or proceed with its execution (as will be the case with data processing for the purposes related to the processing of an order);

When treatment is necessary to comply with the legal obligations to which CLASH is subject;

When processing is necessary to achieve a legitimate interest pursued by CLASH, which does not jeopardize its fundamental interests, rights and freedoms that require the protection of personal data – this legal basis will only be used where there is no less intrusive way of dealing your personal data. We can assure you that if the legitimate interest is used as a reason to process your personal data, we will keep a record of that action and you will have the right to request that information;

When treatment is necessary for the purposes of declaring, exercising or defending a right in a judicial proceeding.

If the user provides CLASH personal data of third parties without their consent, they will be solely responsible for any illegal and improper use of such data.

HOW DO WE KEEP YOUR PERSONAL DATA SAFE?

CLASH takes all possible measures to ensure the confidentiality and security of your personal data, carrying out all efforts and security measures to protect your personal data from misuse, interference, loss, unauthorized access, modification or disclosure. In particular, the entire selection and payment method to be used and the introduction of the data inherent to the payment process for your orders is duly protected, with all information encrypted and managed with advanced security tools. Our measures include the implementation of appropriate access controls, to ensure that we encrypt, pseudonymise and anonymize personal data whenever possible. Access to your personal data is only allowed under the terms already described above, always depending on the actual need for your knowledge, and subject to strict contractual confidentiality obligations when processed by third parties. Although data transmission over the internet or website cannot guarantee total security against intrusions, CLASH and its service providers provide the best efforts to implement and maintain physical, electronic and procedural security measures designed to protect your personal data in compliance with applicable data protection requirements.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

CLASH will retain your data only for as long as is necessary for the purpose for which it was collected. In the case of personal data collected in the context of sales without registration, online sales, and shipment of orders, we will keep the data related to your purchase, so that we can comply with the specific contract you entered into, after which we will keep your personal data for a period of ten (10) years, so that we can deal with or respond to any complaints, questions or concerns regarding the purchase. Likewise, in cases of direct and online marketing and arrangements and reservations, we will keep your personal data for a period of 2 (two) years after inactivity, in order to continue to improve your experience with us, respond to any complaints, questions or concerns related to the contracted services and for any reasons that justify it, namely the execution of a contract with you, always taking into account your best interests. We keep the identifiable data that we collect directly for specific purposes, for the minimum possible time, after which we will take steps to permanently delete it. CLASH takes all possible measures to ensure the confidentiality and security of your personal data, carrying out all efforts and security measures to protect your personal data from misuse, interference, loss, unauthorized access, modification or disclosure.