PRIVACY POLICY

The purpose of this Privacy Policy is to inform all those who access and browse the Website (hereinafter, the “User”) accessible through the domain name https://www.divlos.com/ about the following aspects related to the processing of personal data:

WHO IS RESPONSIBLE FOR THE TREATMENT?

The entity responsible for the treatment of the personal data collected is R&R INVESTMENT AG (DIVLOS), CH-3780 GSTAAD; located in Chalet Erika Egglistrasse 41 Switzerland, phone number +34 912604067; and email: info@divlos.com.

WHAT IS THE PURPOSE OF THE PROCESSING OF YOUR DATA?

DIVLOS collects and processes personal data in accordance with the applicable data protection legislation, only for the purposes described in this Privacy Policy. As a User of our services, we inform you that, depending on the type of form or data collection process that you complete, your information may be processed for the following purposes:

* Web customers: The information collected in the online purchase process will be treated in order to process, send and invoice the products purchased through the online store, as well as to provide customer service after the purchase.
* Registered users: The information you provide us in the registration process will be used so that you can access your profile, check your orders and make your purchases without having to re-enter your identification data and delivery address. You can modify your profile settings whenever you want.
* Queries / contact form: The personal data that you provide us through the contact section enabled on the website will only be processed to answer your query or request. The information collected will be limited to identifying and contact data, as well as data related to the nature of the request you send us.
* Recipients of commercial communications: In cases where you have provided us with your unequivocal consent, we will use your identification and contact details to send you personalized information about the news on the website, promotions and offers of our products and services. Likewise, when you have made a purchase, we may use the contact information to send personalized information about our promotions and news. This information may be sent by post, telephone and/or email, and may involve the sending of personalized information based on your preferences. You must bear in mind that this data processing entails the analysis of your user or client profile to determine what your preferences are and, therefore, which products and services may be that best fit your browsing and purchasing habits at the time. to send you information. For example, based on your purchase and browsing history, we may personalize our suggestions on products and services that we think may interest you. However, we indicate that you can request at this very moment your wish not to receive this type of communication, by sending us an email to info@divlos.com. In each commercial communication that we send you, we will indicate an agile, simple, and free mechanism so that you can express your desire not to receive new commercial communications, without affecting the transactional communications related to the purchase confirmation, delivery information and Customer Service.
* Use of cookies in relation to profile analysis: We use information about the habits of users in their browsing process, purchase and preferences, in order to carry out market studies for the optimization of business processes, design-oriented demand our services and products, as well as to display personalized content. To do this, we use aggregated, pseudonymized or anonymized data, as well as machine learning algorithms, which allow us to make estimates, forecasts and analysis on the interests of our users.

TO WHOM IS YOUR DATA COMMUNICATED?

In relation to the recipients of the information, we inform you that in the event that you make an online purchase, your data will be communicated to the transport company in order to facilitate the delivery process.

Through the Website, the customer can access, through links, third-party websites, such as Stripe or Paypal, to make the payment of the products purchased. At no time does DIVLOS have access to the bank details (for example, the credit card number) that the Client provides. Payment of purchases via credit/debit card in DIVLOS implies that your card information will be sent directly to the entity of means of payment.

Through this method of payment, DIVLOS does not collect or manipulate any customer data regarding their card number. All data is processed directly by the means of the payment entity, so that DIVLOS can always offer the greatest transparency and confidentiality in the transaction.

WHAT IS THE BASIS THAT LEGITIMATES THE TREATMENT?

The legal basis for the processing of personal data collected by DIVLOS is based on different legal precepts, depending on the context of collection and processing:

* Data related to the purchase process and customer service: In relation to the personal data collected during the online purchase process, as well as the data processed within the framework of the relationship that is generated between DIVLOS and the Customer, the The basis that legitimizes the treatment is the execution of the contractual relationship between the parties.
* Data related to the registration in the newsletter, as well as data collected in the different forms enabled on this website not linked to the purchase process and customer service: In these cases the basis that legitimizes the data processing is the own unequivocal consent and acceptance of the User in each of the sections in which personal information is collected. The User has the right to withdraw consent at any time, without affecting the legality of the treatment based on the consent prior to its withdrawal.
* Sending commercial communications to clients: The basis that legitimizes the treatment for sending commercial communications to our clients is the legitimate interest of DIVLOS in maintaining the commercial relationship and sending relevant information about products or services related to those who have been subject to prior contracting.
* Data related to the analysis and personalized preferences of the users: The basis that legitimizes the treatment is the legitimate interest of DIVLOS in the improvement of internal processes that result in the optimization of services and products to users, since we understand that the treatment This data is also beneficial for you, as it allows you to improve your user experience and access information according to your preferences.

HOW LONG IS THE INFORMATION KEPT?

The conservation period of the information will vary depending on the type of treatment:
* Web customers: The information will be kept for the period necessary to manage the delivery and billing of the products purchased, as well as during the guarantee period of the products for the provision of after-sales service; subsequently the information will be kept blocked during the statute of limitations for legal actions and after this period it will be deleted.
* Registered Users: The information of registered Users will be kept indefinitely unless the User requests the cancellation as a Registered User.
* Recipients of commercial communications: The information of recipients of commercial communications will be kept indefinitely unless the User requests to unsubscribe from the receipt of new communications, in which case, we will proceed to remove their data and include them in our Robinson List in order to ensure that no new commercial shipments are made.
* Users of the contact form: The information collected through the contact form enabled on the website will be kept for the period necessary to meet the request for consultation or information that the User has requested; Subsequently, the data will be deleted, unless the nature of the query or request requires the conservation of your information for other purposes, in which case we will inform you about said purpose of the treatment, the conservation period and data recipients, in the terms that correspond.
* Users of our products and services in relation to the analysis of profiles: the data will be kept for the period necessary to achieve the purposes indicated in this Privacy Policy in relation to the improvement of our internal processes that result in the optimization of services and products to users.

HOW DO WE PROTECT YOUR DATA?

DIVLOS uses technologies appropriate to the current state of the art, to protect your data and personal information, so our website is stored on secure servers protected against the most common types of attacks. DIVLOS has adopted technical and organizational measures that guarantee the security of personal data and prevent its alteration, loss, treatment or unauthorized access, taking into account the state of technology, the nature of the stored data and the risks to which they are exposed. We remind you of the need for your username and password to be private and non-transferable.

In the event that you suspect any unauthorized access to the restricted access area, you must notify us immediately at the email address info@divlos.com so that we can adopt the corresponding measures to guarantee confidentiality , security and integrity of your personal data.

WHAT ARE YOUR DATA PROTECTION RIGHTS?

Next, we inform you about each of your rights in terms of data protection and we indicate the channels through which you can direct, where appropriate, the corresponding request:

* Right of access: You will have the right to obtain confirmation on whether or not personal data concerning you is being processed, as well as access to the following information: the purposes of the treatment; the categories of data that are processed; the recipients or categories of recipients to whom they have been or will be communicated; if possible, the expected period of conservation of personal data or, if not possible, the criteria used to determine this period.
* Right of rectification: You will have the right to obtain the rectification of inaccurate personal data that concerns you. In addition, taking into account the purposes of the treatment, you will have the right to complete incomplete personal data, including through an additional declaration. To do this, you must indicate in your request what data you refer to and the correction that we must make; Likewise, you will have to accompany, when necessary, the supporting documentation of the inaccuracy or incompleteness of the data object of the treatment.
* Right of deletion: You will have the right to obtain the deletion of the personal data that concerns you when one of the following circumstances occurs:
    * It is not necessary for the purposes for which it was collected or processed;
    * you withdraw your consent, provided that the treatment is not based on another legal basis;
    * you object to the treatment and other legitimate reasons for the treatment do not prevail; that have been unlawfully treated.
* Limitation right: You will have the right to obtain the limitation of the data processing when any of the following conditions is met:
    * when you have contested the accuracy of your personal data, during the period that allows to verify the accuracy of the same;
    * In the event that you consider that the treatment is illegal, you have opposed the deletion of personal data and request instead the limitation of its use;
    * that the Company no longer needs the personal data for the purposes of the treatment, but the User needs it for the formulation, exercise or defense of claims;
    * In the event that you have opposed the treatment, while it is verified if the legitimate reasons of the Company prevail over yours.
* Right of portability: You will have the right to receive the personal data that concerns you, that you have provided to the Company, in a structured format, of common use and mechanical reading, and to transmit them to another person in charge of the treatment without being prevented by the Company, when the treatment is based on consent, and is carried out by automated means. By exercising your right to data portability, you will have the right to have personal data transmitted directly from controller to controller when technically possible. This right to portability will not apply to the treatment that is necessary for the fulfillment of a mission carried out in the public interest or in the exercise of public powers. The right to portability will not extend to the data that the Company has inferred from data that is derived directly from the use of the services provided.
* Right of opposition: You will have the right to object to the processing of data that concerns you, at any time, including profiling. In the event that you exercise this right, the Company will stop processing your personal data, unless we prove compelling legitimate reasons for the processing to prevail over your interests, rights and freedoms, or for the formulation, exercise or defense of claims.

Channels to exercise these rights: to exercise any of the rights indicated in the previous sections, the User may send an email to info@divlos.com or send a letter to the following address: Chalet Erika Egglistrasse 41 Switzerland.

In cases where you consider that your data protection rights have been violated, especially when you have not obtained satisfaction in the exercise of your rights, we indicate that you file a claim with the competent Control Authority.

VERACITY AND UPDATING OF THE INFORMATION PROVIDED

All information provided by the User must be true and accurate. For these purposes, the User must ensure the authenticity of all the data provided as a result of completing the corresponding forms. To register and/or fill in any form, the User will have to provide all the data that appears in said forms as mandatory, guaranteeing that the data provided is accurate and real. The variation of your data must be notified as soon as possible to DIVLOS. In any case, the User will be solely responsible for any false or inaccurate statements made, and for the damages caused to DIVLOS, or to third parties, due to the information provided.

CHANGES TO THIS PRIVACY POLICY

DIVLOS reserves the right to modify this Privacy Policy to adapt it to new legislation or jurisprudence, as well as to industry practices. In these cases, DIVLOS will announce on this page the changes introduced with reasonable anticipation of their implementation.

Last updated: 13th August 2021