WE RECOMMEND THAT YOU READ AND UNDERSTAND OUR PRIVACY POLICY BEFORE PROVIDING YOUR PERSONAL DATA AND GRANTING CONSENT FOR ITS PROCESSING.

 1.- Who is responsible for processing your data?

 Identity: 3INA COSMETICS, SL.

VAT ID: B87141305

Email: privacy@3ina.com. 

When we refer to 3INA, we generally refer to any of the digital or physical channels or means you have used to interact with us on our Website, www.3ina.com.

 2.- What data of yours do we process?

3INA will process the data you have voluntarily provided, as well as inferred data, which is data resulting from the application of algorithms to analyze data from social media, purchase records, satisfaction surveys, and communications received at the email address hello@3ina.com.

 Depending on the products, services, or functionalities you wish to enjoy, we will need to process certain data, which will generally be, as appropriate, the following:

• identifying data (e.g., your first name, last name, address, zip code, city, province, phone number, mobile number, email address, language, and country from which you interact with us, contact details, and Instagram username, etc.);
• personal characteristics (e.g., gender and date of birth, preferences regarding colors/models, etc.);
• financial and transactional information (e.g., your payment or card details, information about your purchases, orders, returns, etc.);
• connection, geolocation, and browsing data (if you interact with us from your mobile, for example);
• commercial information (e.g., if you are subscribed to our newsletter).

Please remember that when we ask you to fill in your personal data to give you access to a certain functionality or service, we will mark some fields as mandatory, as this data is necessary for us to provide you with the service or give you access to the functionality in question. Please note that if you choose not to provide us with this data, you may not be able to complete your registration as a customer or enjoy those services or functionalities.

3.- For what purpose do we process your personal data, what is the legal basis, and what are the retention periods?

 Depending on how you interact with 3INA, we will process your personal data for the following purposes, legal bases, and retention periods, as described below:

 (1) Purpose: Registration as a 3INA customer. We need to process your data to identify you as a customer and give you access to the functionalities, products, and services available to you.

Legal basis: Consent.

Retention periods: We will process your data for as long as you maintain your status as a registered customer, until you decide to unsubscribe.

 (2) Purpose: Development, fulfillment, and execution of the sales contract. Includes (i) order preparation and delivery management; (ii) payment management and, where applicable, returns; (iii) invoicing and sending purchase receipts and invoices for purchases made in the online store; (iv) sending receipts and invoices for purchases made in physical stores; and (v) surveys and publication of product reviews.

Legal basis: The execution of the sales and/or rental contract.

Retention period: A period of 6 years from the last operation carried out, keeping them blocked until the statute of limitations for possible liability actions.

 (3) Purpose: Sending personalized commercial communications from 3INA by any means of electronic distance communication (Newsletter, promotions and offers, invitations to special events, surveys, contests and sweepstakes, and loyalty programs).

Legal basis: Consent.

Retention periods: Until you request to unsubscribe, as until then we will understand that you are still interested in receiving our communications.

 (4) Purpose: Managing or resolving a request or inquiry through Customer Service.

Legal basis: Contract execution and legitimate interest.

Retention periods: We will process your data for as long as necessary to address your request or inquiry, keeping them blocked until the statute of limitations for possible liability actions.

 If you choose to use WhatsApp or any other similar messaging channel to communicate with Customer Service, we recommend that you review your privacy settings and read the privacy policy for more detailed information on how the messaging service uses the personal data of users who use its services.

 (5) Purpose. Profiling and marketing.

Legal basis: We consider that we have a legitimate interest in creating a profile with the information we have about you (such as your browsing activity and/or purchase history) and the personal data you have provided to us, as we understand that the processing of this data is also beneficial to you because it allows us to improve your user experience and access information according to your preferences. To this end, 3INA has weighed the interests and rights of data subjects, and the measures adopted by the data controller to comply with its general obligations in terms of proportionality and transparency, and has concluded that:

 1.- the impact on the fundamental rights and public freedoms of individuals is limited;

2.- such processing can be reasonably foreseen by the data subject;

3.- the processing of data for the aforementioned purposes does not lead to exclusion, discrimination, defamation, or situations that jeopardize the reputation of the data subject and/or their bargaining power.

Retention period: Until you request to unsubscribe or cancel your customer registration.

 (6) Purpose: Push notifications (regarding the status of your orders, unique opportunities and/or promotions).

Legal basis: Consent.

Retention periods: Until you request to unsubscribe, as until then we will understand that you are still interested in receiving our notifications.

 4.- Who is the recipient of your data?

4.1 Data communication. Personal data processed is only communicated to third parties in compliance with legal obligations.

4.2 Data Processors. 3INA will work with third-party service providers who may have access to your personal data and who will process the said data on behalf of and for the Company as a result of their service provision. 3INA follows strict criteria for selecting service providers in order to comply with its data protection obligations and undertakes to sign the corresponding data processing agreement with them. Specifically, 3INA will contract for services from third-party providers operating, by way of example and not limitation, in the following sectors: logistics services, legal advice, supplier homologation, multidisciplinary professional services companies, maintenance-related companies, technology service providers, IT service providers, physical security companies, instant messaging service providers, infrastructure management and maintenance companies, call center service companies, hosting, maintenance, and support service providers for our databases, as well as software and applications that may process your data.

For service efficiency, some of the aforementioned providers are located in territories outside the European Economic Area that do not provide a level of data protection equivalent to that of the European Union, such as the United States. In such cases, we inform you that we transfer your data with adequate safeguards and always ensuring the security of your data, by signing the Standard Contractual Clauses approved by the Commission, the content of which you can consult at the following link: www.aepd.es/es/derechos-y-deberes/cumple-tus-deberes/medidas-de-cumplimiento/transferencias-internacionales.

 4.3 Security measures. 3INA uses information security techniques such as firewalls and access control procedures, all with the aim of preventing unauthorized access to data and ensuring its confidentiality. To achieve these purposes, the user accepts that 3INA obtains data for the purpose of the corresponding authentication of access controls. 

Additionally, any transaction made through 3INA is carried out through secure payment systems. Confidential payment data is transmitted directly and encrypted (SSL) to the corresponding entity.

3INA declares that it has adopted all necessary technical and organizational measures to guarantee the security and integrity of the personal data it processes, as well as to prevent its loss, alteration, and/or access by unauthorized third parties.

 4.5 Use of cookies. We use cookies to facilitate your navigation on 3INA, to understand how you interact with us and, in certain cases, to show you advertising based on your browsing habits. You will find additional information in our Cookie Policy. 

5.- What are your rights when you provide us with your data?

 Your rights regarding the processing of personal data in relation to 3INA are:

• Right to request access to your personal data
• Right to request their rectification or erasure
• Right to cancellation
• Right to request restriction of their processing
• Right to data portability
• Right to object to processing
• Right not to be subject to automated decisions, including profiling
• Right to withdraw consent given for sending commercial communications.

6.- What is the right of access? 

You shall have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and to the following information: the purposes of the processing; the categories of personal data concerned; the recipients or categories of recipients to whom the personal data have been or will be disclosed; where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period. In these cases, we will provide you with a copy of the personal data undergoing processing. Additionally, when requested by electronic means, the information shall be provided in a commonly used electronic format. You may exercise this right every six months, unless there is a legitimate reason to request it more than once within that six-month period, and we will inform you about the actions taken in response to your request within one month.

 To exercise the right of access, send an email to: privacy@3ina.com, or send a letter to the eCommerce Department, at C/ Doctor Fourquet, 3 Bajo, LC02, 28012 Madrid.

 7.- What is the right to rectification?

 You shall have the right to obtain the rectification of inaccurate personal data concerning you. To do so, you will need to provide, where necessary, documentation justifying the inaccuracy or incompleteness of the data being processed. To exercise the right to rectification, send an email to: privacy@3ina.com, or send a letter to the eCommerce Department, at C/ Doctor Fourquet, 3 Bajo, LC02, 28012 Madrid.

 8.- What is the right to cancellation?

 You shall have the right to obtain the erasure of personal data concerning you where one of the following grounds applies: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent on which the processing is based and there is no other legal ground for the processing; you object to the processing and there are no overriding legitimate grounds for the processing; the personal data have been unlawfully processed. To exercise the right to cancellation, send an email to: privacy@3ina.com, or send a letter to the eCommerce Department, at C/ Doctor Fourquet, 3 Bajo, LC02, 28012 Madrid.

 9.- What is the right to restriction of processing?

 You shall have the right to obtain restriction of processing where one of the following applies: 

1. you contest the accuracy of your personal data, for a period enabling the data controller to verify the accuracy of the personal data;
2. the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
3. the data controller no longer needs the personal data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims;
4. you have objected to processing pending the verification whether the legitimate grounds of the data controller override yours.

When you have obtained restriction of processing pursuant to this section, you will be informed by the data controller.

To exercise the right to restriction of processing, send an email to: privacy@3ina.com, or send a letter to the eCommerce Department, at C/ Doctor Fourquet, 3 Bajo, LC02, 28012 Madrid.

 10.- What is the right to data portability?

You shall have the right to receive the personal data concerning you, which you have provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller when: the processing is based on consent, and the processing is carried out by automated means.

In exercising your right to data portability, you shall have the right to have personal data transmitted directly from one controller to another, where technically feasible.

The right to portability shall not extend to data that the data controller has inferred from data directly derived from the use of the services provided by that controller.

To exercise the right to portability, send an email to: privacy@3ina.com, or send a letter to the eCommerce Department, at C/ Doctor Fourquet, 3 Bajo, LC02, 28012 Madrid.

 11.- What is the right to object?

You shall have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you. In the event that you exercise this right, the data controller shall no longer process your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. To exercise the right to object, send an email to: privacy@3ina.com, or send a letter to the eCommerce Department, at C/ Doctor Fourquet, 3 Bajo, LC02, 28012 Madrid.

 12.- What is the right not to be subject to automated decision-making, including profiling?

You shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you; unless:

- such decision is necessary for entering into, or performance of, a contract,

- is authorized by law or

- is based on your explicit consent.

To exercise the right not to be subject to automated decisions, send an email to: privacy@3ina.com, or send a letter to the eCommerce Department, at C/ Doctor Fourquet, 3 Bajo, LC02, 28012 Madrid.

 13.- How can you stop receiving commercial communications?

 In all commercial communications we send you by electronic means, a link - UNSUBSCRIBE or similar - will be enabled, which will allow you to request that we do not send you new commercial communications, without affecting the lawfulness of the processing based on consent prior to its withdrawal.

You can also withdraw your consent or express your opposition through any of the following means:

By sending an email to: privacy@3ina.com

By postal mail addressed to 3INA COSMETICS, SL with registered office at C/ Doctor Fourquet, 3 Bajo, LC02, 28012 Madrid.

The processing time is 48-72 hours, so it is possible that during this time you may receive some commercial communication.

Additionally, we inform you that you can contact the Spanish Data Protection Agency for additional information about your rights, and the DPO to raise any data protection complaint, or, where appropriate, file a complaint with the Supervisory Authority, the Spanish Data Protection Agency, especially when you have not obtained satisfaction in the exercise of your rights.