Privacy policy

1. Who are we?

We are ZNR DISTRIBUTION SPRL and we process your personal data as the Data Controller. This means that we are responsible for handling the processing and protection of your personal data.

2. Why do we use your personal data?

Among other purposes, we use your data (collected online or in person) to manage your registration as a user, process the purchase of products or services, respond to your inquiries, and send personalized communications if you so wish.

3. What is the legal basis for processing your personal data?

We are authorized to process your data for various reasons. The main one is that it is necessary to perform the contract you enter into with us when registering and making a purchase or using any of our services or features. There are also other legal grounds that allow us to do so, such as our legitimate interest in responding to your inquiries or the consent you provide to receive our newsletters, among others.

4. With whom do we share your data?

We may share your data with service providers who assist us or provide the necessary support, such as external collaborators with whom we have entered into agreements, whether they are located within or outside the European Union.

5. Your rights?

You have the right to access, rectify, and delete your personal data. In certain cases, you also have additional rights, such as the right to object to the processing of your data or the right to data portability, which will be described in more detail below.

We invite you to read our Privacy and Cookie Policy in its entirety to fully understand how we will use your personal data and the rights you have in relation to it.

Before we begin…

• In this Privacy and Cookie Policy, you will find all relevant information applicable to the way we use the personal data of our customers and users, regardless of the channel or means you use to interact with us.

• We are transparent about how we use your data so that you understand the implications of the processing activities carried out and the rights you have over your data:

– All information is permanently available to you in this Privacy and Cookie Policy, which you may consult at any time; and
– Information regarding each specific processing of your personal data will also be provided as you interact with us.

• In this Privacy and Cookie Policy, when we refer to our “Platform,” we generally mean any digital or physical channel through which you have interacted with us, including primarily:

– Our website: www.urbanpulseofficial.com

1. Who is responsible for processing your personal data?

The entity responsible for processing your personal data is:

ZNR DISTRIBUTION SPRL

Advertising and Tracking Technologies
We use tracking technologies, including the Meta Pixel, to understand how visitors interact with our website, improve our services, and deliver relevant advertising across platforms such as Facebook and Instagram. These tools may collect information about your device, browser, and browsing behavior on our site.

The information collected may be used to:

• Measure the effectiveness of our ads

• Show you personalized advertisements

• Improve the user experience on our Platform

2. Why do we process your personal data?

We process certain data depending on the products, services, or features you wish to use at any given time. In general, this data includes:

• Identification data (for example, your first name, last name, language, country from which you interact with us, contact details, etc.)
• Financial and payment information (for example, payment card details, information about your purchases, orders, returns, etc.)
• Connection, geolocation, and browsing data (if you interact with us from your mobile device, for example)
• Commercial information (for example, if you subscribe to our newsletter)
• Information about your tastes and preferences

When we ask you to provide personal data to access a feature or service of the Platform, please note that certain fields will be marked as mandatory. These are data we need in order to provide the service or allow access to the feature. If you choose not to provide this information, your registration may not be completed successfully, or you may not be able to use certain services or features.

Purpuses of processing

1. To manage your registration as a user of the Platform

If you decide to register as a user of our Platform, we need to process your data to identify you as a user and allow you access to the different features, products, and services available to registered users. You may delete your user account at any time by contacting Customer Service.

2. For the implementation, execution, and management of the purchase or service contract concluded with us on the Platform

This purpose includes processing your data in particular to:

• Contact you regarding updates or informative communications related to features, products, or services purchased, including sending quality surveys regarding provided products or services.

• Manage payment for products purchased, regardless of the payment method used.

For example:

– If you choose to activate the feature allowing your payment card details to be saved for future purchases, we will need to process the indicated data to activate and implement this feature. Your consent to activate this feature allows your payment data to be automatically displayed for future purchases so that you do not need to re-enter it each time. You may modify or delete your payment card details at any time in the payment information section of your user account.

– Activate necessary mechanisms to prevent potential fraud against you and against us during the purchase process. If we consider that a transaction may constitute a fraud attempt, this processing may result in blocking the transaction.

• Manage returns after purchase and handle requests related to product availability, reservations through the Platform, or services related to Personal Tailoring, depending on availability.

• Issue invoices and make receipts available for purchases made on the Platform.

• Enable other available services, such as purchasing, managing, and using a Gift Card or Gift Ticket.

3. To respond to requests or inquiries made through Customer Service channels

We only process the personal data strictly necessary to manage or resolve your request or inquiry.

4. For marketing purposes

This purpose includes processing your data, subject to your consent, particularly for:

• If you subscribe to our Newsletter, we will process your personal data to manage your subscription, including sending targeted information about our products or services through various means (such as email or SMS). We may also send this information through push notifications if they have been activated on your mobile device.

• We would like to inform you that this data processing involves analyzing your user or customer profile to determine your preferences and identify which products or services are most suitable for your style, in order to send you relevant information. For example, based on your purchase and browsing history (that is, the items you have clicked on), we may suggest products that we believe may interest you. If you are a registered user, we may also provide the “cart recovery” feature.

• Please note that you may unsubscribe from the Newsletter at any time and at no cost through the “Newsletter” section of the Platform, as well as through the instructions included in each communication. If you no longer wish to receive push notifications, you may disable this option directly on your mobile device.

• Implementation of promotional activities (for example, organizing contests or sending your saved item list to the email address you provide). By participating in a promotional activity, you authorize us to process the data provided in accordance with the terms of that activity and to publish it through various channels such as social networks or the Platform itself. The legal basis for each promotional activity in which you participate will be made available to you, including more detailed information on the processing of your data.

• Publishing on the Platform or through our social media channels photographs or images that you have publicly shared, if you give us your consent to do so.

5. Analysis of usability and quality to improve our services

When you access our Platform, you are informed that we will process your browsing data for analytical and statistical purposes, in order to understand how users interact with our Platform and to introduce improvements.

Please refer to our Cookie Policy for further information.

We may also conduct quality surveys or actions to measure customer satisfaction and identify areas where we can improve our services.

3. What is the legal basis for processing your personal data?

The legal basis that allows us to process your personal data depends on the purpose for which it is processed, as explained below:

1. Managing your registration as a user of the Platform

The processing of your data is necessary for the execution of the terms governing the use of the Platform. In other words, the processing of your personal data is required to allow you to register as a user; otherwise, your registration could not be completed.

2. Implementation, execution, and management of the purchase or service contract

The processing of your personal data is necessary for the performance of the purchase or service contract through which we are bound.

Certain data processing related to the purchase process may only occur if you request it or expressly authorize it, such as saving payment card details for future purchases or processing data necessary to scan purchase receipts.

In such cases, the legal basis for processing your data is your consent.

We also consider that we have a legitimate interest in carrying out the necessary checks to detect and prevent potential fraud when you make a purchase. We believe this processing is in the interest of all parties involved in a transaction, and particularly in your interest, as it allows us to implement preventive measures to protect you from fraudulent activities by third parties.

3. Customer Service

We consider that we have a legitimate interest in responding to inquiries or requests made through available contact channels. We believe this processing is also in your interest, as it allows us to properly manage your requests and answer your questions.

When you contact us regarding issues related to your order or a purchased product or service, processing is necessary for the performance of the purchase contract.

When your request concerns the exercise of rights described below or complaints regarding our products or services, processing is based on compliance with our legal obligations.

4. Marketing

The legal basis for processing your data for marketing purposes is the consent you provide, for example when you agree to receive personalized information through various channels, authorize push notifications on your mobile device, accept the legal terms of a promotional campaign, or consent to the publication of your photos on the Platform or our social media channels.

In order to provide you with personalized information, we consider that we have a legitimate interest in profiling you based on the information available to us (such as the pages you visit, your preferences, or your purchase history) and the personal data you have provided (such as your age range or language). We believe that this processing is also in your interest, as it enhances your user experience and allows you to receive information aligned with your preferences.

5. Analysis of usability and quality

We consider that we have a legitimate interest in analyzing the usability of the Platform and the level of user satisfaction, as this processing allows us to improve the user experience and offer a higher quality service.

4. How long will your data be kept?

The retention period for your data depends on the purposes for which it is processed, as explained below:

1. Managing your registration as a user of the Platform

Your data will be processed for as long as you remain a registered user (that is, until you decide to delete your user account).

2. Implementation, execution, and management of the purchase or service contract

We will process your data for the time necessary to manage the purchase of the products or services you have acquired, including any returns, complaints, or claims related to that purchase.

In certain cases, we will process your data only until you decide otherwise, such as in the case of payment card details that you have requested us to store for future purchases.

3. Customer Service

We will process your data for the time necessary to respond to your request or inquiry.

4. Marketing

We will process your personal data until you unsubscribe or cancel your subscription to the newsletter.

If you participate in promotional campaigns, we will retain your personal data for six months following the end of the campaign.

5. Analysis of usability and quality

We will process your data occasionally for the duration of a specific quality action or survey, or until your browsing data has been anonymized.

Regardless of the above retention periods, your personal data may be stored, duly secured and with restricted access, for the period during which liability may arise in accordance with applicable regulations. Once the applicable legal limitation periods have expired, your data will be deleted.

5. Will your data be shared with third parties?

To fulfill the purposes described in this Privacy and Cookie Policy, access to your personal data may be granted to entities within the ZNR DISTRIBUTION group and to third parties who assist us in providing services, including:

• Financial institutions
• Fraud detection and prevention entities
• Technology service providers
• Logistics, transport, and delivery partners
• Customer service providers
• Marketing and advertising service providers

For service efficiency reasons, some of these providers may be located outside the European Economic Area, in countries where the level of data protection may not be equivalent to that of the European Union, including the United States.

In such cases, we inform you that your data will be transferred with appropriate safeguards in place and that the security of your data will always be maintained.

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

We are committed to respecting the confidentiality of your personal data and to ensuring that you can exercise your rights.

As Data Controller, we have agreed that you may exercise your rights free of charge by sending an email to:

contact@urbanpulseofficial.com

Simply indicate the reason for your request and the right you wish to exercise. If we consider it necessary to verify your identity, we may request a copy of an identification document.

Regardless of the purpose or legal basis under which we process your data, you have the right to:

• Request access to the data we hold about you. If you are a registered user of the Platform, you may also access this information in the section corresponding to your personal data within your account.

• Request the correction of data we hold about you. If you are a registered user, you may modify or update your personal data directly in your account. Please remember that by actively providing your personal data through any means, you guarantee that it is accurate and truthful and undertake to notify us of any changes. Any damage caused to the Platform, the Data Controller, or any third party due to the communication of incorrect, inaccurate, or incomplete information will be the sole responsibility of the user. As a general rule, you should only provide your own personal data and not that of third parties, except where permitted in this Privacy and Cookie Policy.

• Request the deletion of your data when it is no longer necessary for the purposes for which it was collected, as explained above, or when we are no longer legally entitled to process it.

• Request the restriction of the processing of your data, which means that in certain cases you may ask us to temporarily suspend processing or retain the data longer than necessary if you require it.

If you have given your consent for the processing of your data for any specific purpose, you also have the right to withdraw that consent at any time. Certain methods for withdrawing consent are explained in Section 2, where we describe the purposes of data processing.

As explained in Section 3, when the processing of your data is based on your consent or on the performance of a contract, you also have the right to request data portability. This means you have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format, and to transmit it directly to another entity where technically feasible.

In addition, where the processing of your data is based on our legitimate interest, you have the right to object to such processing.

Finally, we inform you that you have the right to lodge a complaint with the relevant data protection supervisory authority.

We offer certain features or services that require the processing of personal data belonging to a third party that you provide to us, such as in the case of activating and sending a Gift Card or managing a Gift Ticket request.

If you provide personal data relating to third parties, you guarantee that they have been informed about the purposes and manner in which we need to process their personal data.

8. Changes to the privacy and cookie policy

The information contained in this Privacy and Cookie Policy may be modified if we consider it appropriate.

If this occurs, you will be notified through various means on the Platform (for example, via a banner, a pop-up window, or a push notification), or even communicated to your email address if the change in question is particularly significant for your privacy. This will allow you to review the changes, assess them, and, where appropriate, object to them or withdraw from a service or feature.

In any case, we recommend that you review this Privacy and Cookie Policy from time to time to stay informed about minor changes or improvements, taking into account that it will always remain permanently accessible on our website:

www.urbanpulseofficial.com

9. Cookie information

We use cookies and similar devices, subject to your consent where required, to facilitate your navigation on the Platform, to understand how you interact with us, and, in certain cases, to provide you with advertising tailored to your browsing habits.

We invite you to read our Cookie Policy to obtain more detailed information about the cookies and similar devices we use, their purpose, and other relevant information.

INFORMATION ABOUT COOKIES

What is a cookie?

A cookie is a small text file that a website installs on your computer, phone, or other device, containing information related to your browsing activity on that website.

Cookies are necessary to facilitate navigation and make it more user-friendly, and they do not damage your device.

Although the general term “cookies” is used in this policy, as it is the primary method of storing information used by this website, the browser’s “local storage” is also used for the same purposes as cookies. In this respect, all information included in this section also applies to local storage.

What are cookies used for on this website?

Cookies play an essential role in how our website functions. Their main purpose is to improve your browsing experience.

For example, cookies allow us to remember your preferences (such as language or country) during navigation and for future visits.

The information stored in cookies also enables us to improve the website through estimates of usage numbers and patterns, adapt it to users’ interests, optimize search speed, and more.

In some cases, if we have obtained your prior informed consent, we may use cookies, tags, or other devices to collect information that allows us to display advertising to you, either from our own website or from third-party websites, based on the analysis of your browsing habits.

What are cookies NOT used for on this website?

We do not store sensitive personal data such as your address, password, or payment card details in the cookies we use.

Who uses the information stored in cookies?

The information stored in cookies on our website is used exclusively by us, except for those identified as “third-party cookies,” which are used and managed by external entities to provide services requested by us in order to improve our services and your experience when browsing our website.

The main services for which these third-party cookies are used include obtaining access statistics and ensuring the proper execution of payment transactions.

How can you avoid the use of cookies on this website?

If you prefer to avoid the use of cookies on this website, taking into account the limitations described above, you must first disable the use of cookies in your browser and then delete the cookies stored in your browser that are associated with this website.

You may use this option to prevent the use of cookies at any time.

How to disable and prevent the use of cookies?

You may restrict, block, or delete cookies from this website at any time by modifying your browser settings, following the steps indicated above.

Although settings vary depending on the browser, cookie configuration is generally found in the “Preferences” or “Tools” menu.

For more detailed information on configuring cookies in your browser, please consult your browser’s “Help” menu.