Privacy policy

This Privacy Policy regulates the collection and processing of personal data of our users and clients that is carried out through the websites (“Websites”), mobile applications, products, services, promotions and other personal data entry points of the different brands of the entity NEINVER, S.A.U. (hereinafter “Neinver“, “us” or “we”), and in particular, the following:

The purpose of this Privacy Policy is to inform users of our Websites, mobile applications, promotions and other products or services about the way in which we collect and use your personal data when you provide us with or we obtain your data through any of the channels available for this purpose, for example:

When you use the telephone, postal mail and email to contact us.
When you make use of the services and content offered on our Websites and mobile applications.
When you use the WiFi network of our shopping centres.
When you participate in any of the promotions we organise in our shopping centres or in a digital manner on our Websites and mobile applications.

Personal data means any information through which a natural person can be identified. For example, these are some of the personal data we may process about you, depending on how you use our services and features:

Identifying data, such as your name, surname, email address, telephone number, etc.
Economic and transactional information, such as your payment details, credit card details you use when shopping on our Websites, information about your purchases and orders etc.
Information about your tastes and preferences, for example those you indicate when you register as a user.
Information about your browsing profile on our Websites or mobile applications or location in our shopping centres.

Please note that we will never ask you to provide us with sensitive information, such as data relating to your ethnic or racial origin, political opinions, information about your criminal or administrative record or offences, religious or philosophical convictions, trade union membership, genetic data, biometrics, data relating to your lifestyle or sexual orientation, and so on. Accordingly, please never provide us with such information. If you voluntarily decide to do so, we will take the view that you are, expressly and unequivocally, granting your consent for the processing of such data. In any case, if we become aware that you have in any way provided us with sensitive data, we will delete it immediately.

Use of our Websites, mobile applications, products and services is restricted to those over 16 years of age only. Accordingly, if you are under the age of 16, you are prohibited from using and registering with us, or otherwise providing us with personal information. When you use our Websites, mobile applications, products or services, you must declare that you are 16 years of age or older. Otherwise, you must notify your parents or legal guardians before using or enjoying any of them.

On the other hand, we remind you that you should only give us personal data about yourself, never about third parties. If you provide us with personal data of third parties, you will be guaranteeing that you have informed them about the purposes and the way in which we will use them. In addition, any information you provide must be adequate, relevant, current, accurate and true, and must be updated at all times.

  WHO IS THE DATA CONTROLLER?

The data controller is Neinver, S.A.U., with registered address at Avenida Pío XII 44, 2º Planta, Edif. Oficinas 28016 Madrid, España, and email: neinver@neinver.com.

This means that we, Neinver, shall collect your data through the different websites mentioned above and we shall determine how to make use of it, as detailed in this Privacy Policy.

  WHAT IS THE PURPOSE OF PROCESSING YOUR DATA?

Depending on your use of our Websites, mobile applications, products, services and your participation in promotions, as well as the features you choose to enjoy, we will process your data for the following purposes:

1. To manage your registration as a user and the creation of Your Profile

When you register as a user on any of our Websites, applications, products, services or participate in promotions, we will process your personal data to manage the registration and create your account and user profile. The registrations through any of the above routes and the subsequent use of any of them are unified; this means that there is a single sign on and all the data we receive is part of a single database, regardless of the route through which you have registered, and that later you can use or enjoy a range of products or services using Your Profile. Please note that when you log in using Your Profile to access a Website, that session will remain logged in to that and any other Websites you choose to access for a period of [...], in order to facilitate your navigation through the different Websites.

When you register, you will receive at the email address you provided when you registered a message with an identity authentication link through which you must activate the account created by confirming your identity by clicking on an activation link. If you do not authenticate your account within 45 days of receiving this email, we will delete your data and accordingly it will not be included in our database.

As a user you are free to decide what information you want to include in Your Profile(s).

While registering, you will have the option to do so using your profile on social networks, such as Facebook. In this case, the data necessary to manage your registration, such as your name and email address, will be provided by the social network, always with your consent. The social network will never share more information about you with us, unless you give your consent or your privacy settings within the social network allow it. The collection and use of the information the social network collects about you is governed by its own privacy policies. Accordingly, if you decide to use this social network registration option, we suggest that you carefully read its terms and social network privacy policies.

2. To manage the purchase of products through our Websites and/or mobile applications

If you make purchases through our Websites or mobile applications, we will process your personal data in order to manage the purchase, so that you can enjoy our e-shop service and receive your order. This implies that we will process personal data for everything related to the purchase, i.e. payment data, shipping address, any possible return etc.

3. To answer your doubts and questions and respond to the requests you make through our Client Service channels.

If you contact us, whether in relation to a purchase or for any other reason, we will process your personal data to answer your query, give proper fulfilment to your request and offer a high-quality client service.

4.  For promotional and marketing purposes

This purpose may include the following:

If you decide to subscribe to our Newsletter, we will process your data in order to manage your registration in it and to send you by email and SMS promotional and advertising communications tailored on the basis of the tastes and preferences that you have indicated to us when you registered or when you subscribed, as well as in your profile. Remember that you can unsubscribe from our Newsletter at any time, free of charge, by changing your preferences in “Your Profile” or by clicking on the corresponding link that you will find in each communication we send you.
If you decide to participate in promotional actions (such as contests, sweepstakes, ability videogames, etc.), we will process your data to manage your participation in the promotional action. In addition, in that case, the promotional action will be subject to the relevant legal basis, in the context of which we may provide detailed information on the processing of personal data that we will carry out in relation to each promotional action.
We may also process your data for analytical purposes and to understand how each of our users is using our services, to create user profiles that will help us to offer you customized information and to tailor our offer according to your tastes, preferences and consumption and browsing habits on our Websites and mobile applications and in shopping centres. We believe that this is good for our users, since in this way we are able to offer you personalized information with the aim of reducing as much as possible the amount of spam or unwanted advertising you receive from us, which makes it possible for us to offer you a higher quality service.
In particular, bear in mind that if when you access any of our shopping centres you have activated the WiFi network or the bluetooth of your mobile terminal, we will collect data on your location in the centre, as well as the MAC address of your terminal and other data linked to that address, such as data on entering and leaving the shopping centre, time spent in the shops or premises of the shopping centre and activity carried out inside it. You can consult specific information about the data captured in each shopping center on the information signs placed at the accesses to them. If you use the WiFi network we offer or if you have used it in the past, we will link that information to the rest of your profile information. If you do not use the WiFi network, we will simply have information that does not allow a direct link with you and that we will use to determine in an aggregate way patterns and interests of visitors to shopping centres. In any case, you can object to us processing your data for this purpose at any time, as explained in the section on your rights below.

We also remind you that you can change your preferences and account settings at any time in the “Your Profile” section.

5. To provide you with Wi-Fi in our centres

As part of our services, in some of our centres we will offer you a WIFI network service, so that you can connect and surf the Internet, completely free of charge. In that case, we will use your data to provide you with the service. Remember that we will also use the data on your presence in our shopping centres and/or your geolocation data to understand your consumer habits so that we can personalise our communications and improve our offer to you.

 WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR DATA?

PURPOSE

1. To manage your registration as a user and the creation of Your Profile

We are entitled to process your data for this purpose since it is necessary for the performance of the contract that regulates the use of our Web site, mobile application, product, service or corresponding feature or the promotion in which you participate and that you accept when you register.

2. To manage the purchase of products through our Websites and/or mobile applications

Again, what legitimates us to process your data for this purpose is that the processing is necessary for us to perform the purchase contract you accept when making a purchase on any of our Websites or mobile applications.

3. To answer your doubts and questions and respond to the requests you make through our Client Service channels.

In this case, what legitimates us to process your personal data is the legitimate interest that we have in being able to attend to your doubts and requests in order to provide you with a high-quality Client Service.

4.  For promotional and marketing purposes

When we process your data to send you our Newsletter and to manage your participation in promotional actions, we will do so based on the consent you give us before subscribing to the newsletter or registering to participate in the promotional action. When we process your data for analytical purposes and to create user profiles, we do so on the basis of our legitimate interest. The specific data processing carried out for a promotional action is based on the performance of the corresponding legal bases.

5. To offer you Wi-Fi on our centres

The data we obtain about you when providing the WIFI service in our centres will be processed because it is also necessary for the performance of the contract you accept by accessing the service. Also, the collection and incorporation to Your Profile of the data of presence in the shopping centers and/or of geolocation is made based on our legitimate interest in obtaining statistics on the visitors of the shopping centers and in improving and personalizing our offer towards you.

 HOW LONG WILL WE PROCESS YOUR DATA FOR?

1. To manage your registration as a user and the creation of Your Profile on our Websites, mobile applications, products, services, features or participate in promotions.

We will process your data for as long as you continue to be a registered user. If you delete your account, we will stop processing your data for any purpose.

After that, we shall process your data duly blocked during the time in which any liabilities may arise from the data processing, according to the current regulation at all times. Once all possible actions have completed their period of prescription, we will proceed to fully delete your data.

2. To manage the purchase of products through our websites and/or mobile applications

We will process your data for as long as is necessary so that we can manage the purchase of the product that you acquired, including any possible refund or complaint made regarding the same.

3. To respond to any doubts and questions and to answer any requests that you make via our Customer Service channels

We will process your data for as long as is necessary in order to answer all of your questions and queries and to respond to your requests or complaints.

4.  For promotional and marketing purposes

Regarding the delivery of our Newsletter, we will process your data for as long as you subscribe to it. When you participate in promotional activities, we will process your data for as long as is necessary in order to manage your participation. Please note that we may continue to use your data for other purposes, such as to allow you to continue to use Your Account to access other services, Websites, applications or promotions; also to send you the Newsletter, if you have consented to it. We will process your data to update your profile until you object to it.

5. To offer you Wi-Fi on our centres

We will process your data for as long as it is necessary in order for us to provide you with the Wi-Fi service. In addition, we will process your presence data in shopping centres and/or geolocation as long as you do not object to it. Remember that at any time you can object to us continuing to process your data, as explained in the section of your rights in this Privacy Policy.

DO WE SHARE YOUR DATA WITH THIRD PARTIES?

In order to provide our services and for you to enjoy the different functions that we offer, it is necessary for us to share your personal data with various third parties. Specifically:

With companies from the Neinver group, to receive advertising communications on products and services from the mentioned companies via postal mail, email and other means of equivalent electronic communication. Specifically, with the following companies.
Neinver Asset Management España: S.L. Avenida Pío XII 44, 2º Planta, Edif. Oficinas 28016 Madrid, España
Neinver Asset Management Polska Sp. z o.o. Żelazna 28/30, 00-832 Warszawa (Poland)
Neinver Czech S.R.O. Prague 8, Pobrezni 620/3 Czech Republic
Neinver France Sarl  8-10 rue de la Ferme 92100 Boulogne Billancourt – France
Neinver Netherlands BV. Amstelveenseweg 760, 1081JK Amsterdam
Neinver La Toja. Avenida Pío XII 44, 2º Planta, Edif. Oficinas 28016 Madrid, España. ES B85385920
Neinver Polska Sp. z o.o.. Żelazna 28/30, 00-832 Warszawa (Poland). PL 5272310154
Neinver Italia spa. Piazza Santa Caterina 1 28060 Vicolungo (NO) – Italy. IT 13218740150
Third party companies belonging  to the following industries: telecommunication, financial, entertainment, education, automotive, energy and water, Non-profit and large consumption companies, so that said companies may send you (via postal mail, email and other means of equivalent electronic communication) advertising communications on their products and services, assuming that you have specifically authorized this by marking the relevant enable boxes on the website and mobile application registration forms.
We may also contract service providers that will have access to your personal data in order to process said data when providing us with their service.

  WHAT ARE YOUR RIGHTS WHEN YOU PROVIDE US YOUR DATA?

At Neinver we are committed to and concerned about your privacy. Therefore, we shall always respect the confidentiality of your personal data and we guarantee that your rights shall be exercised, in accordance with all applicable regulation.

To exercise your rights, you only need to write an email to the following address: neinver@neinver.com . You may do so at any time and free of charge.

Specifically, you may exercise the following rights, depending on the purpose for which we process your data depending on the purposes that you choose to enjoy:

Access to your personal data that we have at our disposal. Furthermore, we remind you that you may check the data that we have on you and may modify your preferences and account configuration at any time via the “Your Profile” section.
Request that we rectify the data that we have about you. Keep in mind that you can modify some of the data yourself via the “Your Profile” section.
Request that we erase your personal data, as long as it is not necessary for our processing of the same for the purposes for which we originally collected said data, or we shall no longer be legitimized to do so.
Request that we restrict the processing of your personal data.

As long as we process your data under your consent, as explained in this Privacy Policy, you also have the right to revoke said consent at any time. On the other hand, when this processing is based on our own legitimate interest, you have the right to object to our processing of your data.

Specifically, we inform you that you can object to our processing of your data used for analytical purposes when creating profiles, as detailed above.

You will also have the right to request the portability of your data when our lawful base for the processing is based on your consent or the performance of a contract.

In any case, you will always have the right to file a claim before the relevant data protection control authority, generally being the Spanish Data Protection Agency (AEPD), contacting them via telephone: +34 901 100 099, or website here.

We inform you that when using our Websites and mobile applications, we will use cookies for different purposes. If you want more information about the use of cookies, you can consult our Cookies Policy here.

UPDATES TO THIS PRIVACY POLICY

We may occasionally update this Privacy Policy. Any modifications to this policy will be posted and noticed on the Website and mobile applications and in the policy itself, and we will do our best to notify you of any modifications. In any event, we recommend that you periodically access the Privacy Policies posted on the Website and mobile applications in order to be aware of the latest version of the policy at all times.