Privacy Policy

PRIVACY POLICY

General information

At Aristocrazy (hereinafter, “Aristocrazy”), we are committed to protecting your privacy and ensuring the security of your personal data. To this end, we have adopted a transparent policy that will allow you to understand how we collect, process and protect your personal data when you access or use our services.

Through this Privacy Policy, we inform you in detail about:

  • Who is responsible for your data? The data controller is Aristocrazy, S.A. In most cases, we act as the sole controller of such data.
  • How do we process your data? Your personal data will be processed for the purpose of managing your registration as a customer, sending you commercial communications, coordinating events, managing contests and draws, carrying out staff selection processes, ensuring the security of our premises through video surveillance systems, among others.
  • What rights do you have and how can you contact us? You have the right to access, rectify, delete, object to, and restrict the processing of your data, as well as other rights that will be detailed below. To exercise your rights or contact our Data Protection Officer (DPO), you may send us an email at puertorico@aristocrazy.com.

The information contained in this privacy portal also includes specific details about the processing of personal data collected in connection with the execution of the services you contract.

Data Controller

The data controller is Aristocrazy, S.A., hereinafter identified as “Aristocrazy” or the “Controller”.

§ Postal Address: 525 FD Roosevelt Avenue Plaza Las Américas 424 San Juan, PR 0918

§ DPO Email: puertorico@aristocrazy.com

In certain circumstances, such as the physical sale of products in other countries, Aristocrazy may act as a joint controller together with other group entities. This applies, for example, in Portugal and Mexico, where Aristocrazy and Pináculos Singulares, LDA and Aristocrazy México, S de R.L. de C.V., respectively, act as joint data controllers. For more information about data processing at our physical points of sale, please refer to the specific section titled “Data processing at physical points of sale”.

Processing of data collected through our website

On our website, we process the personal data of users who browse our website or who provide their information through the available forms. Data may be collected in various ways:

Registration as a user at Aristocrazy

Registering as a user on our platform will allow you to make online purchases, access Aristocrazy news, save your favourite jewellery, among other things.

  • Purpose: When you contact us, we may request only the data strictly necessary to manage and resolve your request or query. If you use third-party channels such as WhatsApp or social media, please be aware that your data will also be processed by those third parties, so we recommend consulting their privacy policies and settings. We also inform you that, when assistance is provided by phone, Aristocrazy may record and transcribe the call in order to handle your contact request through our phone channel and ensure its quality.
  • Legal basis: The processing of your personal data by us is carried out either on the basis of your consent, or for the performance of a contract to which you are party (e.g. when dealing with queries and/or incidents related to a purchase), or for compliance with a legal obligation on our part (e.g. when the query involves claims related to our products or is related to the exercise of a data protection right), or for the defence of our legitimate interests.
  • Recipients: Data will be processed by our legal advisors and, if necessary, by customer service platforms such as Zendesk, which store data outside the EU under a data processing agreement and the corresponding standard contractual clauses (SCCs). In addition to the aforementioned third parties (WhatsApp and social media), which may involve an international data transfer, we may disclose your data to insurers, lawyers or authorities, only in the case of a legal obligation.
  • Retention: We will process your data for as long as necessary to handle your request or query.

Aristocrazy Universe

The Aristocrazy Universe community offers exclusive access to content such as news, events, new collections, private sales, newsletters and other benefits. Users can register via the form “Join our community”, when making a purchase or when registering on our website.

  • Purpose: The processing of personal data aims to send commercial and promotional communications about Aristocrazy products and services, invitations to events, participation in contests and draws, and sending newsletters by email, SMS and WhatsApp. We will also collect your date of birth to send you a birthday greeting. In addition, we analyse preference profiles, interests and activity on the website and social media, as well as sales generated through our communications. However, these analyses do not involve automated decision-making that could affect users. Please note that you may object to these processing activities (see below).
  • Legal basis: The legal basis for processing your data obtained through the aforementioned form is the consent provided by the user. We also process your personal data on the basis of our legitimate interest for sending commercial communications about similar goods and services, by virtue of an existing customer relationship (having made a purchase or registered on our platform). Legitimate interest is also used as the legal basis for showing you personalised information.
  • Recipients: Data will not be disclosed to third parties, except to providers who offer us marketing and technology-related services, who will act as data processors. Furthermore, if you contact us via WhatsApp, please note that the use of this service may involve an international data transfer, as WhatsApp operates under policies that may involve storing data outside the European Union. We therefore recommend reviewing that provider’s privacy policies.
  • Retention: You may unsubscribe from the community at any time, either by email or via SMS or WhatsApp, by following the instructions provided in each communication. Personal data will be retained until you request to unsubscribe, after which we will proceed to delete it.

Online purchase process

Our website has an e-commerce function that allows online purchases for both registered users and guest buyers.

  • Purpose: We process your data to manage and execute the sales contract, managing the customer relationship throughout the entire process, from initial interest (product enquiry or viewing) to after-sales care. This includes sending quality surveys, communications relating to purchased products (see previous section), fraud prevention (see section below), management of repair and return services. Additionally, and only when requested, we can process your data to prepare a full invoice.
  • Legal basis: The processing of your personal data is necessary for the performance of the sales contract, in accordance with the General Terms governing the online sale of our products. Where a full invoice is required, the legal basis will be compliance with a legal obligation.
  • Recipients: Your data will only be disclosed to third parties who provide us with services and act as data processors, such as technology providers, legal advisors, and logistics and transport companies for product delivery.
  • Retention: We retain your data for as long as necessary to manage the product purchase, including possible returns or incidents. In general, purchase data will be retained for a maximum of 6 years, unless anti-money laundering regulations require a longer period, as indicated in the section “Data processing for AML/CTF purposes”).

Recruitment process

Through the “Work with us” section, candidates can submit their CV or apply for job openings, provided they have an InfoJobs account. The following information supplements the informative clauses of each vacancy:

  • Purpose: We manage candidate data for Aristocrazy’s staff recruitment process.
  • Legal basis: This processing is legitimised by the intention to establish an employment relationship.
  • Recipients: Your data will be obtained from InfoJobs. Additionally, with your consent, they may be transferred to companies within our Group. In any other case, your data will not be shared with third parties, except under a legal obligation.
  • Retention: Similarly, and unless you instruct us otherwise, we inform you that if you are not selected for the requested position or do not match the profile of currently open processes, your data will be retained for future selection processes that may match your profile for a maximum period of two years (at which point your data will be permanently deleted).

Data processing in customer service

At Aristocrazy we provide various customer service channels, such as phone, email, our chat and social media.

  • Purpose: When you contact us, we may request only the data strictly necessary to manage and resolve your request or query. If you use third-party channels such as WhatsApp or social media, please be aware that your data will also be processed by those third parties, so we recommend consulting their privacy policies and settings.
  • Legal basis: The processing of your personal data by us is carried out either on the basis of your consent, or for the performance of a contract to which you are party (e.g. when dealing with queries and/or incidents related to a purchase), or for compliance with a legal obligation on our part (e.g. when the query involves claims related to our products or is related to the exercise of a data protection right), or for the defence of our legitimate interests.
  • Recipients: Data will be processed by our legal advisors and, if necessary, by customer service platforms such as Zendesk, which store data outside the EU under a data processing agreement and the corresponding standard contractual clauses (SCCs). In addition to the aforementioned third parties (WhatsApp and social media), which may involve an international data transfer, we may disclose your data to insurers, lawyers or authorities, only under a legal obligation.
  • Retention: We will process your data for as long as necessary to handle your request or query.

Data processing at physical points of sale

Los datos personales proporcionados en nuestras tiendas físicas serán tratados por Aristocrazy. En determinados casos, como en puntos de venta en otros países, como Portugal y México, los datos pueden ser tratados también por la sociedad del grupo en ese país. En tales casos, actuamos como corresponsables de los datos con la sociedad en cuestión y se firma el correspondiente contrato de corresponsabilidad, que establece los objetivos y medios del tratamiento.

  • Purpose: We process your data to perform the sales contract, managing the customer relationship at every stage, from product enquiry or viewing to after-sales care. This includes sending quality surveys, communications about purchased products (see section), fraud prevention (see section “Data processing for AML/CTF purposes”), and management of repair, maintenance (Aristocrazy Care) and return services. We may also contact you to notify you when the product is ready or if there is any other type of update.
  • Legal basis: The processing of your personal data is necessary for the performance of the sales contract.
  • Recipients: Data will only be disclosed to third-party providers who supply us with services and act as data processors, such as technology providers or legal advisors.
  • Retention: We retain your data for as long as necessary to manage the product purchase, including returns or incidents. Purchase data will be retained for a maximum of 6 years, unless anti-money laundering regulations require a longer period, as specified in the corresponding section.

Data processing through the Aristocrazy “Try-On” virtual fitting room

At our store located at Avenida Diagonal, 594, 08021 - Barcelona, we have a virtual piercing and earring fitting room, hereinafter referred to as “Try-On”. When you choose to use this platform, we will process your image data, which includes biometric data, so that you can virtually try on the piercings and earrings in our store and preview the results safely and realistically before purchasing our products.

  • Purpose: We will process your personal data to provide you with a personalised experience in our Try-On virtual piercing fitting room.
  • Legal basis: The legal basis for the processing will be your explicit consent, provided for in Article 6.1(a) of the GDPR. This consent may be revoked at any time by sending a request to the email address provided in the section “Rights. What are your rights when you provide us with your data?”.
  • Recipients: Your data will not be shared with third parties, except with our technology provider who will act as a data processor, or where there is a legal obligation to do so. International data transfers may take place. In such cases, we guarantee that these transfers will be carried out in compliance with all the safeguards and security standards established by the GDPR.
  • Conservación: Sus datos solo se conservarán 24 horas y posteriormente serán eliminados. También podrá solicitar la supresión de sus datos dirigiéndose a la dirección de correo indicada en el apartado correspondiente.

Data processing for AML/CTF purposes

At Aristocrazy, as entities subject to anti-money laundering and counter-terrorism financing regulations (hereinafter, “AML/CTF”), we process additional data when transactions exceed one thousand euros. Below we explain how we will process your data in this context:

  • Purpose: We process your personal data to comply with the legal obligations established in AML/CTF regulations. This includes identity verification, assessment of the financial transaction, and prevention of money laundering and terrorist financing.
  • Legal basis: The legal basis for the processing will be compliance with the provisions of Law 10/2010, of 28 April, on the prevention of money laundering and terrorist financing.
  • Recipients: Personal data may be disclosed to the competent authorities in matters of anti-money laundering and counter-terrorism financing, provided that such disclosure is made in compliance with our legal obligations. Data may also be disclosed to our legal advisors and technology providers, who will act as data processors.
  • Retention: The information will be retained for a period of 10 years, after which it will be deleted ensuring its confidentiality. After five years from the end of the transaction, the retained documentation will only be accessible by the internal control bodies of the obliged entity, including the technical prevention units, and, where applicable, those responsible for its legal defence.

Video surveillance data processing

At Aristocrazy, we have video surveillance systems on our premises. The following information supplements the informational signs located in our stores and centres:

  • Purpose: We process the images obtained through the video surveillance systems installed in our administrative offices and establishments open to the public in order to preserve the security of people, property and the premises.
  • Legal basis: This processing is legitimised based on legitimate interest and is carried out in accordance with Law 5/2014, of 4 April, on Private Security.
  • Recipients: This data may be accessed by companies with which we have subcontracted security services, as well as technical maintenance services for our video surveillance cameras, acting as data processors. Data may also be disclosed to law enforcement agencies, if necessary.
  • Retention: Data will be retained for a maximum period of 30 days, unless it is necessary to retain them for longer in order to clarify any infringement or unlawful act detected.

Rights: What are your rights when you provide us with your data?

You have the following rights in relation to your personal data:

  • Right of access: You have the right to obtain confirmation as to whether Aristocrazy is processing personal data concerning you. You also have the right to access such data.
  • Right to rectification: You may request the rectification of incorrect or incomplete data concerning you. You also have the right to restrict its processing.
  • Right to erasure: You have the right to request the deletion of data concerning you, in the cases provided for by the regulations.
  • Right to data portability: You may request that the personal data concerning you be provided to you in a structured, commonly used and machine-readable format.
  • Right to object and to withdraw consent: You have the right to object to the processing of your personal data, provided that the processing is based on legitimate interest. You may also withdraw your consent at any time.
  • Right to restriction of processing: You may request the restriction of the processing of your personal data to those cases you deem appropriate, without prejudice to being able to modify your preferences at any time.
  • Right not to be subject to automated individual decisions (including profiling): You have the right not to be subject to decisions based solely on the automated processing of your data that produce legal effects that significantly affect you.

To exercise your rights, you may send an email to puertorico@aristocrazy.com. You may also lodge a complaint with the Data Protection Agency, especially when you have not obtained satisfaction in the exercise of your rights, at the postal and/or electronic address indicated on the page www.aepd.es.

Security measures

Data will be processed confidentially and subject to appropriate technical and organisational security measures to prevent their alteration, loss, unauthorised processing or access.