Data Protection and Privacy Notice

This Notice applies to anyone who visits Eskadi.com’s websites orEskadi.com’s mobile applications (the "Sites"), and any other platforms Eskadi.com owns or controls and makes available (the "Eskadi.com Platforms"). We refer to the Sites and Eskadi.comPlatforms as the "Services".

When you use the Services, you access linked pages or blogs, features and content (including any information, text, graphics, photos, lists of items compiled by you, comments, reviews, links, or other materials uploaded, downloaded or appearing on, or linked to the Services) (collectively the "Content").

Any personal data about our users (the "User" or "you") provided to or gathered by the Services is controlled by Eskadi.com LTD (a company incorporated in England and Wales, with company number 13285581 and with a registered office at 86-90 Paul Street, London, EC2A 4NE ("Eskadi.com", "we", "our" or "us"). For the purposes of General Data Protection Regulation (the "GDPR"), Eskadi.com acts as a "Controller" as defined under the GDPR ("Controller").

1. What Does This Notice Cover?

This Notice covers Eskadi.com’s treatment of personal data thatEskadi.com gathers when you access the Services and/or access the Content. We explain what information we gather, why we gather it and the choices you have regarding your personal data.

2. What Information Does Eskadi.com Collect, and How?

As customers, you do not have any legal obligation to provide any information to Eskadi.com. However, we require certain information from you in order to operate properly. Login credentials (your email) enable us to personalize and improve our services. You hereby agree and acknowledge that any information you do provide to us is provided at your own free will, for the purposes mentioned in this Privacy Notice and that we may keep such information in a database(s) which will be registered and kept in accordance with applicable laws and regulations.

a) Information You Provide to Us

We receive and store any information you enter on the Services or provide to us in any other way. The types of information provided by you may include your full name and email address.

b) Information Collected Automatically

i. We receive and store certain types of information whenever you interact with the Sites or use another feature of the Services. In other words, when you are using the Services we are aware of it and may gather, collect and record the information relating to such usage, either independently or through the help of third-party services as detailed below. Eskadi.com automatically receives and records information on our server logs from your browser including your IP address, certain cookie information (please see our Cookie Notice for further information) unique identifiers (such as click IDs) and the page you requested.

ii. We automatically collect usage information, such as the numbers and frequency of visitors to the Services, similar to user music preference data or to TV ratings that indicate how many people watched a particular show. Eskadi.com only uses this data in aggregate form, that is, as a statistical measure, and not in a manner that would identify you personally. This type of aggregate data enables us to figure out how often customers use parts of the Services or another feature of the Content so that we can make the Services appealing to as many customers as possible, and improve the Content.

iii. We also collect information about the devices you use to access our Services. This includes, for example, the type of computer or device you use, the hardware model, operating system and software.

c) E-mail Communications

Our CRM software recognises when an individual receives, opens and clicks through from one of our emails. Eskadi.com uses this information to help us decide how to make emails more interesting and helpful. You may opt out of emails at any time.

d) Location Information

When you download or use apps created by Eskadi.com or its affiliates or subsidiaries and, where applicable, have requested or consented to location services, we may receive information about your location. We may use this information to provide you with personalised content and location-based services, such as search results. Most mobile devices allow you to turn off location services. To learn more about what information your device makes available to us, please also check the policies of your device manufacturer or software provider.

3. What About Cookies?

Technologies such as cookies, beacons, tags and scripts are used byEskadi.com and our partners, affiliates, analytics or service providers. These technologies are used in analyzing trends, administering the Sites, tracking users’ movements around the Sites and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

Please see our Cookie Notice for information as to how we use cookies in relation to the Services.

4. Why Do We Collect Information?

We use the information we collect in order to:

Operate and improve the Services and to display Content

Allow you to take full advantage of the Services, including using "Wish Lists"

Recommend relevant products, and make it easier for you to track products you’re interested in

Offer you a personalised experience of the Services and on Eskadi.comSites. This process constitutes profiling under the GDPR

Communicate with you about your orders and provide customer service, technical assistance and collect feedback

Communicate with you about products, sale reminders, services and promotional offers

Administer your account if you have one, and update our records

Enable third-party service providers and contractors to carry out technical, logistical or other functions on our behalf

Conduct research, troubleshoot problems and detect and protect against error, abuse of the Services, fraud or other criminal activity

Control risk, comply with laws and regulations and comply with other legal process and law enforcement requirements

Produce aggregated statistical reports (provided that the reports do not identify customers)

5. Where Will We Store Your Information?

To provide the Services, the information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed and used by staff operating outside the EEA who work for us or by one of our third-party service providers. Such staff may be engaged in, among other things, the fulfilment of your request, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that third parties to whom we transfer any data provide sufficient protection of that data.

6. Sharing Information With Third Parties

We share your information only as described in this Notice and require commercial entities with which we share your information to agree to keep it confidential.

a) Eskadi.com Partners

We work with a variety of partners ("Eskadi.com Partners") in order to offer you the widest possible choice of fashion items on the Sites. To buy a product, you will be taken directly to the Eskadi.comPartner website and asked by the Eskadi.com Partner to provide further personal details related to the transaction. The information you enter on the Eskadi.com Partner website will be collected, stored, and processed in accordance with the privacy policy of the Eskadi.comPartner.

Please note that: (i) you should carefully review the Eskadi.com Partner privacy policy before completing any transaction involving a Eskadi.comPartner; and (ii) the Eskadi.com Partner is solely responsible for its use and sharing of your information.

Promotions: We may also share your data with Eskadi.com Partners in connection with certain promotions and competitions. These will be subject to additional rules and conditions which will be made available to you at the time of entering any such competition or promotion. You should carefully review the rules and conditions relating to such competitions and promotions.

Aggregate information: We may also share aggregate information withEskadi.com Partners about how our customers, collectively, use the Content. We share this type of statistical data so that Eskadi.comPartners also understand how often people use the Content, so that they, too, may provide you with an optimal online experience. Eskadi.com never discloses aggregate information to a Eskadi.com Partner in a manner that would identify you personally, unless we need to in order to complete a transaction on your behalf.

b) Affiliate Networks

Eskadi.com shares personal data with affiliate networks such as Rakuten ("Affiliate Network") for the purpose of Eskadi.comparticipating as a publisher in the Affiliate Network and entering into engagements with Partners. Where the Affiliate Network collects and uses personal data for its own permitted purposes, the Affiliate Network acts as a separate and independent Controller in relation to that personal data. The Affiliate Network will use the personal data in accordance with applicable data protection laws and regulations and will individually and separately fulfil all obligations that apply to it as a Controller.

c) Advertisers

Advertisers and advertising networks may use automated technologies such as cookies to collect information about your website activity on the Sites and other sites. This is used to target advertising to you online that may be of interest to you. For more information on cookies and how to reject targeted advertising or interest-based advertising cookies, please read our Cookie Notice.

d) Analytics

We have implemented the Google Analytics Demographics and Interest Reporting feature and may share your information to analytics and search engine providers that help us to improve and optimize the Services.

e) Agents

We employ other companies and people to perform tasks on our behalf and need to share your information with them only to the extent necessary to provide products or services to you. Unless we tell you differently,Eskadi.com’s agents do not have any right to use the information we share with them beyond what is necessary to assist us.

f) To comply with legal requests

We may provide your information to relevant third parties when we believe in good faith that it is necessary in order to (i) comply with the law, regulation or a legal request; (ii) enforce or apply our conditions of use in other agreements; or (iii) protect the rights, property, or safety of Eskadi.com, our employees, our users, or others. This may include exchanging information with other companies and organizations for fraud protection and credit risk reduction.

g) Third parties where a corporate transaction is contemplated

In some cases, we may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that are transferred. In addition, in the event of a merger, acquisition, reorganization, asset sale, or in the unlikely event thatEskadi.com goes out of business or enters bankruptcy, customer information may be one of the assets that are transferred to or acquired by a third party. If such transfers occur, the third-party transferee may continue to use your information as set out in this Notice.

7. How is Your Information Kept Secure?

We take care to maintain appropriate safeguards and security features to protect the integrity and privacy of the information you provide us with and to try to prevent unauthorised access to it. We encrypt your information to protect it from unauthorised use, and we use pseudonymisation, information access controls, and firewalls.

All information you provide to us is hosted and stored on Hetzner cloud-based services in Germany which is also in compliant with ISO27001 standard. If you are not satisfied with the levels of security offered by our cloud provider, you should restrict the nature and amount of information which you include in your log data or not use the Services. Any payment transactions will be encrypted using Secure Socket Layer (SSL) technology.

If you choose to create an account with Eskadi.com (a "Eskadi.comAccount"), the information in your Eskadi.com Account is protected by a dynamically generated token for your privacy and security. You need to ensure that there is no unauthorised access to your account and information by limiting access to your computer and browser by signing off after you have finished accessing your account. Eskadi.com cannot and will not be liable for any loss or damage arising from your failure to comply with the above requirements.

The transmission of information via the Internet is not completely secure and we cannot guarantee the security of your data transmitted to the Services. Unauthorised entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. Any transmission of data is at your own risk.

8. What About Links To Third Party Websites?

The Services contain links to other sites such as Eskadi.com Partners.Eskadi.com is not responsible for the privacy policies and/or practices on other sites. When linking to another site you should read the privacy policy stated on that site. This Notice only governs information collected on the Services.

9. Data Retention

Subject to any legal obligations to keep your information longer, we store the data you provide to us for as long as is necessary to provide the Services to you (and if you have a Eskadi.com Account, for as long as you have a Eskadi.com Account), or until you ask us to delete it, whichever comes first.

After a request from a User to delete any data, a process will begin that permanently deletes the relevant data. Once begun, this process cannot be reversed and data will be permanently deleted. Any data which is not deleted shall be kept in an anonymized manner.

Eskadi.com collects and retains usage data, other metadata and statistical information about the use of the Services in an aggregated and anonymised format.

10. What’s Our Legal Basis for Processing Your Information?

We process your information where we have a legal basis for doing so.

a) Necessary for our legitimate interest. Our legitimate interests include:

Improving Eskadi.com Sites and Services and offering you a personalised experience.

Ensuring that our marketing communications, advertising and recommendations are relevant to you.

Understanding customer usage of the Services.

Ensuring the Services are managed correctly.

b) Necessary for the performance of our contract with you.

For example, in order to register and manage your Eskadi.com Account, we collect your email address and any other additional details you wish to add to your account.

c) Based on your consent.

For example, where you provide us with marketing consents in order to send you information about products that may be of interest to you. Your consent may be withdrawn at any time by contacting us.

d) Necessary to comply with relevant legal obligations.

For example, to make mandatory disclosures to law enforcement.

11. What rights do You have in relation to the information We hold about You?

You have certain rights in relation to the information that we hold about you, which are detailed below. Some of these rights only apply in certain circumstances.

a) Access

If you are based in the EU, you have a legal right under GDPR to request access to a copy of your personal data held by us. To do this, please contact us at gdpr@Eskadi.com.com., use the subject line "DSAR" and include the details about what personal data you are looking for.

b) Deletion

To ask us to delete your Eskadi.com Account, please follow the instructions in the Account Settings section of your Eskadi.com Account.

Please note that although your personal data may be removed from our databases, Eskadi.com may retain the anonymous information contained in the data you provided, and such information will continue to be used by us for statistical purposes.

c) Correction

If you have a Eskadi.com Account, you can update certain information in your ‘Account’ settings. The information that you can update or amend may change as the Services change.

d) Marketing opt-out

When you register for a Eskadi.com Account, you can give your consent to receive certain marketing emails or other communications from us. We will use your information such as your email address to occasionally provide you with information about products and services which may be of interest to you.

If you no longer wish to receive marketing messages from us, or if you want to change the type and frequency of these messages, you can change your preferences at any time in the Account Settings of your registeredEskadi.com Account, or by clicking on the unsubscribe button in our marketing emails. Please note that it sometimes takes a short amount of time to refresh our records for these purposes.

Please also be advised that you may not be able to opt-out of receiving non-promotional, transactional messages, or information about yourEskadi.com Account (e.g. service announcements or administrative messages).

You can always opt not to disclose information, even though it may be needed to take advantage of the Services.

Please note that if you choose not to receive or read legal notices from us, such as this Notice, those legal notices will still govern your use of the Services, and you are responsible for reviewing such legal notices for changes.

12. Children

We do not knowingly market or sell products for purchase by children. The Services are not designed for use by children under 13 years old. Children under 13 are not allowed to register with Eskadi.com or use the Services, or submit personal data through the Services. We do not knowingly collect personal data from anyone under the age of 13. If you have any reason to believe that anyone under the age of 13 has provided their personal data to us, please contact us as specified below, and we will work to delete that information from our databases.

13. Changes To This Notice

Eskadi.com reserves the right to change this Notice from time to time. Use of information we collect now is subject to the Notice in effect at the time such information is used. If we make substantial changes in the way we use personal data, we will notify you by posting an announcement on the Services or sending you an email. Otherwise, all other changes to this Notice are effective as of the stated "Last Revised" date.

14. Questions Or Concerns

If you have any questions or concerns regarding privacy on our Services or the Content, please send us a detailed message here. We will make every effort to resolve your concerns. If your questions or concerns are not answered online, you may write to us at 86-90 Paul Street, London, EC2A 4NE.

This Agreement has been drawn up in the English language. In case of discrepancies between the English text version of this Agreement and any translation, the English version shall prevail

Last revised: 5 November 2021