Loyalty Scheme Privacy Policy

Protecting Your Privacy

Darmanin Footwear Limited (C6082) (“Darmanin Group”) strongly values the privacy of its clients and is committed to protect your personal data (i.e. information that identifies you)

One of your rights under EU law – the GDPR – is that you must be informed when your personal data – also known as personal information – is processed (collected, used, stored) by any organisation. You also have the right to know the details and purpose of that processing.

This privacy policy describes our practices related to the processing of personal data, including that relating to the personal data of Loyalty scheme cardholders who have registered with us to obtain their Darmanin Group Loyalty Card for Darmanin Footwear, Teamsport and Gallarija Darmanin.

We assure you that we will only use and disclose any personal data collected from you in accordance with the manner set out in this policy.

► Information we collect

Most of the personal information which we collect about you is collected through our registration form or process which you need to fill in order for us to provide you with your Loyalty Card, which card allows you to enjoy our special offers, discounts and member offers. This personal information will be requested when you fill in the registration form physically at one of our outlets.

If you send us emails, then the personal data we process will depend on what you send us via email.

The information we collect from you normally includes the following:

  1. Name and Surname; 2. Email address 3. Date of Birth 4. Mobile number 5. Landline number 6. Address

Please read the following sections to understand how and why we use this information.

► How & Why we use your information

We use the above mentioned personal data we collect from you to keep a database of loyal customers and to get in touch with you via mail, email or sms to inform you of our special offers and discounts available at our stores.

We do this because we need your personal details to provide you with your Loyalty Card and to inform you of our special offers and discounts which you are entitled to as a Loyalty Scheme cardholder.

If you want to unsubscribe from receiving more information about our discounts, special offers or marketing, or if you want us to completely remove all your information from our loyalty scheme database please send us an email on info@darmaningroup.com.

You don’t have to give us any of this personal information but if you don’t, you will not be issued with a Loyalty Card and will not benefit from our special offers and discounts.

The Legal Basis for Processing

For some of the uses of your personal data (as described above) there is a legal basis under applicable data protection laws for us to use such personal data without having obtained your consent.

This includes, for example, where it is necessary for us to use the information to perform a contract with you.

In some circumstances (such as we have described below) we have a legitimate interest to use your data, provided that proper care is taken in relation to your rights and interests:

(i) to ensure that you know about any changes to the terms of this Privacy Policy. (ii) to ensure that we organise our databases efficiently and understand how our

clients may make purchases; (iii) to carry out research and analysis of your data (including purchase information) as this helps us understand our clients better, who they are and how they interact with us;

Retention Periods

  • We will hold on to your information for no longer than is necessary keeping in mind the purpose/s (or compatible purposes) for which we first collected the data.
  • We may also keep hold of some of your information if it becomes necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.
  • As a guide:

– we will usually keep your personal data while your Loyalty Card is still active with us or until when you ask us to remove you completely from our Loyalty Scheme database, unless there are valid or legal reasons for us to keep the data for longer;

– we may keep certain categories of personal data for longer in order to meet any

legal or regulatory requirements, or to resolve a legal dispute;

► Children Under 16

If you are aged 16 or under, please get your parent/guardian’s permission before you provide any personal information to us.

We will need to process personal data relating to parents or guardians in that case – and we may also need to request for verification documentation to ensure that consent is given or authorised by the holder of parental responsibility.

► Sharing your information

We will not, sell any of your personal data to any third party

However, we share your data with the following categories of companies as an essential part of being able to provide our services to you, as set out in this statement:

  1. Companies in the group to which Darmanin Group belongs, related entities and subsidiaries use the information collected to better understand our customers and markets; and to improve our products and services. Members of the group vary from time to time.
  2. Professional service providers, such as marketing agencies, advertising

partners and website hosts who service us in turn to operate our business.

► Marketing Messages

As part of our Loyalty Scheme we normally communicate to you about products or services in which you have shown interest or which you are already buying from us – we understand that you would be interested in receiving this information as it is of use with the product or service. But rest assured, you can ask us to stop whenever you want by hitting the “unsubscribe” button.

How to stop marketing messages from us

You can stop receiving marketing messages from us at any time through any of the following methods:

o By clicking on the ‘unsubscribe’ link in any email we send you o By contacting our Customer Care team

Once you do this, we will update your profile to ensure that you don’t receive further marketing messages.

► Your rights

You enjoy several rights relating to your personal information:

(i) The right to be informed about how your personal information is being used;

We need to be clear with you about how we process your personal data. We do this through this Privacy Policy, which we will keep as up to date as possible.

(ii) The right to access the personal information we hold about you;

You can access the personal data we hold on you by contacting us on info@darmaningroup.com

To process your request, we will ask you to send us proof of identity so that we can be sure we are releasing your personal data to you and not someone else.

We will carry out our best efforts to process your request within one month or, if the request is particularly complex, two months. We can provide you with a copy of your personal data in electronic format or hard copy.

If we consider the frequency or nature of your requests as excessive or unreasonable, we may refuse to comply with your request. In those circumstances, if you disagree, you can complain to the data protection authority – in Malta, the Information and Data Protection Commissioner.

(iii) The right to request the correction of inaccurate personal information we hold about

you;

We want to ensure that our records and data are accurate and up-to-date.

If you think that the information we hold about you is inaccurate or incomplete please ask us to correct it by sending an email to info@darmaningroup.com

(iv) The right to request that we delete your data, or stop processing it or collecting it;

You have a right to ask us to delete your personal data; however, this is not an absolute right.

In spite of a request for erasure, we may be justified to keep personal data which we need to keep, e.g. (i) to comply with a legal obligation or in the exercise or defence of any legal claims.

When you ask us to delete your personal data, we assume that you do not want to hear from us again. To ensure that we do not send you any special offers in the future we will keep just enough of your personal data solely for suppression purposes.

Other than as described above, we will always comply with your request and do so promptly.

(v) The right to stop direct marketing messages;

(vi) The right to object to certain processing based on legitimate interest;

You have a right to object to our use of your personal information including where we use it for our legitimate interests or where we use your personal information to carry out profiling using automated mean (which we currently do not). You can do this by sending an email to info@darmaningroup.com

(vii) The right to request human intervention if automated processing without human intervention is used to make decisions having legal or similar effects on you;

(viii) The right to withdraw consent for other consent-based processing at any time;

(ix) The right to request that we transfer or port elements of your data either to you or

another service provider;

(x) The right to complain to your data protection regulator — in Malta – the Information

and Data Protection Commissioner (IDPC)

If you want to exercise your rights, have a complaint, or just have questions, please send an email to info@darmaningroup.com

Please appreciate that the rights must be exercised within some limitation – for example, if you ask us for information we can only give you what relates to you and not what relates to other persons. When we receive requests, we may also request that you identify yourself and provide documentation or information for verification (we would not want to disclose information to the wrong person). Unreasonable requests may be subjected to a reasonable fee or refusal to respond.

► Security of your Personal Data

Security of your personal data is very important to us.

We do our best to keep the information you disclose to us secure. However, we can’t guarantee or warrant the security of any information which you send to us.

Security measures which we have implemented to secure information transmitted through our Loyalty Scheme include the following:

  1. Use of secure servers; 2. Use of firewalls; 3. Use of password encryption; 4. Physical access controls at data centres; 5. Information access controls; 6. Use of back-up systems;

Please understand, however, that no system is perfect or can guarantee that unauthorised access or theft will not occur.

► Changes to how we protect your privacy

We are continually reviewing our systems and offering, thus changes to our privacy policy may be required from time to time. Feel free to get in touch with us on info@darmaningroup.com for the latest copy of our privacy policy.

► How to contact us

We are always happy to hear from you, whether to make a suggestion but especially if you feel we can do better. If you have any questions about this Privacy Policy, or if you wish to make a complaint about how we have handled your personal information, please contact us at:

Darmanin Footwear Limited Gallarja Darmanin Dun Karm Street Iklin IKL9022 info@darmaningroup.com