Privacy policy of «ShoppyClub» and represented domains

This Policy is part of the Customer Agreement, hereinafter referred to as the "Agreement", which accepts the terms and conditions (by accepting the offer ), you consent to the processing of your personal data in the terms established in the Privacy Policy detailed below.

Domains and websites covered by this agreement.

The domains and websites covered by this privacy policy are:

• https://shoppyclub.com

1. WHO WE ARE

Wirsom Shopping Center, S.L.
Avda. Juan de la Rosa, 24-B
11600 UBRIQUE (Cádiz)
B-72263502

ShoppyClub acts as the operator of your personal data. We combine the functions of the controller ("controller") and the processor ("processor") of personal data in the sense given to these terms in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and retaliating Directive 95 /46/EC). The contacts of the official representative of ShoppyClub in matters of personal data protection ("data protection officer") and other representatives of ShoppyClub are detailed below in section 11 of the Policy. 

The data collected will be shared with the Galilea Group (Insurance Brokerage) for insurance policy quotes.

2. FOR WHAT PURPOSES ARE PERSONAL DATA USED?

Your personal data may be used by ShoppyClub for the following purposes:

2.1.1 Your identification for the conclusion and performance of the Agreement with You (hereinafter "Registration Identification");

2.1.2 Compliance with the terms of the Agreement with You (hereinafter "Execution of the Agreement"), including what is necessary for this:

(a) The promotion of products and / or services of the Advertisers with a description of the cashback that You could receive for the purchase of the products / services of the respective Advertisers (hereinafter "Promotion under the Agreement");< /p>

(b) The implementation of the referral program;

(c) The promotion of ShoppyClub services, including information about new ShoppyClub products, as well as promotions, sweepstakes, discounts, etc. on the site shoppyclub.com, also on the terms of referral programs and loyalty programs, ... (hereinafter "Promotion of the ShoppyClub Service ");

(d) The improvement, modernization, updating of services and products of ShoppyClub (hereinafter "Service Improvements");

(e) The information addressed to You in connection with the Agreement, including the update of the ShoppyClub services (hereinafter "Information within the framework of the Agreement");

2.1.3 The transfer of cashback to You, in accordance with the applicable law and the requirements of the payment systems chosen by You to receive the transfer (hereinafter "Cashback Transfer");

2.1.4 Direct marketing, advertising and promotion of products and (or) services of ShoppyClub partners (hereinafter "Direct Marketing");

2.1.5 Consumer market research taking into account your personal data and the uses of the ShoppyClub service for the marketing purposes of the ShoppyClub services (hereinafter "Market research for ShoppyClub Marketing");</p >

2.1.6 Compliance with the orders of the applicable law or the ruling of the court or other competent state or municipal authority (hereinafter "Execution of the Law or the Ruling of the Competent Authority"). Please note that the terms in parentheses will be used below in their full meaning explained in this paragraph 2 of the Policy.

3. The personal data we use

3.1.1 The customer himself is responsible for updating and maintaining correct contact information in his account on the Service. The Customer can make all changes on the Settings page in their personal ShoppyClub account.

3.1.2 The information you provide us:

(f) When registering at ShoppyClub with your email:

(i) Name (alias) on the shoppyclub .com site;

(ii) Your password for the personal account;

(iii) Email address;

(iv) The country of residence;

(v) Currency used;

(vi) Avatar;

(g) When registering with ShoppyClub through social networks:

(vii) The identifier (ID) of your Facebook profile or your Google account;

(viii) Email address;

(ix) A photo of your Facebook profile or your Google account;

(x) The country of residence; From now on, the personal data indicated above will be called "Identifying Information";

(h) In the personal account after registration (by free will):

(xi) Date of birth;

(xii) Telephone number;

(xiii) Sex;

(xiv) Photo of his profile on the Service, hereinafter the personal data indicated above will be called "Additional Identification Information"; (i) for the transfer of cashback, depending on the requirements of the applicable law and payment systems:

(xv) The telephone number (for transfer to the subscriber's mobile account);

(xvi) The number of the bank card or account (wallet in the payment system) to which the Cashback is transferred;

(xvii) Your first and last name (for Cashback transfer using Visa, MasterCard, PayPal, ect.) payment systems;

(xviii) Your physical address;

(xix) Other information necessary to carry out the cashback transfer in accordance with the requirements of applicable law and payment systems, the personal data mentioned below are called "Requirements for Cashback Transfer".

3.1.3 The information we receive from other sources:

(j) Regardless of the way of processing personal data, except for Identification for Registration:

(i) Your identification number (ID) in the ShoppyClub service, assigned after registration;

(ii) Your IP address;

(iii) Geolocation data using GPS and public Wi-Fi networks;

(iv) The identifiers (UUID, model and others) of your computer, mobile device or tablet;

(v) Operating system and its version;

(vi) Type and version of your browser;

(vii) Version and identifiers of the ShoppyClub mobile application that You use;

(viii) UTC time

(ix) Language used;

(x) Detailed information about your behavior on the shoppyclub .com site, including: time spent on its web pages; data about tracking ("clicks") of links located on these sites; data about the movement of the cursor or other pointer across the web pages of the indicated sites; data on scrolling through the content of the web pages of the indicated sites;

(xi) Cookies (small files that are stored in the memory of your device, designed to personalize your activity and behavior on the shoppyclub.com sites and other sites on the Internet);

(xii) Your browser cache (files that are stored in the memory of your device, which reproduce some parts of the web pages already visited on the shoppyclub .com site and allow reduce the loading time of the content of these web pages) hereinafter this information is called "Standard External Information";

(k) Also during the Execution of the Agreement with You:

(xiii) Information from Advertisers regarding your acquisition of their products and (or) services;

(xiv) Information about your Google contacts if you use Google Sharing;

(l) also with the Cashback Transfer:

(xiv) information from payment systems, banks, telecommunications operators and other intermediaries participating in the Cashback Transfer;

(m) Likewise with the Execution of the requirements of the law or the decision of the competent authority:

(xv) Any information necessary for the execution of the requirements of the law or the decision of the competent authority. 

4. How we process personal data

The use of your personal data by us depends on the specific purposes of your processing. We inform you that from now on the terms that name the purposes of treatmentnto data are used in their full meaning given in paragraph 2 of the Policy.

4.1.1 Use of Personal Data for Identification for Registration

To identify you as part of the Agreement, we must obtain sufficient information to establish your identity. For this, we have designed the registration procedure for the Service. For successful registration, you must provide us with your identifying information (listed in paragraphs 3.1.2(a) and 3.1.2(b) of the Policy). In this way, we collect, record and systematize your identity information, also by automatic means. We may also confirm this information to ensure that your identity information is accurate and up to date. We store your Identification information until the date of termination of the Agreement (deletion/blocking of your account). Your identifying information is then deleted and destroyed.

4.1.2 Use of personal data in the Execution of the Agreement

We process the following information in all ways necessary for the most complete and qualitative Execution of the Agreement, including the Promotion under the Agreement, the implementation of the referral program, the Promotion of the ShoppyClub Service, the Improvement of the Service and the Information in the framework of the Agreement:

(n) Your identifying information (listed in paragraphs 3.1.2(a) and 3.1.2(b) of the Policy);

(o) Your additional identifying information (listed in paragraph 3.1.2(c) of the Policy);

(p) Standard external information (specified in paragraph 3.1.3(a) of the Policy);

(q) Information from Advertisers about your acquisition of their products and (or) services after using the ShoppyClub service. information from Advertisers about your acquisition of your products and (or) services after using the ShoppyClub service.

By the automatic processing of the above data, we generate derived data about your preferences, which we also use for the complete and qualitative fulfillment of the Agreement, including Service Improvement, Promotion under the Agreement and Promotion of ShoppyClub Services . For you this means, for example, that we draw your attention to the Advertisers' proposals, which you will probably find more interesting, taking into account your behavior on the shoppyclub .com site (for example, if you place orders in stores of appliances or fashion, we can draw your attention to other offers of this type). We can also personalize the promotion of ShoppyClub Services for you, so that you can receive the information that interests you most.

We carry out the Promotion of ShoppyClub Services so that our current and potential Clients receive complete information about the services we offer, about the new ShoppyClub products, and also so that they use our service more actively, obtaining additional benefits for using the ShoppyClub Service.

Among other things, we:

(r) We collect, record, organize, accumulate and use the personal data mentioned above;

(s) we transfer them to the advertising platforms and services, CPA and CPI affiliation networks, with which ShoppyClub collaborates through contracts and agreements, the fulfillment of which is necessary or could create prerequisites for the possibility of signing and carrying out the Agreement with you and other Customers, including the receipt of Commission by ShoppyClub;

(t) We use them to send you notices, posting them to your personal account and sending emails to your address, for example:

(i) Notices regarding cashback transfers, balance changes, finances and orders;

(ii) Notices about new developments in the Service or about the publication of a new version of the Agreement;

(iii) Notices about new promotions, sweepstakes and other events and programs that encourage the use of the ShoppyClub Service;

(iv) Other service notices and information;

(u) Use of personal data in our referral program “Refer and win”:

(i) If you have registered with ShoppyClub using a URL provided by another ShoppyClub user (hereinafter, the “Inviter”) within the terms of our registration program reference “Refer and Win”, we will provide the Inviter with your ShoppyClub account details (full name/username, ID, profile photo), as well as details of your orders such as order date, price, name of the affiliated store, the cashback amount, the current cashback status and other statistical informationsimilar style, without including information about specific products purchased by you.

(ii) If you use Google Sharing to invite new users to ShoppyClub within the terms of our “Refer and Earn” referral program, we will receive an encrypted list of your Gmail contacts in order to send them a standard welcome email to the “Refer and Earn” referral program with your referral link. We store the personal information indicated above until the date of termination of the agreement between You and ShoppyClub (deletion / blocking of your account). After that, your data is deleted and destroyed.

4.1.3 Use of personal data for cashback transfer

To guarantee the cashback transfer, we need to know in what way and with what bank details we must transfer the funds, and also have the possibility to verify the status of payment completion. For this we request::

(v) From You: the Requirements for Cashback transfers (indicated in paragraph 3.1.2(d) of the Policy) and

(w) From payment system operators, banks, telecommunications operators and other intermediaries participating in the Cashback Transfer: information on the possibility, receipt and status of making the payment. The information indicated above is collected, recorded, systematized, accumulated and used in the processing of payment documents and the transfer of cashback.

We store the personal information indicated above until the date of termination of the agreement between You and ShoppyClub (deletion / blocking of your account). After that, the above data is deleted and destroyed.

4.1.4 Use of personal data for Direct Marketing We carry out Direct Marketing for commercial purposes, and as a result You may obtain information about products and/or services from our partners that may interest you.

For the implementation of Direct Marketing, we collect, record, organize, accumulate and use:

(x) Your identifying information (listed in paragraphs 3.1.2(a) and 3.1.2(b) of the Policy), except your password for the personal account;

(y) Your additional identifying information (listed in paragraph 3.1.2(c) of the Policy);

(z) The information specified in paragraphs 3.1.3(a)(ii), 3.1.3(a)(x) and 3.1.3(a)(xi) of the Policy, as well as the results of automatic processing of the information indicated above.

Such automatic processing means to you that we are trying to determine the effectiveness of Direct Marketing.

We may also transfer the above information to our partners, with whom ShoppyClub has signed appropriate agreements on advertising, promotion or marketing (including through intermediaries), and we may use various marketing, statistical and technical tools. We inform you that by consenting to the processing of your data for Direct Marketing purposes, you confirm that you have read and accept the processing of your data for the use of these tools, that is:

(1a) Facebook pixel — Data use policy published under the URL https://www.facebook.com/about /privacy;

(1b) Google Analytics — The Google Analytics terms of use, published under the following URL, where you can select the appropriate language to read the document, https://www.google.com/analytics/terms;

(1c) Yandex.Metrics — The Yandex.Metrica terms of use, published under the following URL, where you can select the appropriate language to read the document, https://yandex.ru/legal/metrica_termsofuse/;

(1d) Vk pixel — Data usage policy published under the URL https://vk.com/privacy; (bb) Hotjar — Data usage policy published under the URL https://www.hotjar.com/legal/policies /privacy;

(1e) Google Ads — The Google Ads terms of service published under the following URL, where you can select the appropriate language to read the document. https://policies.google.com/technologies/ads

We store the personal information indicated above until the date of termination of the agreement between You and ShoppyClub (deletion / blocking of your account). After that, the above data, which is available to ShoppyClub, is deleted and destroyed.

4.1.5 Use of personal data in Market Research for ShoppyClub Marketing

We carry out market studies for ShoppyClub Marketing, taking into account the behavior and preferences of customerss from ShoppyClub. Marketing ensures the growth of ShoppyClub's business, which can subsequently contribute to improving the quality of our services. To carry out Market Research for ShoppyClub Marketing, we collect, record, systematize, store and use:

(1f) Your identifying information (listed in paragraphs (f) and (g) of the Policy), except your password for the personal account;

(1g) Your additional identifying information (listed in paragraph (h) of the Policy);

(1h) Standard external information (specified in paragraph (j) of the Policy);

As well as the results of automatic analysis and other processing of the information indicated above. We may also transfer the above information to our partners, with whom ShoppyClub has concluded appropriate agreements regarding the performance of analysis, statistical research, etc. (even through intermediaries). Such automatic processing allows us to carry out market research and obtain relevant results, as well as to structure the results by customer categories taking into account various criteria (for example, country of residence). Therefore, your data becomes part of the ShoppyClub Marketing Market Research results. We take the above data into account when developing our market strategy, as well as ShoppyClub's services and products. We store the personal information indicated above until the date of termination of the agreement between You and ShoppyClub (deletion / blocking of your account). After that, the above data, which is available to ShoppyClub, is deleted and destroyed, and the research results are depersonalized (if they were not depersonalized before). 

5. Data transfer outside the European Union

Since the service provides the opportunity to make purchases outside the European Union, it is impossible to prevent the transfer of data outside the EU. In accordance with the provisions of the European data policy of the GDPR, we are obliged to notify users about the risks associated with cross-border data transfers. This does not mean that your data is freely available or not protected in any way, we only draw your attention to the existence of the usual risks associated with the use of services registered in jurisdictions that are not directly covered by the GDPR Privacy Policy</ p>

6. For what reasons do we use personal data?

We use your personal data legally. Therefore, we process your personal data only if:

6.1.1 You consent to the processing of your personal data in one way or another as stipulated in the Agreement; o

6.1.2 The processing of your personal data is necessary for the performance of the Agreement; o

6.1.3 The processing of your data must be carried out by us in accordance with the requirements of applicable law, by a court decision or other competent state or municipal authority; o

6.1.4 These data have been made public by you and have public access. 

7. Where we store personal data

ShoppyClub carries out the recording, systematization, accumulation, storage, updating (modification), extraction of your personal data using databases located on the territory of Germany. Privacy Policy

8. How we protect the confidentiality of your data

We take technical, organizational and legal measures or secure actions to protect your personal data from unauthorized or accidental access, collection, storage, use, transfer, blocking or destruction, as well as from other illegal actions or accidental leaks. For example, we ensure:

8.1.1 The appointment of employees in charge of organizing the processing and protection of personal data ("data protection officer");

8.1.2 The restriction and regulation of ShoppyClub personnel who have access to personal data;

8.1.3 The familiarization of ShoppyClub employees with the requirements of applicable laws and regulations on the processing and protection of personal data;

8.1.4 The accounting and storage of material carriers of information and their management, to exclude unauthorized theft, substitution, copying and destruction thereof;

8.1.5 The identification of threats to the security of the confidentiality of personal data during its processing, and subsequently the formation of threat models;

8.1.6 The development, based on threat models, of the personal data protection system for the corresponding class of computer systems;

8.1.7Verification of the readiness and effectiveness of the use of information security systems;

8.1.8 The implementation of a licensing system for access to computer resources, software and hardware for the protection of information;

8.1.9 The registration of actions of users of personal data computer systems;

8.1.10 Password protection of user access to the personal data computer system;

8.1.11 The application of access control measures to communication ports, information input/output devices, removable media and external storage devices;

8.1.12 The implementation of antivirus control, prevention of the introduction of malicious programs (virus programs) and program markers into the corporate network;

8.1.13 The detection of intrusions into the corporate network of ShoppyClub, which violate or create the preconditions for the violation of the requirements established for the security of personal data;

8.1.14 The centralized management of the personal data protection system;

8.1.15 The training of employees who use the information security tools used in personal data computer systems, for their correct use;

8.1.16 The record of the information protection means applied and its operational and technical documentation;

8.1.17 Monitoring user actions, conducting investigations in case of violation of personal data security requirements.

9. What are your rights and how do we protect them?

We respect and protect your rights regarding personal data. You can contact our personal data protection officer with a request to exercise your rights, listed below (you can find contact details in section 11 of the Agreement). We ensure processing of the request within a reasonable time, but no later than 1 (one) month from the date of receipt of the request. This period may be increased to 3 (three) months due to the complexity of the request or a large number of requests from ShoppyClub customers. We will notify You in advance of such extension of the deadline by email You specified when registering. With a request addressed to us, you can exercise the rights of:

9.1.1 Access to information related to the processing of your personal data:

(1i) Access to information within the framework of this Agreement;

(1j) Obtain an electronic copy of all personal data processed, in a structured and machine-readable format;

9.1.2 Clarification of your personal data, of which we will notify all parties that have previously processed your personal data, provided that such notification is not impossible or does not require a disproportionate effort;

9.1.3 Direct transfer of your personal data from ShoppyClub to third parties;

9.1.4 Restriction or total or partial withdrawal of your consent for the processing of personal data in one way or another;

9.1.5 Destruction of your personal data (of which we will notify all parties that have previously processed your personal data, provided that such notification is not impossible or does not require a disproportionate effort):

(1k) At your request;

(1l) If consent to data processing is withdrawn;

(1ll) If it is no longer necessary to process your personal data.

9.1.6 How to delete your ShoppyClub account:

• Log in to your account with your username and password.

• Go to "My Account" and choose "My information".

• Now scroll until you reach the end of the page.

• Choose “ I want to cancel my account</ span>”.

• A confirmation message will appear "Are you sure you want to delete your accounts?" .

• Select "Yes" to delete it or "Cancel" to return to your account.

You can delete your ShoppyClub account at any time. After that, you can create a new ShoppyClub account if you wish. After deleting your account, we will stop processing your personal data that we had previously been managing with your permission.

If you believe that your legal rights and (or) interests have been violated, you have the right to file a claim or legal action with the state authority.to the competent one. For example, if you are located in the territory of the European Union, you have the right to lodge a complaint with the supervisory authority of the relevant member state of the European Union ("supervisory authority"). If you believe that the automatic processing of your data violates your rights and (or) interests or creates significant negative consequences for you, we will ensure human intervention in the results of automatic processing and guarantee your right to challenge decisions made with the help of automatic tools. Furthermore, apart from the information set out above, we emphasize that you, among other things, can deny the processing of your data for Direct Marketing. By doing so, we guarantee the completion of such processing and the deletion of your personal data. The information set out in this paragraph does not limit in any way your right to withdraw consent to other types of processing of personal data.

10. The processing of your personal data by our partners and third parties

This Agreement governs only the processing of your data by ShoppyClub and not by third parties. The processing of your data by third parties, for example when you click on links to Advertisers' sites, is not governed by this Agreement, unless expressly stated in the Agreement as an exception.

11. Contact information

You can contact us or send your questions through the "contact" section. There is also a hotline at the telephone numbers specified on the site. If anything in the Agreement is not clear to you, we will be happy to answer your questions.