1. Prior Considerations Pursuant to the provisions of Organic Act 15/1999, of December 13, 1999, on Personal Data Protection (hereinafter, LOPD) NEINVER S.A. wishes to inform all users visiting its website of its policy concerning the processing and protection of the personal data of all those persons voluntarily using the e-mail to contact NEINVER S.A. or any other service contained in the website that involves the notification of their personal data to NEINVER S.A.
Users are hereby informed that all personal data processing operations are subject to the applicable legislation in Spain governing data protection, established by the LOPD and all provisions complementing and implementing it.
To those effects and purposes, personal data refer to any information concerning the identified or identifiable individual persons -including the e-mail address and/or IP address- and user refer to any individual person identified or identifiable who notifies his/her personal data to NEINVER S.A., using any service in the website of the foregoing company.
NEINVER S.A. warns all users that this entity is only responsible for, and assures, the confidentiality, safety and processing of the data in accordance with the present policy, with regard to the personal data obtained from the user through the website www.thestyleoutlets.com and assumes no direct responsibility for any subsequent processing and use of the personal data that might be carried out by third parties rendering services to the information society, who could obtain access to such data by rendering such services or in the course of exercising their business activity.
2. Identification of the company responsible for the database NEINVER S.A. hereby informs all those persons using its website of the existence of a database or system for processing personal data, of which the manager is NEINVER S.A., with registered offices in calle Francisca Delgado nº 11, 5th floor, Arroyo de la Vega, Alcobendas, 28108 Madrid, where the personal data furnished by users to NEINVER S.A. are collected and stored.
3. Purposes for which the personal data are to be used Users accessing the website of NEINVER S.A. are not obliged to provide their personal data in order to use it. The website only collects personal information that serves to identify the user, taking into consideration, moreover, that such information shall in all cases be furnished by the user of his/her own free will. The information that might be requested includes, among others: name, address, e-mail address, telephone and fax number, preferential work areas and country, and the Curriculum Vitae of the person. That information shall be stored in a processing system for which the company NEINVER S.A. is responsible, for the purpose of analysing the professional profile of the person in question with a view to incorporating that user into our staff selection processes for filling vacant positions or recently-created positions arising in the company. Similarly, the above data obtained from the user in question and his/her C.V. may be assigned by NEINVER, S.A. to the following companies of the Neinver group, all of them located in the European Economic Area that provide an adecuate level of data protection and that engage in real estate promotion:: NEINVER ASSET MANAGEMENT ESPAÑA, S.L. with registered office at NEINVER S.A., with registered office at calle Francisca Delgado nº 11, 5th floor, Arroyo de la Vega, Alcobendas, 28108 Madrid, TECKEL GESTORA, S.L., with registered office at NEINVER S.A., with registered office at calle Francisca Delgado nº 11, 5th floor, Arroyo de la Vega, Alcobendas, 28108 Madrid and NCR, S.A. with registered office at NEINVER S.A., with registered office at calle Francisca Delgado nº 11, 5th floor, Arroyo de la Vega, Alcobendas, 28108 Madrid, IRUS ZWEIBRÜCKEN, S.A. with registered office at Brussels Avenue de Tervueren 13A bte, 1040 Brussels (Belgium) IRUS VILA DO CONDE, S.A., with registered office at Avenida Fonte Cova, 400, Modivas, Vila do Conde,, IRUS VILA DO CONDE II, S.A., with registered office at Avenida Fonte Cova, 400, Modivas, Vila do Conde, IRUS VILA DO CONDE III, S.A., with registered office at Avenida Fonte Cova, 400, Modivas, Vila do Conde., IRUS VICOLUNGO II SRL with registered office at Milano - Via LARGA 15 Vicolungo (NO) - and address for notification purposes at Vicolungo (NO) - Piazza Santa Caterina 1, IRUS VICOLUNGO III SRL with registered office at Milano - Via LARGA 15 Vicolungo (NO) - and address for notification purposes at Vicolungo (NO) - Piazza Santa Caterina 1, IRUS CASTEL GUELFO SRL, with registered office at Milano - Via LARGA 15 and address for notification purposes at Vicolungo (NO) - Piazza Santa Caterina, CASTEL GUELFO II SRL with address at Milano - Via LARGA 15 Vicolungo (NO) - and address for notification purposes at Vicolungo (NO) - Piazza Santa Caterina 1 and MAB ROPPENHEIM, a Limited Liability Company, which has its registered offices situated at Paris (75008) 125 avenue des Champs Elysées, registered with the Register of Companies and Commerce, Paris, so that the person in question can take part in the staff selection processes organized by those companies for the purpose of filling vacant positions or recently-created positions in the same, and for the purpose of controlling the recruitment of that person. Should any user not consent to his/her personal data being assigned to the NEINVER companies group referred to above, that user is asked to kindly refrain from sending his/her personal data to NEINVER S.A.
As a general rule, NEINVER S.A. does not ask users to provide specially protected information. Such information is taken to be the following, in accordance with articles 7 and 8 of the LOPD: data related to race or ethnic origin, religious beliefs, criminal records, physical or mental health or sexual preferences. In the event that NEINVER S.A. were to at any time request specially protected information of that kind, the users express consent shall be sought beforehand, in order to obtain and use that information.
If this is not the case, should the user not agree, he/she shall refrain from sending e-mails or notifying its personal data to NEINVER S.A.
The personal data shall only be used for the limited purposes set forth in each case.
NEINVER S.A. may request the users of its website for their personal data at any time, through the use of forms. In this case, NEINVER S.A. shall include an informative note in the data-collection form, indicating all the conditions for the processing of personal data pursuant to article 5 of the LOPD, such as whether responding to the questions asked is compulsory or voluntary, the consequences of obtaining the data or refusal to furnish such data, the purposes for which such data are obtained, possible assignments that could be made and, if necessary, a request for the user's consent for the personal data he/she furnishes to be processed.
5. Identification of the recipients to whom NEINVER S.A. plans to assign personal data or notify regarding personal data NEINVER S.A. intends to assign or notify the data which, based on article 11.2.c. of the LOPD, it must assign or notify in order to comply with its obligations towards the Public Authorities in cases in which this is required, in accordance with the applicable legislation on each issue at any given time and also to other bodies such as Judges, the Tax Authorities, the Courts of Justice, the Court of Auditors or the Citizens Ombudsman.
Similarly, NEINVER, S.A. may assign the users personal data and its Curriculum Vitae to the following companies in the NEINVER group:, NEINVER ASSET MANAGEMENT ESPAÑA, S.L., TECKEL GESTORA, S.L., NCR, S.A., IRUS ZWEIBRÜCKEN, S.A. with registered office at Brussels Avenue de Tervueren 13A bte, 1040 Brussels (Belgium) IRUS VILA DO CONDE, S.A., with registered office at Avenida Fonte Cova, 400, Modivas, Vila do Conde,, IRUS VILA DO CONDE II, S.A., with registered office at Avenida Fonte Cova, 400, Modivas, Vila do Conde, IRUS VILA DO CONDE III, S.A., with registered office at Avenida Fonte Cova, 400, Modivas, Vila do Conde., IRUS VICOLUNGO II SRL with registered office at Milano - Via LARGA 15 Vicolungo (NO) - and address for notification purposes at Vicolungo (NO) - Piazza Santa Caterina 1, IRUS VICOLUNGO III SRL with registered office at Milano - Via LARGA 15 Vicolungo (NO) - and address for notification purposes at Vicolungo (NO) - Piazza Santa Caterina 1, IRUS CASTEL GUELFO SRL, with registered office at Milano - Via LARGA 15 and address for notification purposes at Vicolungo (NO) - Piazza Santa Caterina, CASTEL GUELFO II SRL with address at Milano - Via LARGA 15 Vicolungo (NO) - and address for notification purposes at Vicolungo (NO) - Piazza Santa Caterina 1 and MAB ROPPENHEIM, a Limited Liability Company, which has its registered offices situated at Paris (75008) 125 avenue des Champs Elysées, registered with the Register of Companies and Commerce, Paris so that users furnishing their CVs may take part in the staff selection processes organised by those companies.
On the other hand, NEINVER, S.A. hereby informs users that it shall permit access to their personal data and those related to their CVs in accordance with the provisions of article 12 of the LOPD by third parties contracted by NEINVER, S.A. for rendering their staff selection services, which requires access to and the processing of data. The data shall not be assigned to such companies for legal purposes and the establishing of the appropriate security and confidentiality measures shall be demanded and assured, as foreseen in the foregoing LOPD and in Regulation 1720/2007, of December 13, on Security Measures.
Likewise, NEINVER S.A. hereby informs users they will be notified of any other assignment of data it has to make when this is so required by the LOPD, and that they will be provided with express, accurate and unequivocal information on the recipients of the information, the purpose for which those data are to be used and the nature of the data assigned or, as applicable, if the LOPD so requires, the user shall be requested to give his/her unequivocal, specific and informed consent thereto.
6. Data Quality NEINVER S.A. warns users that except in the case of the existence of legally constituted representation, no user may supplant the identity of any other person and notify that person's personal data, for which purpose users shall at all times bear in mind that if they use the e-mail, they may only include personal data on their own identity that are sufficient, relevant, accurate and truthful. For this purpose, users shall be the only responsible for any direct and/or indirect damage caused to others or to NEINVER S.A. for using the personal data of a third person, or if their own personal data provided are false, erroneous, not updated, inappropriate or impertinent. Furthermore, users making use of a third person's personal data shall be liable before that person for the obligation of information set forth in article 5.4 of the LOPD when the personal data have not been obtained from the data subject and/or of the consequences for the lack of information.
7. Data on minors or mentally handicapped persons If a user is a minor or mentally handicapped person, NEINVER S.A. hereby warns that such user shall require the consent of his/her parents, tutors or legal representatives in order to notify their personal data. In this case, NEINVER S.A. asks these users to refrain from using its e-mail service if they do not have the consent of their parents, tutors or legal representatives. Otherwise, NEINVER S.A. shall not be held responsible for the acts of that minor or mentally handicapped person.
8. Updating of data Users are the only source of information with respect to their personal data, and therefore, for the purposes of keeping all their data up to date at all times, and in compliance with the provisions of the LOPD, NEINVER S.A. asks the users to notify at the address indicated for the purpose of exercising their rights of access, rectification, cancellation and opposition any modification in such data, as well as the ceasing of their activity in the company they represent, as applicable, for the purpose of cancelling and/or the historic processing of those data.
9. Exercising of the rights of opposition, access, rectification and cancellation of the data NEINVER S.A. hereby informs users that they may exercise their rights of access, rectification, cancellation and opposition by writing to NEINVER S.A. at the following address: calle Francisca Delgado nº 11, 5th floor, Arroyo de la Vega, Alcobendas, 28108 Madrid, or any address substituting this one and is notified to the General Data Protection Register.
10. "Cookies" To ensure that the website www.thestyleoutlets.com is properly managed and to facilitate navigation inside the website, NEINVER S.A. may use "cookies" (small text files stored in the user's navigator). However, users are informed that most navigators permit users to reject the "cookies".
11. Security measures implemented in relation to the processing of personal dataNEINVER S.A. hereby informs users that pursuant to the provisions of the LOPD and the Security Measures Regulation, it has taken all necessary technical and organizational measures to assure the security of the personal data and prevent the alteration, loss, and unauthorized processing of or access to, the data, bearing in mind the state of technology, nature of the data stored and the risks to which they are exposed, whether or not these risks are caused by human acts or from the physical or natural environment, and that it shall only record personal data in files that meet the requirements set forth in the foregoing Regulation with respect to their integrity and security, and those of the processing centres, premises, equipment, system and programs.
In addition, NEINVER S.A. guarantees to users that it shall comply with its professional secret obligation with respect to the personal data of the users and its obligation to safeguard them.
12. Recommendations to usersNEINVER S.A. recommends to users that they use the latest software releases in navigating the Internet, due to the fact that they contain more advanced security measures.
Likewise, NEINVER S.A. recommends users to use the security mechanisms available to them (safe website servers, encryption, digital signature, firewalls, etc.) to protect the confidentiality and integrity of their data to the necessary extent, in view of the existence of risks through the supplanting of other people?s identities or the breaching of communications.
NEINVER S.A. reminds users that the Internet is not safe. Nevertheless, different means exist and are in the process of being developed to enable the protection of their data to be improved. Thus, users are recommended to use any means within their reach to protect their data and communications, such as legally available codification for confidential e-mails and access codes to their own PCs.
NEINVER S.A. warns users that whenever they send personal information through the Internet by e-mail, to news groups, debate forums, etc., they should remember that that information could be obtained and processed for undesirable purposes by other users. For which reason NEINVER S.A. strongly recommends to users that they obtain information about the privacy and non-disclose policies of the online websites they visit.
NEINVER S.A. warns users to remain alert to the fact that, unless they use encrypting mechanisms, sending e-mails over the Internet is not safe. E-mail messages and debate forums may be fraudulently set up and third person's identities supplanted, and this should always be taken into account whenever they are used. If a user does not want his/her e-mail address to be published, he/she should configure their navigator so that it does not leave his/her e-mail address in the servers of the websites he/she visits.
13. Updating of the policiesFrom time to time, NEINVER S.A. shall update this policy on privacy and the processing of personal data obtained from users visiting its website.
Any modification in this policy shall be published and posted in the website of NEINVER S.A. and in the actual policy. Each user must consider that the processing of his/her data shall be governed -in the cases in which he/she notifies them to NEINVER S.A.- by the applicable provisions in force at the time when they have notified their personal data to NEINVER S.A.
14. Contact informationNEINVER S.A. will be pleased to receive any comments from users with respect to this policy on privacy and personal data protection. For that purpose, or for the purpose of making any consultation in relation to the same, users may contact NEINVER S.A. using either electronic means or by mail, at the address shown below.
Users and/or any interested parties may contact NEINVER S.A. by writing to the business address indicated at the top of this document and/or using the following contact particulars:
Telephone: 91 490 22 00
Fax: 91 490 23 01