PRIVACY POLICY

1. Introduction

The purpose of this Policy is to inform, in accordance with the provisions of the applicable regulations, about the processing that will be carried out regarding the personal data collected through the website www.totto.es (hereinafter referred to as “TOTTO.ES”).

2. Who is the Controller?

  • Identity: UNCONDITIONAL PARTNERS, S.L. (hereinafter referred to as “UNCONDITIONAL”)
  • Postal address: C/ Coto de Doñana, 14. Pinto. 28320. Madrid
  • Phone: (+34)911903836
  • E-mail: online@totto.es

3. How do we collect personal data?

Users are informed that, as a result of the use of certain functionalities of TOTTO.ES, it is necessary to provide certain personal data that will be incorporated into files for which UNCONDITIONAL is controller. Specifically, TOTTO.ES will register the following information:

  • Data of the contact form that the User interested in obtaining commercial information - and/or relating to the management of orders for TOTTO brand products - voluntarily provide to UNCONDITIONAL, (full name, e-mail address and phone number).
  • Data of the newsletter form that the User interested in receiving information about news, offers, and promotions of TOTTO brand products voluntarily provide to UNCONDITIONAL (full name, birth date, postal code, e-mail and phone number).
  • Registration in TOTTO.ES store: personal data (including, but not limited to, full name and e-mail address) provided by the User when registering for the first time or when managing their personal account in TOTTO.ES online store.
  • Sending of e-mails: personal data (including, but not limited to, e-mail address) that the User provides us by sending an email to @totto.es addresses.
  • Data included in the form "Work with us": personal data - including CV - that the User voluntarily provides to participate in selection processes carried out by UNCONDITIONAL.

The use of the different forms and functionalities of TOTTO.ES is voluntary. However, some fields are necessary to correctly process your request (e.g. for the management of returns and exchanges), the inclusion of personal data in the remaining fields being voluntary or accessory. The refusal of the User to provide the information required in the mandatory fields could prevent UNCONDITIONAL from processing your request.

4. For what purpose do we process your data?

In general, the information registered through TOTTO.ES which UNCONDITIONAL obtains from Users will be processed for the following purposes:

  1. Processing and responding to requests made by Users through the forms enabled in TOTTO.ES and/or by e-mail.
  2. Allowing the purchase, assisting, delivering, and processing the payment of products purchased by Users at TOTTO.ES online store, as well as managing possible returns and/or exchanges.
  3. Allowing access and management by the User of their account at TOTTO.ES online store
  4. Sending of the newsletter and other commercial communications, whit the previous authorization of the User.
  5. Management of selection processes in which the User participates as a candidate.

5. To which recipients will we communicate your data?

In general, UNCONDITIONAL does not intend to communicate your personal data to any third Party, except for those data strictly necessary that UNCONDITIONAL PARTNERS needs to communicate to:

  1. Companies or entities appearing in "Payment methods", in order to process the payment of the products acquired at TOTTO.ES online store (connection with payment gateway in the case of payment by credit card).
  2. Companies providing transport or courier services (e.g. SEUR, NACEX, etc.) for the correct delivery of the products purchased at TOTTO.ES online store.

Likewise, UNCONDITIONAL contracts the infrastructure and functionalities of the web, as well as the development of its online store through NALSANI SAS, VICOM, VTEX, ICOMMKT, supplier companies with headquarters outside the European Union with which UNCONDITIONAL has signed the corresponding contracts based on standard contractual clauses, approved by the European Committee for Data Protection, ensuring the adequate level of protection required by regulations for international transfers. Likewise, VICOM, VTEX, ICOMMKT, are companies whose services use the infrastructure of Amazon Services LLC, a company under the Privacy Shield Agreement between the EU and the US.

5. To which recipients will we communicate your data?

The legal base for the processing of the data collected is the consent of the User expressed by accepting this Privacy Policy, or by sending an e-mail to any of the addresses provided through TOTTO.ES.

Likewise, when the User acquires products at TOTTO.ES the legal base for the processing of their data is legitimated by the contractual relationship arising from the purchase made.

Where appropriate, if accepted, the legal base for sending commercial communications is legitimized by the consent provided by the User.

7. How long will we keep your data?

The personal data collected will be kept by UNCONDITIONAL only during the time necessary to process and manage each specific request made by the User.

  • In the case of the contact form, or e-mails, data shall be kept during the time necessary to properly process your request, or to resolve possible incidents, where appropriate.
  • In the case of newsletter and/or commercial communications, data shall be kept until the User revokes the consent given for their reception.
  • In the case of the form "work with us", data shall be kept for a year from the date of sending of the aforementioned form, for selection processes that could begin in such period.

However, after this period, the data may be blocked and maintained by UNCONDITIONAL to cover possible liabilities arising from the processing and only during the limitation period of such responsibilities. After the mentioned time limits, personal data will be deleted by UNCONDITIONAL.

8. What are your rights when you provide us with your data?

The User may revoke at any time the consent given for the processing of their data.

At any time, the User can request UNCONDITIONAL to confirm whether their personal data are being processed by our Company and, if so, access them. Likewise, the User can request the rectification of inaccurate data or, where appropriate, its erasure when, among other reasons, the data are no longer necessary for the purposes for which they were collected.

Likewise, under certain circumstances, the User may request the restriction of the processing of their data, in which case we will only keep them for the exercise or defence of claims. The User may also object to the processing of their data in certain circumstances. UNCONDITIONAL will stop processing the data, except on compelling legitimate grounds or for the exercise or defence of possible claims. Finally, where appropriate, the User may exercise the right of data portability in order to obtain the data in electronic format or to transmit them to a different entity.

To that end, they can use the following channels, always accompanying a photocopy of their Identification Document or any other document proving their identity:

  • By letter to the postal address: C/ Coto de Doñana, 14. Pinto. 28320. Madrid
  • By e-mail to online@totto.es

Finally, Users are informed of their right to file a claim with the Spanish Data Protection Agency if they become aware or consider that there might be a fact involving a breach of the applicable regulations on Data Protection.

9. Updates and changes in the Privacy Policy

UNCONDITIONAL reserves the right to make changes to this Privacy Policy. Therefore, Users are advised to check it periodically. When significant changes are made to this Privacy Policy, Users will be notified for acceptance through notices on TOTTO.ES, or through any other appropriate procedure according to the circumstances.