Privacy

Last updated: November 8, 2018

INTRODUCTION

TWOTHIRDS SLU with VAT number ESB75025494, is a company organized and existing under the laws of Spain, with the office located in Barcelona, C/Goya, 12 (08012) SPAIN.

At TWOTHIRDS SLU we are deeply committed to the relationship of trust we have with you, our consumers and friends.

We make goods for a better future. We create sustainable products designed in Barcelona, crafted in Portugal.

As we continue to innovate in how we bring our products to life online, we'll match cutting-edge technology with your privacy interests. The information below constitutes our Privacy Policy. It describes what information is collected when you interact with our website, apps and our other communication channels (“other channels”) such as social media and how we use, share and protect it. It also explains the rights and the choices you have relating to your personal information and how you can contact us.

 

OUR PILLARS OF PRIVACY

 

  • TRANSPARENCY: We want you to know what information is collected when you interact with our stores, websites, apps and our other channels and how we use it.
  • YOUR RIGHTS: We will offer you choices about how your information can be used.
  • DATA INTEGRITY: We take reasonable security measures to protect the personal information we collect from you.

  

Contact Us Regarding Your Information

If you have any questions or concerns about our Privacy Policy or you wish to exercise any of your rights related to your information, please contact us by clicking here.

Although we urge you to contact us first to find a solution for every concern you may have, you always have the right to lodge a complaint with your competent data protection authority.

 

TRANSPARENCY

What Information Do We Collect?

When you interact with our website, apps and other channels, we may collect information about you from three main sources:

  • you may give us some of this information directly;
  • we may collect information automatically from your interaction with our website, apps and other channels; and
  • we may also obtain information from third parties.

Depending on how you interact with our Web, i.e., depending on the services, products or functionalities that you wish to enjoy, we will process your personal data for the following purposes:

 

PURPOSE

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1. To manage your registration as user of the Web

If you decide to become a registered user of our Web, we need to process your data to identify you as a user of the Web and grant you access to its various functionalities, products and services available to you as a registered user. You may cancel your registered user account by contacting us through Customer Support.

2. For the development, performance and execution of the purchase or services contract

This purpose includes processing your data, mainly:

 

  • To contact you for updates or informative notices related to the contracted functionalities, products or services, including quality surveys and to be able to establish the degree of customer satisfaction with the provided service;
  • To manage payment of the products that you purchase, regardless of the payment procedure used. For example:

 

    • If on purchasing any of our products through the Website or the App, you opt to activate the functionality of save your card data for future purchases, we need to process the indicated data for activation and development of that functionality. Consent to the activation of this functionality enables your autocompleted payment data to appear in subsequent purchases so that you do not need to introduce them in each new process, and these data will be deemed valid and effective for subsequent purchases. You may change or cancel your cards at any time through the section on payment information, either of your Website registered user account.

 

  • Activate the necessary arrangements in order to control and prevent potential fraud against you and against us during the purchase process. If we consider that the transaction can be fraudulent, this processing may cause the blocking of the transaction.

 

  • To manage potential returns after you have purchased and manage requests of availability information for articles, reservations of products through the Web, depending on the availability of such options from time to time.

 

  • For invoicing purposes and to make available to you the tickets and invoices of the purchases you have made through the Web.

3. To meet requests or applications that you make through the Customer Support channels

We only process the personal data that are strictly necessary to manage or resolve your request or application.

 

4. For marketing purposes.

This purpose includes the processing of your data, mainly, for:

If and when you subscribe to our Newsletter, we will process your personal data to manage your subscription, including to send customised information on our products or services through various means (such as e-mail or SMS). We may also make available to you this information through push notifications in case you have activated them in your mobile device.

    • Accordingly, please take into account that this data processing implies analysis of your user or customer profile to establish your preferences and therefore which products and services are most fit to your style when sending you information. For example, based on your purchases and browsing history (i.e., depending on the articles that you clicked), we will make you suggestions on products that we believe may interest you and, if you are a registered user, we will provide you with the "recover cart " functionality.

 

    • Remember that you may unsubscribe from the Newsletter at any time without cost through the "Newsletter" section of the Platform, in addition to the instructions that we provide you with each notice. If you do not want to receive push notifications, you can deactivate this option in your mobile device.
  • To perform promotional actions (for example, for the organization of competitions or to send the list of items stored to the e-mail you designate). On participating in any promotional action, you authorise us to process the personal data that you have shared with us depending on the promotional action and disclose them through different media such as social networks or the Platform itself. In each promotional action in which you participate you will have the terms and conditions available where we will be providing more detailed information about the processing of your personal data.

To disseminate in the Platform or through our channels in the social networks photographs or pictures that you shared publicly, provided that you expressly give us your consent for the purpose.

5. Analysis of usability and quality to improve our services

If you access our Web, we inform you that we will treat your browsing data for analytic and statistic purposes, i.e., to understand the manner in which users interact with our Web and thus be capable of introducing improvements in the Web.

In addition, we occasionally perform quality surveys and actions to know the degree of satisfaction of our customers and users and detect those areas in which we may improve.

 

How And Why Is Your Information Used?

We use the above described information we collect about you to pursue the following purposes, which are necessary for the performance of the contract between us to provide you with the products or services you requested or which we consider in our legitimate interests:

 

Purpose

Legal standing

1. To manage your Web user registration

We process your data because this is necessary on the terms regulating the use of the Web. In other words, for you to be able to register as a user on the Web, we need to process your personal data, since we would otherwise be unable to manage your registration.

2. Development, performance and making of the purchase or services contract

We process your data because their processing is necessary for us to make the purchase or services contract with you.

 

Certain processing of data related to the purchase process is activated only because you request or authorise it, as is the case of the storage of payment (card) data for future purchases. In these cases, our processing of your data is supported by your own consent.

 

We consider that we have a legitimate interest to carry out the necessary verifications to detect and prevent potential fraud when you make a purchase. We understand that the processing of these data is positive for all the participating parties when a purchase is paid and in particular for you, since this allows us to establish measures to protect you from fraud attempts by third parties.

3. Customer Support

We consider that we have legitimate interest in answering the requests or queries raised by you through the existing different contact channels. We understand that the processing of these data is also beneficial to you to the extent that it enables us to assist you adequately and answer to the queries raised.

When you get in touch with us, in particular, for the management of incidents related to your order or the product/service acquired through the Web, the processing of your data is necessary to perform the purchase contract.

 

When your request is related to the exercise of your rights on which we inform you below, or to claims on our products or services, we are legally permitted to process your data for compliance with our legal obligation

4. Marketing

We are legally permitted to process your data for marketing purposes due to the consent that you give us, for example when you accept receiving customized information through multiple channels, when authorizing the sending of notifications or when accepting the legal terms and conditions to participate in a promotional action or to publish your pictures on the Web or on our social networks' channels.

In order to show you customised information. We consider that we have a legitimate interest to conduct a profiling with the information that we have about you (such as your  browsing, preferences or purchase history) and the personal data that you have provided us, such as the age range or language, since we understand that the data processing of these data is also beneficial to you because it allows you to improve your user experience and access the information in accordance with your preferences.

5. Analysis of usability and quality

We consider that we have a legitimate interest in analysing the Web usability and the user's satisfaction degree, since we understand that that the processing of these data is also beneficial for your because the purpose is to improve the user experience and provide a higher quality service.

 

In order to comply with our legal obligations and security of our website, we may also use some of your personal information to detect and prevent illegal uses, abuse, spam, (payment) fraud (e.g. payment card authentication) security incidents and other harmful activity or government or court orders.

If we use your information for other purposes than those above mentioned, we will notify you of these purposes before using your information and obtain your consent where necessary.


With Whom Do We Share Your Information?

We may share information we collect from you or about you with some of our business partners who help us operate our website, apps or other channels and provide important services to our customers and visitors: we consider these our trusted business partners. Our trusted business partners may change over time but we are committed to building relationships with third parties who are dedicated to providing you a safe and satisfying experience.

The following categories of trusted business partners may come into contact with your personal data and/or information:

  • external consumer relations service provider;
  • payment processing providers, who need to process your data in order to allow you to make payments for your online purchases;
  • transport and shipping companies;
  • third party advertising and analytics companies who collect browsing information and profiling information and who can provide advertisements which are tailored to your interests;
  • social media companies, where you make use of social media features that are offered on our websites or apps;
  • added value service providers who provide their services via our websites or apps;
  • service providers who host and operate our websites, apps or other channels.

Our trusted business partners will be given limited access to your personal data as is reasonably necessary to deliver the services they are engaged to provide. They are also contractually obligated to collect and use any personal information collected from you in our website, apps or otherwise on our behalf in a manner that is consistent with this Privacy Policy. Any trusted business partner that processes your personal data on our behalf will also commit to implement reasonable security measures.

In addition to the foregoing, please note that the third parties mentioned above will in many cases have their own statement regarding the collection and use of your personal data and information. We strongly advise you to carefully review these statements.

Any reference to “we” or “us” in this Privacy Policy may also refer to our trusted business partners.

We may also share some of your user generated content in our website, apps or other channels with the general public visiting our website, apps or other channels.

We may also be required to disclose your information to public authorities or other governmental agencies only to the extent this is permitted under data protection laws and is required by mandatory provisions in applicable laws.

International Transfers

Personal information we collect or process when you use our website, apps or other channels may be stored or processed by TWOTHIRDS SLU or other recipients listed above in countries other than the country in which your personal information originally was collected. The laws in those countries may not provide the same level of data protection compared to the country in which you initially provided your personal information. However, please rest assured that we implement all the necessary and appropriate legal, organizational and technical measures to protect your personal information. Furthermore, as regards the transfer of personal information to countries outside the EU, we have entered into so-called “Standard Contractual Clauses” approved by the Commission of the European Union for international transfer of personal information to controllers or processors established in third countries as the case may be.

How Long will we keep your data?

The principle that we apply is that your personal information will be deleted when they are no longer necessary for the purpose for which they were collected.

The time for which we will keep your data will depend on the purposes for which we process them, as explained below:

 

Purpose

Time for which the data are kept

1. To manage your Web user registration

We will process your data for the time during which you remain a registered user (meaning, until you decide to unsubscribe).

2. Development, performance and execution of the purchase or services contract

We will process your data for the time necessary to manage the purchase of the products or services that you buy, including potential returns, complaints or claims related to the purchase of the product or service in question.

Sometimes, we will only process the data until the time when you decide, as is the case of payment (card) data that you requested us to store for future purchases.

3. Customer Support

We will process your data for the time necessary to meet your request or application.

4. Marketing

We will process your data until you unsubscribe or cancel your subscription to the newsletter.

If you participate in promotional actions, we will keep the data during a six (6) months period from the end of the action.

5. Analysis of usability and quality

We will process your data occasionally for the time during which we proceed to carry out a specific quality action or survey or until we anonymise your browsing data.

 

Notwithstanding the fact that we will process your data for the time strictly necessary to achieve the purpose in question, we will subsequently keep them duly stored and protected for the time during which liability may arise for their processing, in compliance with legislation in force from time to time. Once each of the potential actions is time-barred we will proceed to delete the personal data.Children’s Privacy

Our websites and apps do not address anyone under the age of 14 (“Children”). We do not knowingly collect personal information from children under 14. If you are a parent or guardian and you are aware that your child has provided us with personal information without your consent, please contact us and we will take steps to remove that information from our servers.

Analytics

Information collected through cookies to keep track of what products you viewed and purchased and what areas or pages you viewed on our websites or apps is called “analytics data”. We use analytics data to improve the design and content of our websites and apps, to help us learn things like what pages are most attractive to all of our visitors and what promotions visitors like to see, and to gauge the success of our advertising campaigns.

Interest-Based Advertising

Interest-based advertising has become commonplace across the Web. It is the term we use for the activity that enables us to tailor ads to your interests and activities. Either TWOTHIRDS SLU or third-party advertising companies we work with may look at your browsing activity, such as the types of content you access, ads you click on, and searches you conduct. We can then infer certain interests you have and place ads and offer you deals that meet your needs. Our goal for interest-based advertising is to show ads to people likely to be interested in the products we offer at TWOTHIRDS SLU We believe these interest-based ads are more useful to you than randomly-generated ads because they are tailored to your shopping and product interests as indicated by your browsing habits.

If you would like to learn more about interest-based advertising and see what choices you may have about how companies use your information, please go to http://aboutads.info/choices/ or http://www.networkadvertising.org/choices/. We do not operate or control these sites, and are not responsible for the opt-out choices available there. The only way to fully opt-out of online tracking is to adjust your browser settings to reject cookies or to notify you when a cookie is set. Please remember, even if you opt-out of interest-based advertising on or through http://aboutads.info you may still receive ads from TWOTHIRDS SLU, as interest-based ads are only one form of advertising.

Finally, it is important to note that in most cases opting out drops an “opt-out cookie” on your browser. As a result, if you delete, block or otherwise restrict cookies or use a different computer or Internet browser, you will need to renew your opt-out choice.

 

Third-Parties Websites, Apps and Services

Our websites and apps may contain hyperlinks to and from websites and apps of third parties such as Facebook or Instagram. If you follow a hyperlink to one of these websites or app or interact with them, please note that we cannot assume any responsibility or warranty for the third party content or data protection conditions, nor do we have any influence on this. We encourage you to review the privacy policies of these third-parties websites and apps before you transmit personal information to these websites and apps.

Parts of our websites and apps use Google Maps/Earth services, including the Google Maps API(s). Use of Google Maps/Earth is subject to the Google Maps/Google Earth Additional Terms of Service (including the Google Privacy Policy).

 

YOUR RIGHTS

We undertake to keep your personal data confidential and to ensure that you may exercise your rights. Bearing that in mind, we have agreed that you may exercise your rights free of charge by writing us an e-mail to a single e-mail address (data@twothirds.com), simply informing us of the reason for your request and the right that you wish to exercise. If we consider this necessary to be able to identify you, we may request you to provide a copy of a document evidencing your identity. In any case, you have at your disposal our Personal Data Subject Rights Guide and a Request Form.

In particular, notwithstanding the purpose or legal basis we use to process your data, you have the following rights:

  • To request access to your personal data that we hold. We remind you that where you are a Web registered user you may also consult this information in the relevant section of your online account.
  • To request that we rectify the personal data that we hold. Please bear in mind that if you are a registered user on the web, you may also access the relevant personal data section of your online account to change or update your personal data. In any case, please take into account that, on actively making your personal data available to us through any procedure, you guarantee that they are true and accurate, and you undertake to notify to us any change or modification of your data. You will be liable for any loss or damage caused to the web or to the person responsible for the web or to any third party by reporting erroneous, inaccurate or incomplete information in the registration forms. Please remember that, as a general rule, you must provide us only with your own data, not with those of third parties, other than to the extent otherwise permitted in this Privacy Policy.
  • To request that we erase your personal data to the extent that they are no longer necessary for the purpose for which we need to keep processing them, as we have explained above, or when we are no longer legally permitted to process them.
  • To request that we cancel or limit the processing of your personal data, which entails that in certain cases you can request us to temporarily suspend the processing of the data or that we keep them longer than necessary.

If you have given us your consent to process your data for any purpose, you also have the right to withdraw such consent at any time.

When we are legally permitted to process your data due to your consent or to for the purposes of a contract you will also have the right to request the portability of your personal data. This means that you will have the right to receive the personal data that you made available to us in a structured, commonly used and machine-legible format, to be able to transmit them to another entity directly without impediments on our part.

In addition, where the processing of your data is based on our legitimate interest, you will also have the right to object to the processing of your data.

Finally, we inform you that you have the right to file a claim before the responsible data protection regulatory authority, in particular, before the:

Regarding our marketing emails, you can always click on the "Unsubscribe" link at the bottom of any marketing email you receive from us or click on the “Unsubscribe” button in “My Account – Email Preferences” on our websites to opt out of receiving email communications from us in the future.

Your web browser or mobile device may also provide additional tools to allow you to control when your device provides specific categories of information (for example geolocalisation data or cookies use). Be aware of these tools. See our cookie policy section for more information.

 

SAFEGUARDING YOUR PERSONAL INFORMATION

When you register on our website or apps, we ask you to set up a username/login and password that you can use to access your information at our website and apps. If you want to change your username/login or password, sign in to your account by clicking on “My Account” from any page, or click on "Manage Your Account" from within the Help section Desk and follow the instructions.

We maintain appropriate, administrative, technical, organizational and physical safeguards to protect the personal data you provide to us against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use, and other unlawful forms of processing.

We use industry recognized security technology for establishing an encrypted channel to pass information between two systems. This link ensures that all data (payment information, personal information) passing between your computer and our websites remain private and secure.

However, when you communicate with customer service via email or chat on our website, the level of protection for such communication channels is not guaranteed (e.g. there is no encryption), and therefore, be aware that information provided (such as email address, payment information, etc.) may be accessible to others. For that reason, we ask that you protect yourself and not share sensitive information via these communication channels.

Interacting with social media on our website or apps

We may receive information from third parties through the social links presented on our website or apps in the form of social buttons like Tweet, Like or Pin it. By clicking on one of these buttons, you will be prompted to log in to the corresponding social media website; you will essentially be browsing both our website/app and the social platform at the same time, but your experience with the social components will be governed by the privacy and other policies of the social platform. The privacy settings you have chosen on that social media platform will determine the degree to which your information is made public. We encourage you to choose your privacy settings accordingly.

SECURE SHOPPING

We take security very seriously, so your personal information will be protected. We use the industry standard encryption protocol known as Secure Socket layer (SSL) and other reasonable measures to protect your information from unauthorized use or disclosure. All the confidential data like payment information is encrypted and transmitted through a secure channel using SSL encryption.

If  any unauthorized charges appear on your credit card as a result of shopping with www.twothirds.com, you must notify your credit card provider in accordance with its reporting rules and procedures.

Please note that we never ask a customer to confirm any account or credit card details via email. If you receive an email claiming to be from TWOTHIRDS SLU asking you to do so, do not respond and let us know by clicking here.

Online Updates to the Privacy Policy

Our practices and applicable laws change over time. We may modify this Privacy Policy at any time to reflect these changes and will post the revised Privacy Policy on our websites and apps and elsewhere as appropriate. We strongly recommend that you read our Privacy Policy every time you visit our website to see if we’ve made any changes since your last visit. If we materially change our practices regarding the processing of personal data, where legally required, we will highlight such changes on our websites and apps and request your consent, where necessary.