Privacy Policy

The purpose of this Privacy Policy is to inform the data subjects regarding the collection and processing
of personal data provided by any customer or user through the website www.havaianas-store.com
(hereinafter, the “Website”).

The Website is owned by ALPARGATAS EUROPE S.L.U., with registered office at Avenida Arroyo del
Santo, 4 bis, 28042 Madrid, with Spanish Tax Identification Number B85358596, that is responsible for
collecting and processing your personal data (hereinafter “ALPARGATAS”).

1. PURPOSE OF THE PROCESSING

ALPARGATAS hereby informs you that the personal data you provide to us as a result of (i) browsing the Website, (ii) any queries you make through any of the means indicated in the “Contact Us” section of the
Website as well as manage your subscription in our newsletter, and/or send you commercial
communications, and (iii) the request or purchase of any product, or any transaction or operation
performed by the User through the Website, will be processed for the following purposes:
a) Proceed with any pre-contractual or contractual measures in order to:
• Identify you and, where appropriate, assist and manage your registration.
• Contact you and answer any questions you may have. In this case we may send you an
email in order to complete your registration procedure.
• Carry out all the necessary actions and procedures connected with your purchase.
• Carry out all the necessary procedures in the event that you have some type of pre-
contractual or contractual relationship.
• Carry out all the necessary procedures so you may benefit from our promotions or
discounts.
• Send you an email informing about the status of your shopping cart.
• Record our telephone conversation with you to clarify the details of our conversation and
for internal training and customer service quality control purposes. When you make a
telephone payment, we do not record the part of the conversation that includes your bank
account number, sort code or payment card details.
• Request your bank information in exceptional occasions when you have requested the
cancellation of your order and it is no longer possible to return you the corresponding
money with the same means you used when you placed the order.
b) Analysis of usability and quality to improve our services in order to:
• Draw up statistical profiles.
• Know your opinion and conduct surveys about our products, services and your relationship
with ALPARGATAS in case you gave us your consent.
c) For marketing, subject to your consent, to:
• Send information, by any means, about products and related actions and promotions of
Havaianas brand.
• Receive offers of products, actions and promotions of Havaianas brand that are
personalised and enhanced through the preparation of automated profiles.
• Send our Newsletter periodically
• Maintain your wish list of Havaianas Products active.
• Send notifications when a product is in stock.
d) For Human Resources, when the processing of your personal data shall be necessary, subject to
your explicit consent when applicable:
• Forward your data to our Human Resources department in order to proceed with your
application job submitted through the website.

• Carry out all the necessary procedures, when you connect your account to our fidelity
program, so you may benefit from the privileges of our fidelity program.

2. LEGAL GROUNDS FOR PERSONAL DATA PROCESSING

The legal standings we have to process your personal data are the following:
– The performance of the contract when you make a purchase in order to process your order, the
contract you accept when you register and make a purchase.
– The consent freely given, in order to manage the requests and/or requests that you make,
including doubts, queries and/or complaints, manage the registration and cancellation, the sending
of commercial communications about products and services, as well as making it possible for you
to enjoy any of our services or functionalities. Although you may withdraw your consent at any time,
without it we will not be able to respond to your queries. This will not affect the lawfulness of any
processing previously carried out.
– Legitimate interest in order to carry out satisfaction surveys and to monitor the use made by
users of the information systems from which the services are offered.

3. DATA RETENTION

The data provided will be stored for the time necessary in order to guarantee fulfilment of the legal
obligations corresponding to ALPARGATAS, including:
– For processing activities based on the user’s consent, personal data will be kept until the user
withdraws the consent given.
– For activities based on ALPARGATAS’ legitimate interest, personal data will be kept until the
user objects to the processing activity.
– For processing based on the contractual relationship established by the purchase of our
products, personal data will be retained for the period of time during which the obligations or
responsibilities arising from such provision last.
In any case, once you withdraw your consent or object to the processing activity, the data will be duly
blocked and kept until the expiry of the legal blocking periods relating to the liabilities to which
ALPARGATAS may be subject.
To determine the appropriate retention period of your personal data, ALPARGATAS shall consider the
amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or
disclosure of your personal data, the purposes for which we process your personal data and whether
ALPARGATAS can achieve those purposes through other means, and the applicable legal, regulatory,
tax, accounting or other requirements.

4. DISCLOSURE AND ACCESS TO YOUR DATA

We also hereby inform you that your personal data may be disclosed to other companies of the
ALPARGATAS Group, as well as our affiliates and franchisees, which are located inside the European
Economic Area, with the purpose of the performance the services related with your purchase and the
delivery of the products.
In this regard, ALPARGATAS hereby informs you that it has adopted all the necessary legal measures in
order to ensure that the transfer of data to such countries is secure and in accordance with the provisions
of applicable regulations.

In addition, your data may be accessed by service providers or suppliers with which we have entered into
respective agreements where they need to have access to data in order to preserve the relationship of
ALPARGATAS with its customers. In any event, the necessary legal and organisational measures will be
taken to ensure security and access to the data.

5. SECURITY IN PROCESSING YOUR DATA.

ALPARGATAS has implemented the necessary technical and organisational security measures in order
to ensure the security of your personal data and to prevent their alteration, loss, unauthorised processing
and/or access, given the state of technology, the nature of the stored data and the risks to which they are
exposed to whether from human action or the physical and natural environment.
Any processing related to the services of this Website is performed solely by the personnel designated for
data processing purposes or by the personnel involved in maintenance operations.

6. UPDATING YOUR DATA

You must notify ALPARGATAS of any modification to the data you have provided, and, in any event, you
will be liable for the truthfulness and accuracy of the data provided at any time.

7. WHAT ARE DATA SUBJECT RIGHTS?

In accordance with data protection regulations, you have right to:
 Right of Access. You have right to obtain confirmation as to whether or not personal data is are
being processed, and, if so, access to the personal data and information on the purposes of the
processing, the categories of personal data concerned, the recipients to whom the personal data
is disclosed, and the envisaged period for which the personal data will be stored, among other
information.
 Right to rectification of inaccurate personal data. You have right to obtain the rectification of
inaccurate personal data concerning him/her.
 Right to data portability. You have right to receive the personal data concerning him/her, in a
structured, commonly used machine-readable format and have the right to transmit those data to
another data controller without hindrance, in the cases foreseen in the regulations to this effect.
 Withdraw the consent. You may withdraw the consent at any time, without prejudice to the
lawfulness of the processing previously carried out.
 Right to object to a processing activity based on legitimate interest.
 Right to erasure personal data concerning, when the data is no longer necessary for the
purposes for which such was gathered.
 Obtain the restriction of the processing of personal data, which will then only be processed
for the establishment, exercise or defence of legal claims.
The aforementioned rights may be exercised by sending a written communication to the following email
address dataprotection@alpargatas.com.
We inform you that ALPARGATAS will address the right exercised within one month, counting from the
reception of the request. This period may be extended by two months, considering the complexity and
number of applications, in which case data subject will be notified.
Additionally, you may lodge a complaint in relation to the processing of personal data with the competent
supervisory authority, when you consider that your rights set forth in the applicable regulations have been
violated.

8. INTERNATIONAL DATA TRANSFERS

We inform you that, although no international transfer is planned, the provision of services by
ALPARGATAS to its clients may be associated with imply international data transfers. If this is the case,
such transfers are regulated in accordance with the provisions of current legislation on data protection, as
indicated by the said third parties.

9. THIRD PARTIES’ PERSONAL DATA

In the event the user includes personal data relating to other person, he/she must, prior to the inclusion or
communication of their data, inform such persons of the content of this Privacy Policy. In any case, data
subject guarantees that it has obtained prior consent of these third parties for the communication of their
personal data to ALPARGATAS.

10. MODIFICATION OF THE PRIVACY POLICY

ALPARGATAS reserves the right to modify and/or update this privacy policy at any given time in order to
adapt it to the applicable legislation. In any event, the content of the new policy will be published on this
Website and will remain available to users and visitors at all times. We recommend that you regularly
check Website to make sure you are aware of any changes.