PERSONAL DATA PROTECTION POLICY

3.2 Online profile: New technologies allow us to create much more accurate profiles, analyzing not only the preferences that you transmit to us in our stores, but also, among others, the following sources of data:

• Information provided at the time of booking an appointment, such as the date of an event, including that of your wedding; the type of surroundings in which you will conduct the event or your wedding; your preferences regarding wedding dress silhouette and neckline; your budget for the dress;
• Information provided at the time of creating a user account, such as personal identity, contact information, and mailing/email addresses;
• Purchases that you may make through our online store, from which we can infer your style and product preferences;
• Behavior on the website itself (content accessed, types of dresses viewed, favorite colors, frequency with which you visit our website), all of which aid us in understanding your personal tastes;
• Behavior with respect to our newsletter (what kind of content leads you to open or click on the newsletter; how often you open our messages); or, among others,
• Relevant information based on the dresses you include in the "My Favorites" section (type of dress, colors, and other features that help us understand your preferences in relation to our products).

Both profiles may be combined when their sources relate to Pronovias, either through physical channels (visits to stores or customer support), online visits to our website, use of apps, activity on social networks, and so on.

3.3 Use and exploitation of data stored in user profiles:

The information that we may collect from our customers is used for a variety of purposes, although these can easily be summarized in two broad groups, (i) purposes relating to personalized services tailored to our customers, and (ii) purely advertising purposes.

With respect to personalized service, being aware of your preferences facilitates our allowing all our Pronovias stores to anticipate your needs so that they and we may offer added value to our services. For example, knowing your dress preferences allows store staff to not only show you dresses that match those preferences (e.g. long or short party dresses, having a given neckline or color, and so on), but also so that whenever you might book an appointment, you may also pre-select all the dresses or products that might match your tastes, including available sizes and colors.

If you have any upcoming events, especially in the case of your wedding, knowing their date allows us to predict the dresses that should be ideally available for conducting fitting sessions, as well as for providing you with up-to-the-minute availability of sizes and types of dresses.

In similar fashion, the creation of these profiles allows us to improve our advertising effectiveness by allowing us to customize and tailor the content of promotional messages to your interests, as well as the type of message we might send you, or how often we might contact you.

For example, if we know your interest in our new collections, we will inform you any time they are introduced and are available for sale. In addition, if you have shown interest in our events – for example, the presentation of new collections – we can invite you to them, also taking into account their location and where the presentation takes place.

All promotional messages may be made both electronically, as discussed below, and by telephone, both directly from Pronovias through its Customer Service department, as well as directly by the store in order to inform you about new dresses, confirm upcoming appointments and reservations or, in general, maintain a business relationship with you.

The personalization of content allows us to ensure that we send you information that may be of interest to you. For example, if we know you have a preference for long dresses, we will prioritize news or promotions about that type of dress.

In addition, depending on your interactions with us, we may offer you special promotions, contests or the option to participate in certain customer-only events.

In the next section on Promotional Messaging, you can learn more about how we conduct it, the channels used, and with what platforms we collaborate to improve our advertising capacity.

All the information contained in the Customer account, and hence all the information about your profile and preferences, is accessible by our San Patrick stores, which use it to improve the personalized service provided in the store itself or in other different companies (for example, in the case of franchises or wholesalers, which are managed by third parties). All the details are the property of San Patrick, S.L.U., without prejudice to the fact that the store, especially when it comes to franchises, may ask you for additional details, for its own use, during your visit to the store.

• Messages sent by email, SMS, MMS or direct messaging (WhatsApp, telegram, Facebook Messenger, direct messages in Forums or on Social Media platforms, and so on):

  If we possess the appropriate information (email, mobile phone number, etc.) we may send you promotional messages by such means. As a general rule, the communication channel will be limited to email, wherever possible, although certain messages may relate to another one of the purposes indicated (e.g. sending reminders, events or surveys).

• Promotional messaging on third-party platforms (e.g. social networks):

  Some third-party platforms (i.e., websites, online communities, or apps, for example) allow outside advertisers, such as Pronovias, to use such platforms to place advertising directly targeting Pronovias customers who also have a user account on the platform.

  To do so, the platform may require the advertiser (Pronovias) to establish the identity of its customers by providing an encrypted and protected means to do so using the technical tools provided by the platforms themselves, with matching based on basic identifying data, such as an email address or phone number.

  Once the identity of a customer and the existence of their user account on the platform has been established, Pronovias can create what is commonly referred to as a "custom audience" comprised of those customers who have agreed to receive advertising on that platform, and may thus display Pronovias advertising directly on the user's profile.

  For example, among social networks, this type of activity can be found on Facebook (Custom Audience), Twitter (Custom Audiences), or Google (Customer Match).

  Such activity is solely intended for advertising purposes, so your data shall only be used if you have previously agreed to receive promotional messages from us.

  In addition, such third-party platforms may also allow their advertisers, such as Pronovias, to use their tools to identify users who, within their platform user base, have a "similar profile" to that of Pronovias customers.

  The procedure for identifying and accrediting the identity of customers is the same as that indicated earlier.

  For example, on social media sites, this type of activity can be found on Facebook (Lookalike Audience), Twitter (Custom Audiences), or Google (Similar Audiences).

  In this case, since the data is not used for a purpose directly relating to sending advertising to our Customers, but rather for sending it to those who, without being customers, possess a profile similar to that of our Customers, we will use the basic data of all our Customers (and not only those who may have agreed to receive promotional messaging) to identify potential customers on that platform. Thus, the advertising will be aimed only at those potential customers who have consented on that particular platform to receive promotional messaging. We conduct such processing based on our legitimate business interest in expanding our client base, but you may object to your data being processed for such purposes at any time.

  As indicated in the preceding paragraphs, the services in question only request basic identifying data; namely, we do not provide all your personal data, not even the preferences that we may already be aware of. Rather, they are limited to an email account or phone number that is shared in an encrypted and protected format using the technical tools provided by the platforms themselves and which is sufficient for the social network to identify you in its database.

  In addition, secure data communication methods, including data encryption prior to upload, are used to ensure data confidentiality and security.

  Finally, we do not obtain data about you directly from such third-party platforms; namely, we may obtain anonymous and statistical data, but never accurate information identifying your interests or indicating whether or not you have seen a particular advertisement, unless you choose to interact with us or with the specific ad.

  If you do not wish us to use your data for advertising purposes on third-party platforms, you may contact us at the e-mail and postal addresses below. If we are already using them on those platforms, we shall delete them during the next update of the data provided.