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PERSONAL DATA PROCESSING

At DANG DANG, S.L.U., we care about the personal data that we process and about precise compliance with the legislation in force regarding personal data protection, which includes Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.

Pursuant to that regulation, we would like to inform you about the following matters related to the personal data processing we perform at DANG DANG, S.A.U.

Who is the controller of your personal data?

Identity: DANG DANG, S.A.U.

Tax ID no.: A20083879

Postal address: Calle Portuetxe 24 bajo, Telephone: +34 943 32 61 26 20018, San Sebastián, Guipúzcoa.

Email: info@indiandcold.com

Principles related to the processing

The personal data processing that takes place at our company respects the principles required by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter, GDPR).

• Principle of lawfulness, fairness and transparency: the data we collect are processed lawfully, fairly and transparently, with the prior consent of the data subject when this is necessary or, where applicable, to perform a contract to which the same is party, or to implement pre-contractual measures taken at the data subject's request, or if the processing is necessary to comply with an applicable legal obligation.

• Principle of purpose limitation: the personal data we process will be used for the purposes described in the section “What do we use your personal data for?”.

• Principle of data minimisation: in accordance with this principle, the only personal data we collect from users are the ones that are strictly necessary to achieve the purposes described in the section “What do we use your personal data for?”.

• Principle of accuracy: The personal data we collect will be kept accurate and, if necessary, updated. To this end, shloud there be any change to your personal data, you should notify us, so we can make the appropriate update.

• Principle of storage limitation: the personal data we process will be stored for the time periods stated in the section “How long do we keep your personal data?”.

• Principle of integrity and confidentiality: to respect this principle, personal data will be processed in such a way as to guarantee an appropriate level of security, including protection against unauthorised and illegal handling and against their loss, destruction and accidental damage, and, to this end, we apply the appropriate technical and organisational measures.

What do we use your personal data for (whether or not you are a website user)?

Customer data: to properly maintain, develop, perform and control contractual relationships with our customers, to process and send the orders or purchases they make, and to provide the services they require.

Furthermore, we use customers’ identity and contact data to send, electronically or using other means, marketing information of interest regarding offers, promotions, products and services.

Supplier data: to properly maintain, develop, perform and control contractual relationships with our suppliers and the services they provide to us.

Employee data: to maintain, develop, perform and control contractual relationships with our employees, and to comply with the applicable legislation in force regarding employment, social security and occupational risk prevention.

Candidate data: to manage the participation of data subjects in the staff selection processes the company organises.

Data collected through the contact form: to manage and respond to queries, complaints, suggestions and requests that users make through the website.

Data collected through the newsletter form: to send newsletters providing information, news and marketing information about offers, promotions, discounts and new products, all of which relates to our business and the textile sector.

Data belonging to members of the loyalty plan: to manage their membership of this plan, so they can enjoy the advantages and discounts we offer its members, and to send them marketing information of interest regarding offers, promotions, products and services.

Data processing excluded by the GDPR

Recital 14 of the GDPR provides that “the protection afforded by this Regulation should apply to natural persons, whatever their nationality or place of residence, in relation to the processing of their personal data. This Regulation does not cover the processing of personal data which concerns legal persons and in particular undertakings established as legal persons, including the name and the form of the legal person and the contact details of the legal person”.

This means that this regulation and the obligations and rights it contemplates will not be applicable to some of the data processing performed by DANG DANG, S.A.U., specifically, the processing related to customers that are legal persons and suppliers.

Why is it legitimate for us to process your personal data?

Customer data: the legal basis for processing personal data belonging to customers is to perform contracts or fulfil orders they make.

Regarding sending marketing information, the legal basis is to satisfy the legitimate interests pursued by DANG DANG, S.A.U. pursuant to Article 6.1.f of the GDPR. This will be notwithstanding the possibility for the customer to object to such marketing information being sent.

Supplier data: the legal basis for processing personal data belonging to suppliers is to perform contracts or existing business relationships with the company.

Employee data: the legal basis for processing personal data belonging to employees is to perform employment contracts between the company and its employees.

Candidate data: the legal basis for processing the personal data belonging to the data subject is the consent this person gives when they provide us with their curriculum vitae to take part in the staff selection processes we organise.

Data collected through the contact form: the legal basis for processing the data subject’s personal data is the consent they give when they contact us through the contact form and, therefore, the need to process the said data to deal with and respond to the contact request made to us.

Data collected through the newsletter form: the legal basis for processing the data subject's personal data is the consent they give when they subscribe to the newsletter.

Data belonging to members of the loyalty plan: the legal basis for processing the personal data is the consent given when the data subject joins our loyalty plan.

How did we get your personal data?

All the personal data we process at DANG DANG, S.A.U. is given to us by the data subjects or their legal representatives.

The personal data we collect through this website have been collected through the different forms available or through the email addresses set up to enable contact with us.

Who will be the recipients of your personal data?

Personal data belonging to customers, suppliers and employees will be communicated, where applicable, to the tax authorities to comply with our legal and tax obligations, and to the financial entities through which DANG DANG S.A.U. manages charging (in the case of customers) and payments (in the case of suppliers and employees).

However, for more efficient, dynamic and operative management of the informative communications we send by email, and to be able to better control them, we use MailChimp, a platform developed by The Rocket Science Group LLC, an entity that is certified with the EU-U.S. Privacy Shield. Available information regarding this: https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active. The Rocket Science Group LLC privacy policy: https://mailchimp.com/legal/privacy/.

How long will we keep your personal data?

Customer and supplier data:

• Five years: corresponding to the limitation period for tax obligations, as established in tax regulations. The same term for exercising personal actions that do not have a special limitation period, as established in Article 1,964 of the Spanish Civil Code.

• Six years: in relation to books, correspondence, documentation and written proof concerning the business, as required by Article 30 of the Spanish Commercial Code.

• 10 years: documentation formalising compliance with the obligations established in Spanish Law 10/2010 of 28 April on the Prevention of Money Laundering and Terrorist Financing, as required in Article 25 therein.

Employee data: personal data belonging to employees will be kept while the contractual employment relationship remains in force and, when the relationship comes to an end, for the limitation periods for liabilities established in the applicable legal provisions.

Candidate data: personal data belonging to candidates will be kept for a maximum of two years.

Data collected through the contact form: personal data that users give us when they fill in this form will be kept solely while we deal with their request and so, once processing has been completed, they will be erased.

Data collected through the newsletter form: personal data that users give us when they subscribe to our newsletter will be kept until they withdraw their consent.

Data belonging to members of the loyalty plan: personal data that members of the loyalty plan give us will be kept until they request deregistration.

Data belonging to users of our social network profiles: the time periods during which personal data belonging to our followers on social networks will be kept depend on the policies of each social network, although we will process them only until they stop following

What are your rights when you give us your personal data?

• Right to request access to your personal data: to find out about and check the lawfulness of our processing, you may, at any time, ask us to confirm whether DANG DANG, S.A.U. is processing your personal data and, in such event, we will tell you, among other matters, what data we are processing, the purpose, the origin of the data, how long we plan to keep the data and, where applicable, the recipients or recipient categories.

• Right to request rectification: you may ask us to rectify any personal data that may be inaccurate or to complete any that may be incomplete, including by providing an additional declaration. If you do this, in your request, you should state the data in question and the correction that has to be made, and, where applicable, you should include documentation to prove the inaccuracy or incomplete nature of the data being processed.

• Right to request erasure (right to be forgotten): you may ask us to erase your personal data and to stop processing them if they are no longer necessary in relation to the purposes for which they were collected or otherwise processed, if you withdraw your consent, if they were processed illegally or if they have to be erased to comply with a legal obligation.

• Right to request limitation on the processing of your personal data: in this event, DANG DANG, S.A.U. will keep your personal data only for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest.

• Right to the portability of your personal data: you may ask us to hand over your personal data to you or to another controller that you may designate, in a structured, commonly used, machine-readable format.

• Right to object to processing: DANG DANG, S.A.U. will stop processing your personal data as you request, unless we have to continue processing them for compelling legitimate reasons or for the establishment, exercise or defence of possible legal claims.

How to exercise your data protection rights: to exercise your rights, send us a written request by post to DANG DANG, S.A.U., Calle Portuetxe, nº 24, 20018, San Sebastián, Guipúzcoa, or by email to contacto@indiandcold.com, always including a photocopy of your identity document.

DANG DANG, S.A.U. will respond to all requests within the time periods and pursuant to the conditions required in the legislation in force regarding personal data protection.

How to lodge a complaint with the Spanish Data Protection Agency: if you believe that we have failed to appropriately process your personal data or that we have not properly assisted you in exercising your data protection rights, you can lodge a complaint with the Spanish Data Protection Agency, either through its electronic office or by post, to Calle Jorge Juan, nº 6, 28001, Madrid.

You can find more information about data protection rights and complaints to the controlling authorities at www.agpd.es.

Security

Pursuant to the provisions of Article 32 of the GDPR, DANG DANG, S.A.U. has implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk.

For the purposes of assessing the appropriate level of security, special attention has been paid to the risks that are presented by processing data, in particular from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.

Duty of secrecy

DANG DANG, S.A.U. has adopted measures to ensure that anyone acting under its respective authority who has access to the personal data that users provide to us can process them only following the company’s instructions, and they must also maintain the corresponding professional secrecy regarding the same, and this will be applicable for an unlimited term.

To this end, our employees have signed a confidentiality document and duty of secrecy regarding the information and personal data that they process as a result of their employment relationship with the company.

Use of the website by children

We ask all users to read the policies on use of the website by children that we have published in the “Legal Notice” on our website.

Social networks

Profiles on social networks: DANG DANG, S.A.U. has profiles on some of the leading social networks currently available, which means that we may process personal data belonging to our followers, people who appear in our publications (e.g. photographs) and people who send us private messages.

Data processing and purpose: the data processing that DANG DANG, S.A.U. will perform will be limited to, and conditional on, the policies and functionality of each social network. When a user becomes one of our followers on a social network, they consent to us using their personal data solely within the sphere of the corresponding social network to manage our page or profile and the communications that we bidirectionally maintain with our followers through chat functions, messages and other means of communication that the Social Network permits, at present or in the future. This means that we will have access to the user’s profile information that appears on the comment, which may include, but is not limited to, their username, image (if the user has put a photograph on their profile) and any comments made.

We would also like to notify you that, when a user becomes one of our followers, the news we publish may also appear on their wall and that, if they make comments on our wall, their comment, profile name and, where applicable, the photograph they have on their profile will be accessible to other followers. In any event, the user is liable for how they use the Social Network.

We will not use personal data belonging to users for any purposes other than the ones stated in the above paragraphs or to send them information through any environment other than the social network.

Unless the data subject gives us their consent or should so request so we can deal with a request they make to us, we will not extract their personal data from the social network environment.

Data protection rights: regarding the rights to access, rectify or erase, processing limitation, objection and portability of personal data, we may act only in accordance with the possibilities that each social network permits for this purpose. DANG DANG, S.A.U. will give all possible assistance to the data subject to enable them to exercise the rights mentioned.

In any event, any of our followers may deregister from our page or profile at any time so that we would no longer have access to their personal data, although the social network may keep any comments they have previously made on our wall.

In any event, the user is liable for how they use the Social Network, which means that DANG DANG, S.A.U. assumes no liability in this regard.

Cookies

Cookie Policy

Please be informed that this website uses first-party and third-party cookies for operational purposes (for example, to manage the acceptance of cookies), and to analyse web traffic. Herein you will be able to select the cookies that you wish to accept.

Necessary cookies

Cookies that allow the website to function correctly. Without them, some of its functionalities would be seriously affected. These cookies do not require consent, just information, which can be found following the link above. They can be disabled only via the browser settings.

Analytical cookies

Cookies managed by Google Analytics, which allow us to analyse web traffic to improve our content and the way we present it, based on the results obtained examining users' browsing patterns and preferences.

What are cookies?

Cookies are small text files that are stored on the hard drive or in the memory of the computer that accesses or visits the pages of certain websites, to allow identify users' preferences on their next visit. Cookies stored on the user’s hard drive can neither read the data contained there, nor access personal information or read cookies created by other providers.

How many different types of cookies exist?

Based on who manages them:

First-party Cookies: generated by the page the user is visiting.

Third-party Cookies:generated by external provides or services such as Facebook, Twitter, Google, etc..

Based on the time they remain active:

Session Cookies: designed to collect and store data while the user accesses a web page.

Persistent Cookies: designed to keep storing data that can be accessed and processed for a period of time, which is set by the party that manages them.

Based on their purpose:

Technical Cookies: these are the simplest of all cookies; among other things, they can determine whether a human, a robot, a registered customer or an anonymous user is browsing the website. They also allow the website's basic functionalities to work correctly.

Preference Cookies: these are the cookies that allow users to access the service either with certain general default characteristics or based on the preferences they set themselves. For example, language, type of browser used to access the service, design of the selected content, device geolocalisation and regional preferences depending on the location from where users are accessing the website.

Analytic Cookies: these cookies collect browsing information, most visited sections, products viewed, browsing time, language, etc.

Advertising Cookies: allow to show advertising messages based on browsing data, country of origin, language, etc.

Behavioural advertising cookies:these are the cookies that allow the efficient management of advertising spaces included on the website pages or on the devices used to offer the service. These cookies store users' behavioural information and allow to create specific user profiles to show them advertising accordingly.

COOKIE DESCRIPTION CADUCIDAD ORIGIN
bsUI, bsCold, bsUId, bs_cc, bs_lvp Used to analyse the preferences of the user visiting the webpage Persistent BrainSins
PREF, NID, HSID, APISID, SID, SSID, SAPISID, GAPS, LSID, BEAT, ULS, SIDCC,1P_JAR, CONSENT, DV When creating or starting a session in a Google account, cookies are stored in your PC in order to remain connected to your Google account when you visit its service next time. While your session remains active and you use features on other websites like ours, Google uses these cookies to improve your user experience. 2 years Google
PREF, NID, SNID We use Google Maps to view geographic locations 6 months Google
_ga, _gid, _gat Used to analyse the preferences of the user visiting the webpage Persistent Google
landing_store_selected Used during browsing to store user preferences on the landing page 1 year Indiandcold
user_allowed_save_cookie Used to know if the user has accepted the use of cookies 1 year Indiandcold
frontend Used as unique identifier to keep the user in session during browsing 1 hour Indiandcold
sld Session cookie 1 year Indiandcold
external_no_cache Platform cookie for internal use 1 hour Indiandcold
store Language selection cookie 1 year Indiandcold
wfivefivec Collects user browsing data. This information is used for targeted advertising 1 year w55c.net
_AVESTA_ENVIRONMENT Allows to offer the newsletter service The session MailChimp
fr Facebook monitoring cookie Facebook
IDE, DSID, id, drt, _sonar, FLC Used to collect data for targeted advertising Doubleclick

How are cookies deactivated?

How users deactivate cookies depends on the browser, or browsers, they use. All browsers allow to change settings related to the use of cookies. Here we show the steps to follow to change cookie settings in the most popular browsers, however steps may vary depending on the version of the browser used:

- Firefox: http://support.mozilla.org/es/kb/habilitar-y-deshabilitar-cookies-que-los-sitios-we

To access your cookie settings in Firefox, follow these steps (steps may vary depending on the version of your browser):

1. Go to Options or Preferences depending on your operating system.

2. Click on Privacy.

3. In History choose Use custom settings for browsing history.

4. You will see the option Accept cookies, you may choose to activate or deactivate the option.

- Internet Explorer: http://windows.microsoft.com/es-es/windows-vista/Block-or-allow-cookies

To access your cookie settings in Internet Explorer, follow these steps (steps may vary depending on the version of your browser):

1. Go to Tools, Internet Options

2. Click on Privacy.

3. Adjust the slider to the level of privacy required.

- Chrome:https://support.google.com/chrome/answer/95647?hl=es

To access your cookie settings in Chrome, follow these steps (steps may vary depending on the version of your browser):

1. Go to Settings or Preferences from the Archive menu or by clicking on the customise icon in the top right corner.

2. You will see a number of sections, click on Show advanced options.

3. Go to Privacy, Content Settings.

4. Select See all cookies and site data.

5. You will see a list of all cookies ordered by domain. To find cookies from a specific domain, use the search feature and enter the full or partial URL in the Search cookies field.

6. Using this feature, you will obtain a list of all cookies used by the website you searched. Now all you have to do is click on the delete icon next to the cookies you wish to remove.

- Safari:http://support.apple.com/kb/HT1677?viewlocale=es_ES

To access your cookie settings in Safari for OSX, follow these steps (steps may vary depending on the version of your browser):

1. Go to Preferences, then Privacy.

2. In this section you will see the Block cookies option, where you can select the type of blocking option you prefer.

To access your cookie settings in Safari for iOS, follow these steps (steps may vary depending on the version of your browser):

1. Go to Settings, then Safari.

2. Go to Privacy and Security, you will see the Block cookies option, where you can select the type of blocking option you prefer.

- Apple: https://www.apple.com/legal/privacy/es/cookies/

- Android:

Link to Google privacy policy: http://www.google.es/intl/es/policies/privacy/

Link to Android help: https://support.google.com/android/?hl=en

To access your cookie settings on Android devices, follow these steps (steps may vary depending on the version of your browser):

1. Open your browser and click on Menu, then Settings.

2. Go to Security and Privacy, you will see the option Accept Cookies where you can activate or deactivate cookies.

- Windows Phone:http://www.windowsphone.com/es-ES/how-to/wp7/web/changing-privacy-and-other-browser-settings

To access your cookie settings on Windows Phone devices, follow these steps (steps may vary depending on the version of your browser):

1. Open Internet Explorer, then More, then Settings

2. Now you will be able to activate or deactivate the Allow Cookies tick box.

-BlackBerry: http://docs.blackberry.com/en/smartphone_users/deliverables/18578/Turn_off_cookies_in_the_browser_60_1072866_11.jsp

What are the consequences of deactivating cookies?

When you block cookies, or deactivate cookies you had previously activated, some functionalities of the website may be affected.

Also, we will not be able to collect browsing information on our website, which will prevent us, or make it more difficult for us to improve the information and the content we publish and the way we present it.

Cookies on social media on which INDI & COLD has a profile

Users are informed that social media on which INDI & COLD has a profile use cookies that are not controlled by us. Below we provide information on the cookie policy adopted by each social media network, which we recommend you read before accepting this cookie policy.

- Facebook and Instagram: https://www.facebook.com/policies/cookies/

Changes or updates to our cookie policy

The structure and functionalities of this website may change as we add new features, services and content. This may lead to changes in the use we make of cookies and to our cookie policy. Therefore, we recommend that users check our policy every time they access our website, to see if any changes have been made since their last visit.

Google Analytics

This web page uses Google Analytics, a web site analysis service provided by Google, Inc., a Delaware company with main offices at 1600 Amphitheatre Parkway, Mountain View (California), CA 94043, USA (“Google”). Google Analytics uses cookies, small text files stored on your computer, to help the website analyse how users interact with it. The information that generates the cookie about your use of the website (including your IP address) is transmitted directly to Google and stored on their servers in the United States. Google uses this information on our behalf in order to track your use of the website, compiling reports on activity on the website and providing other services related to website activity and Internet use. Google may transmit this information to third parties when required to do so by law or when said third parties process the information on Google’s behalf. Google will not associate your IP address with any other data they may have.

You can refuse to allow processing of the data or information by disabling the use of cookies via the appropriate configuration options of your browser. However, you should be aware that in this case you may not have full access to the functions of our website. By using this website, you consent to Google processing information about you in the manner and for the purposes indicated above.

Text dated: 1 May 2018.

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