Privacy Policy

1. WHO ARE WE? We are ZNR DISTRIBUTION SPRL and we process your personal data as the Data Controller. This means that we are responsible for the processing and protection of your personal data.
2. WHY DO WE USE YOUR PERSONAL DATA? Among other purposes, we will use your data (obtained online or physically) to manage your registration as a user, manage the purchase of products or services, answer your questions, and send you personalized communications, if you wish.
3. WHAT IS THE BASIS FOR PROCESSING YOUR PERSONAL DATA? We are authorized to process your data for various reasons. The most important reason is that it is necessary to execute the contract you have entered into with us when you registered and by making a purchase or by using one of our services or features, although there are other reasons that authorize us to do so, such as
the interest in responding to your questions or the consent given to send you our newsletters, among others.
4. WITH WHOM DO WE SHARE YOUR DATA? We may share your data with service providers who assist us or provide the necessary support, such as external collaborators with whom we have entered into an agreement, whether they are located within or outside the European Union.
5. YOUR RIGHTS. You have the right to access, rectify, and delete your personal data. In some cases, you also have other rights, such as the right to object to the processing of your data or the right to data portability, a more detailed description of which will be provided below.
We invite you to read our Privacy and Cookie Policy in its entirety to fully understand how we will use your personal data and your rights regarding it.

BEFORE YOU START…
• In this Privacy and Cookie Policy, you will find all relevant information applied to our use of our customers' and users' personal data, regardless of the channel or means you use to interact with us.
• We are transparent about what we do with your data, to allow you to understand the implications of the processing implemented or your rights regarding your data:
o All information is made available to you permanently in this Privacy and Cookie Policy, which you can consult at your discretion and, in addition,
o Information regarding each processing of your personal data will also be provided to you as you interact with us.
• Regarding some terms we will use in this Privacy and Cookie Policy:
o When we talk about our Platform, it generally refers to any of the digital or physical channels or means you have used to interact with us, the main ones being:
 Our website, www.bluewellford.com.

1. WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?
The data controllers for your personal data are:

2. WHY DO WE USE YOUR PERSONAL DATA?
We will process some of your data based on the products, services, or features you wish to use at any given time. In general, these will be:
 your identification data (e.g., your first name, last name, the language and country from which you interact with us, contact details, etc.);
 economic and payment information (e.g., your payment or credit card data, information about your purchases, orders, returns, etc.);
 connection, geolocation, and browsing data (if you interact with us from your mobile phone, for example);
 commercial information (e.g., if you are subscribed to our newsletter),

 data about your tastes and preferences.

When we ask you to enter your personal data to allow your access to one of the Platform's features or services, please remember that some fields will be marked as mandatory, as this is data we need to provide the service in question or to allow you to access that feature. Thus, if you choose not to provide us with this data, it is possible that your user registration cannot be successfully completed or that you will not be able to enjoy these services or features.
Depending on how you interact with our Platform, your personal data will be processed for the following purposes:

PURPOSE Learn more
1. To manage your registration as a user of the Platform If you decide to register as a user of our Platform, we will need to process your data to identify you as a user and to allow you to access the different types of features, products, and services available to you as a registered user. You can delete your registered user account by contacting us via Customer Service.
2. For the implementation,
application, and execution of the purchase or This purpose includes the processing of your data, in particular, to:
 Contact you regarding updates or information communications concerning the
features, products, or services concluded, including sending quality surveys on the products or services provided.
 Manage the payment for the products you purchase, regardless of the payment method used. For example:
 If you choose to enable the feature to save your payment card data for future purchases, when purchasing one of our products through the website or app, we will need to process the indicated data for the activation and implementation of this feature. Consent for the activation of this feature allows your payment data to be automatically displayed during subsequent purchases so that you do not have to enter it in each new process. They will be considered valid and effective for subsequent purchases. You can modify or delete your payment cards at any time through the section corresponding to payment information, either on your registered user account on the website.
 Activate the necessary mechanisms to prevent potential fraud against yourself and against us during the purchase process. If we consider that the transaction may constitute an attempt at fraud, this processing may result in the transaction being blocked.
 Manage potential returns after purchase and manage requests for information on item availability, product reservation via the Platform, or provide you with services related to the Personal Tailoring feature, depending on the availability of these options at any given time.
 For invoicing purposes and to provide you with receipts and invoices for purchases made on the Platform.
 Guarantee you the use of other available features or services, such as the purchase, management, and use of the Gift Card or Gift Voucher, as well as to facilitate your access and use of the Wi-Fi made available to our customers in physical Stores.

services concluded with us on the Platform
3. To respond to requests or queries made through Customer Service channels We only process personal data strictly necessary to manage or resolve your query or request.
4. For marketing purposes This purpose includes the processing of your data, subject to your consent, in particular for:
 If you are subscribed to our Newsletter, we will process your personal data to manage your subscription, including sending targeted information about our products or services through various means (such as email or SMS). Similarly, we may send you this information through push notifications if these have been activated on your mobile device.
 We therefore wish to draw your attention to the fact that this data processing involves analyzing your user or customer profile to determine your preferences and therefore which products or services are most appropriate for your style to send you information. For example, based on your purchase and browsing history (i.e., based on the items you have clicked on), we will suggest products that we believe may interest you and, if you are a registered user, we will provide you with the "cart recovery" feature. Please read our cookie policy for more information.
 Please remember that you can unsubscribe from the Newsletter at any time and free of charge through the "Newsletter" section of the Platform, as well as through the instructions provided in each communication. If you no longer wish to receive push notifications, you can deactivate this option on your mobile device.
 Implementation of promotional actions (for example, for conducting contests or sending your saved item list to the email address you provide). By participating in a promotional action, you authorize us to process the data provided according to each promotional action and to be able to communicate it through various means such as social networks or the Platform itself. The legal bases for each promotional action in which you participate will be available to you, with more detailed information on the processing of your data.
 Disseminate on the Platform, or through our social network channels, photos or images that you have
publicly shared, if you give us your consent to do so.
5. Ergonomics and quality analysis for improving our services When you access our Platform, you are informed that we will process your browsing data for analysis and statistical purposes, i.e., to understand how users interact with our Platform, in order to introduce improvements to it. Please read our cookie policy for more information.
Similarly, we sometimes carry out actions and quality surveys designed to ascertain the degree of satisfaction of our customers and users and to detect areas in which to improve our performance.

3. WHAT IS THE BASIS FOR PROCESSING YOUR PERSONAL DATA?
The legal basis that allows us to process your personal data depends on the purpose for which it is processed, as explained in the following table:

Purpose Basis
1. Managing your registration as a user of the Platform The processing of your data is necessary for the performance of the terms governing the use of the Platform. In other words, the processing of your personal data is necessary to register you as a user of the Platform; otherwise, this registration could not be managed.
2. Implementation, application, and execution of the purchase or services contract The processing of your personal data is necessary for the performance of the purchase or service contract to which we are bound.
The activation of certain data processing associated with the purchase process can only take place if you request it or if you expressly authorize us, as in the case of the retention of payment data (card) for future purchases or the processing of data necessary to scan purchase receipts through the Wallet section of the app or to inform you of the availability of our products. In
these cases, the legal basis on which we process
your personal data is your own
consent.

We consider that we have a legitimate interest in carrying out the necessary checks to detect and prevent potential fraud when you make a purchase. We believe that the processing of this data is in the interest of all parties involved in the payment of a purchase and, more specifically for you, since we can thus take preventive measures to protect you against fraud attempts by third parties.
3. Customer Service We consider that we have a legitimate interest in responding to your queries or requests made through the various existing contact methods. We believe that the processing of this data is also in your interest, as it allows us to properly manage your requests and answer your questions.
When you contact us, in particular for managing incidents concerning your order or the product/service purchased on the Platform, the processing is necessary for the performance of the purchase contract.
When your question concerns the exercise of the rights about which we inform you below, or claims regarding our products or services, the processing of your data is based on compliance with our legal obligations.
4. Marketing The legitimate basis for processing your data for marketing purposes is the consent you give us, for example by agreeing to receive personalized information through various means, when you authorize the sending of push notifications on your mobile device, or when you accept the legal conditions for participating in a promotional action or for publishing your photos on the Platform or our social media channels.
In order to show you personalized information, we consider that we have a legitimate interest in carrying out profiling with
the information we have about you (the
sites you visit, your preferences, or your purchase history) and the personal data you have provided us with, such as age group or language, since we consider that the processing of this data is also in your interest as it allows you to improve your user experience and access information that matches your preferences.
5. Ergonomics and quality analysis We consider that we have a legitimate interest in analyzing the ergonomics of the Platform and the degree of user satisfaction, as we believe that the processing of this data is also in your interest, as its purpose is to improve the user experience and offer a better quality service.

4. HOW LONG WILL YOUR DATA BE RETAINED?
The retention period of your data depends on the purposes for which it is processed, as explained below:

Purpose Retention period
1. Managing your registration as a user of the Platform Your data will be processed as long as you maintain your status as a registered user (i.e., until you decide to delete your user account).
2. The implementation, application, and execution of the purchase or service contract We will process your data for the time necessary to manage the purchase of the products or services you have purchased, including any possible returns, complaints, or claims associated with the purchase of the specific product or service.
In some cases, we will only process the data until you have decided, as in the case of payment data (card) that you have asked us to keep for possible future purchases.

3. Customer Service We will process your data for the time necessary to respond to your query or request.
4. Marketing We will process your personal data until you unsubscribe or cancel your newsletter subscription.
If you participate in promotional actions, we will keep your personal data for 6 months from the end of the action.
5. Ergonomics and quality analysis We will occasionally process your data for the duration of a specific quality action or survey or until your browsing data is pseudonymized.

Regardless of the processing of your personal data for the strictly necessary period to fulfill the corresponding purpose as indicated above, it will then be stored, properly safeguarded and protected with restricted access for the period during which liability could be incurred following the processing, in execution of the regulations in force at all times. Personal data will be deleted once any possible actions in each case have expired.

5. WILL YOUR DATA BE SHARED WITH THIRD PARTIES?
In order to fulfill the purposes indicated in this Privacy and Cookie Policy, access to your personal data must be allowed to ZNR DISTRIBUTION company entities and to third parties we use to offer you certain services, i.e.:
 financial institutions,

 fraud detection and prevention entities,

 technology service providers,

 logistics, transport, and delivery service providers and collaborators,

 customer service providers,

 marketing and advertising service providers and collaborators.

For service efficiency reasons, some of these providers are located outside the European Economic Area, where the level of personal data protection is not comparable to that of the European Union, particularly in the case of the United States. In these cases, we wish to inform you that the transfer of your data will be carried out with appropriate safeguards and always maintaining the security of your data:

6. WHAT ARE YOUR RIGHTS WHEN YOU PROVIDE US WITH YOUR DATA?
We are committed to respecting the confidentiality of your personal data and to guaranteeing the exercise of your rights. As the Data Controller, we have agreed that these rights can be exercised at no cost by sending an email to a single email address contact@bluewellford.com, simply indicating the reason for your request and the right you wish to exercise. If we deem it necessary to identify you, we may request a copy of an identity document.
Regardless of the purpose or legal basis under which we process your data, you are particularly entitled to:
• Ask us for access to the data we hold about you. We remind you that if you are a registered user of the Platform, this information can also be consulted in the section corresponding to your personal data.
• Ask us to rectify the data we already hold. We remind you that if you are a registered user of the Platform, you can also access the section corresponding to your personal data in your account to modify or update your personal data. However, please remember that by actively providing us with your personal data through any means, you ensure that it is true and accurate and that you undertake to inform us of any change or modification to it. Any damage or loss caused to the Platform or the platform controller or any other third party due to the communication of erroneous, inaccurate or incomplete information in the registration forms, is the sole responsibility of the user. Please do not forget that, as a general rule, you should only provide your own personal data and not that of third parties, except as permitted in this Privacy and Cookie Policy.
• Ask us to delete your data to the extent that it is no longer necessary for the purpose for which we may have needed to process it, as already indicated above, or for which we are no longer competent to do so.
• Ask us to limit the processing of your data, which implies that, in certain cases, you can ask us to temporarily suspend the processing of data or to keep it beyond the necessary time if you need it.
If you have given us your consent for the processing of your data for any purpose, you also have the right to withdraw it at any time. Some ways to withdraw your

consent are explained in paragraph 2, where we explain the purposes of processing your data.
As explained in paragraph 3, when the processing of your data is based on your consent or the performance of the 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 have provided to us in a structured, commonly used, and machine-readable format, in order to be able to transmit it directly to another entity, provided that this is technically possible.
Furthermore, if 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 of your right to lodge a complaint with the corresponding data protection supervisory authority.

7. WHAT HAPPENS IF YOU PROVIDE US WITH THIRD-PARTY DATA?

We offer certain functionalities or services that require the processing of personal data of a third party that you have provided to us, such as in the case of activating and sending a Gift Card or managing a Gift Ticket request. If you provide Personal Data relating to third parties, you assure us that they have been informed about the purposes and the way in which we need to process their personal data.

8. CHANGES TO THE PRIVACY AND COOKIE POLICY
The information contained in this Privacy and Cookie Policy may be modified if we deem it appropriate. In such a case, you will be notified through various channels on the Platform (e.g., a banner, a pop-up window, or a push notification), or even communicated to your email address if the change in question is particularly important for your privacy, so that you can review the changes, evaluate them and, if necessary, object or withdraw from a service or functionality. In any case, we suggest you review this Privacy and Cookie Policy from time to time, in order to be aware of minor changes or the introduction of an interactive improvement, taking advantage of the fact that it will always constitute a permanent reference for information on our site and our app.

9. INFORMATION ON COOKIES

We use cookies and similar devices, subject to your consent, to facilitate your navigation on the Platform, to understand how you interact with us and, in some cases, to offer you advertisements adapted to your browsing habits. Please read our Cookie Policy to learn more in detail about the cookies and similar devices we use, their purpose and other relevant information.

Information about Cookies

What is a cookie?
A cookie is a small text file that a website installs on your PC, phone, or any other device, and that contains information related to your navigation on that website. Cookies are necessary to facilitate navigation and make it more user-friendly, and they do not damage your computer.

Although, in this policy, the general term cookies is used as it is the method of storing information that this website uses, the browser's "local storage" space is used for the same purposes as cookies. In this regard, all the information included in this section also applies to this "local storage."

For what purposes are cookies used on this website?
Cookies play an essential role in how our website works. Their main objective is to improve your experience on the site. For example, cookies allow us to remember your preferences (language, country, etc.) during navigation and on future visits.
The information stored in cookies also allows us to improve the website through estimates of the number and modes of use, adapting it to user interests, optimizing search speed, etc.
Occasionally, if we have obtained your informed consent in advance, we may use Cookies, tags or other devices to obtain information, which allows us to show you, either from our own website or from third-party websites or any other means, advertisements based on the analysis of your internet search habits.

For what purposes are cookies NOT used on this website?
We do not store sensitive personal data such as your address, password, credit card details, etc., in the cookies we use.

Who uses the information stored in cookies?
The information stored in the cookies on our website is processed exclusively by us, except for those identified below as "third-party cookies," which are used and managed by external entities to provide the services we request, with the aim of improving our services and the user experience when browsing our website. The main services for which these
"third-party cookies" are used consist of obtaining website access statistics and also ensuring the proper execution of payment transactions.

How to avoid the use of cookies on this website?
If you prefer to avoid the use of cookies on this page, taking into account the limitations mentioned above, you will first need to disable the use of cookies in your browser and then delete the cookies associated with this website that are stored in your browser.
You can use this option to prevent the use of cookies at any time.
How to disable and prevent the use of cookies?
You can restrict, block, or delete cookies from this website at any time by modifying your browser settings, following the steps outlined above. Although the settings vary depending on the browser, cookie configuration is generally done from the "Preferences" or "Tools" menu. For more information on configuring cookies in your browser, consult its "Help" menu.

What cookies does this website use and for what purpose?

The table below indicates the cookies, tags and other devices used by this website, together with information relating to the purpose, duration and management (by the owner and by third parties) for each type of cookie.