Shoes and Trends Privacy Notice

(Last update December, 11 2023)

1....... Introduction and Purpose. 1

2....... What data do we collect?. 1

3....... How do we collect your data?. 4

4....... How do we use your data?. 4

5....... With whom do we share your data?. 4

6....... How do we store and how long do we retain your data?. 5

7....... What are your data protection rights?. 6

8....... Cookies and website data. 7

1.Introduction and Purpose

This Privacy Policy ("Policy") informs you which personal data is collected and processed by SHOES & TRENDS INTERNATIONAL S.R.L (hereinafter referred to as "Shoes & Trends", “we” or “our”) in the context of our business activities including the provision of our website shoes-trends.net (“Website”) in accordance with Regulation (EU) 2016/679 - General Data Protection Regulation ("GDPR") and applicable national data protection laws. Unless otherwise defined in this Policy, terms and definitions used herein shall have the same meaning as defined in GDPR. This Policy provides all information required by Art 13 and 14 GDPR.

Unless otherwise stated in this Policy, controller of the data processing in accordance with Art 4 (7) GDPR is SHOES & TRENDS INTERNATIONAL S.R.L, Str. Iustin Marsieu nr.6, Arad 310150, Romania. For data privacy related questions, requests or complaints, please contact:

SHOES & TRENDS INTERNATIONAL S.R.L

Attn.: Data Privacy

Mail: Str. Iustin Marsieu Nr.6, Arad 310150, Romania

Email: info@shoes-trends.net

We keep this Policy under regular review and may update this Policy from time to time by updating this site.

Disclaimer – Privacy policies of other websites

Please note, our Website contains links to other websites. However, our Policy only applies to our Website and not to any third-party. We have no control over the content or privacy practices of these other websites. Please read the respective data protection provisions of other websites that you visit.

2. What data do we collect?

Shoes & Trends collects the following personal information about its business partners:

·Contact information: This information is generally limited to the kinds of information that can be found on a business card: first name, last name, job title, employer name, work address, work email, and work phone number, website.

·Correspondence between you and Shoes & Trends: In the regular course of our business relationship with you (or your company/employer) we collect certain personal data which you provide to us such as business correspondence. These personal data may include your name, date and place of birth, gender, address (domicile/residence), position, e-mail, phone number, employer and power to represent, data on contract performance as well as any other information that you disclose to us.

·Online identifiers such as IP addresses

·Any other information necessary to fulfill a contract or pre-contractual endeavors between you and Shoes & Trends or your employer and Shoes & Trends such as payment information, tax numbers and information, company registration numbers.

The purposes and legal basis we may process your data for:

·Initiation, negotiation and performance of the business relationship: Art 6(1) b and f GDPR – performance of contract, where you are a party of the contract and legitimate interest in fulfilling our contractual obligations in case of a contractual relationship between your company/employer and Shoes & Trends;

·Business communications with you (replying to messages, complaints, requests, etc.) and relationship management: Art 6(1) b and f GDPR – performance of contract and legitimate interest in effective business administration and development;

·Internal accounting and finance: Art 6(1) c and f GDPR – legal obligation and legitimate interest in adequate internal business practices;

·Compliance with legal obligations (e.g. reporting and retention obligations pursuant to tax and company law): Art 6(1) c GDPR – legal obligation;

·Investigations and preventing of fraud or other illegal activities: Art 6(1) c and f GDPR – legal obligation, where such processing is legally required, and legitimate interest in protecting our rights or property;

·Verify your identity and accuracy of data: Art 6(1) b and c GDPR - performance of contract and legal obligation, e.g. when you exercise your privacy rights;

·Where necessary, establishment, exercise or defense of legal claims: Art 6(1) f GDPR, Art 9(2) f GDPR.

Where we ask for your permission to process your personal data, we will use your personal data only to the extent you have consented (Art 6(1) a GDPR). You may withdraw your consent at any time with effect for the future at info@shoes-trends.net.

Your correspondence with Shoes & Trends

If you correspond with us by email, the web form, the postal service, or other form of communication, we retain such correspondence and the information contained in it and use it to respond to your inquiry and to keep a record of it. If you ask Shoes & Trends not to contact you by email at a certain email address, Shoes & Trends will retain a copy of that email address in order to comply with your no-contact request.

Legal basis: legitimate interest (Article 6(1)(f) GDPR)

Payment and purchase information

You may choose to purchase goods or services from Shoes & Trends. Typically, payment and shipping information is provided directly by our customers. We collect shipping and billing information to fulfill customer orders. Shoes & Trends therefore relies on contract fulfillment and legitimate interest basis for processing this personal data.

Legal basis: contract fulfilment obligations and legitimate interest (Article 6(1) (b) and (f) GDPR)

Personal data you actively disclose to us

When you actively communicate with us via our Website’s contact form, we process those personal data that you voluntarily provide to us (e.g. name, email address, correspondence). We process this data for the purpose of answering your questions, fulfilling your requests or otherwise communicating with you.

Legal basis: Art 6(1) b GDPR – performance of (pre-)contractual duties.

Social Media

Regarding the operation of the individual social media channels we may act as joint controllers together with the respective operator of the platform where this operator is not acting as sole controller. However, we do not have full access to the data processing by the platform operator. Therefore, we recommend reading our privacy policy together with the privacy policy of each platform to get a comprehensive overview.

For the operation of our social media channels we may process your personal data, e.g. your name, your profile information, your contacts information) and interaction data, e.g. if you communicate with us via our social media channels through posts, comments, personal messages or contact forms.

When interacting with our social media channels we may have access to your publicly visible data (e.g. name and profile picture when you make a public comment on our page). Please review your profile settings to check which data is publicly available and to change which data can be shared by the platform. For more information please read the privacy policies of the respective social media platform.

In addition, we may receive anonymous statistics from the social media operators about the use and popularity of our social media pages. The following information are processed:

·Total number of followers (i.e. person following our channel);

·Reach: number of people who see a specific post; number of interactions with a specific post; this enables us to review which topics are of great interest to our community;

·Demographic data of users: age, gender, place of residence, language;

·Ad performance: How many people were reached by a post? How many people have interacted with it?

Legal basis for social media: Art 6(1) a GDPR – consent given via social media platform.

What happens if you don’t give us your data?

You can enjoy browsing our website. Some personal information is necessary so that Shoes & Trends can get in contact with you and provide you with the services you have purchased or requested. For example, we need some of the above-mentioned personal data for the performance of the contract with you (or your company/employer) or in order to comply with legal obligations we are subject to. If you refuse to provide personal data which are required for the performance of the contract or which we are obliged to process due to legal obligations, it may not be possible for us to carry out the business relationship and/or, more specifically, the purposes listed above (for example transfer payments, if you don’t provide your bank details).

Special categories of personal data ("sensitive data")

Shoes & Trends does not collect or use any sensitive personal data and does not want you to provide us with such. Sensitive data are personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership as well as genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

3. How do we collect your data?

Most business partners provide their personal information directly to us. In some cases, Shoes & Trends receives personal information about individuals from third parties. This may happen, for example, if your employer or another business partner is providing us with your information to get in contact with you upon your request or to fulfill our (pre-) contractual obligations. We may also collect your personal data from a third-party website (e.g. your company’s website or social media site) for direct contact purposes only. However, we may occasionally also receive personal details, business related information and correspondence data about you from other sources such as from your company/employer, public registers (such as company, association or land registers), published information on websites and from the media, or where data about you is forwarded to us by our business partners.

In most cases, you directly provide Shoes & Trends with the data we collect. We collect data and process data when you:

·Get in contact with us via the Website’s contact form or if you contact us directly via email or phone

·Use or view our Website via your browser’s cookies

Shoes & Trends may also receive your personal data indirectly from the following sources:

·Our business partners in the context of contract fulfillment or pre-contractual endeavors, which may or may not be your employer

·From social media sites such as LinkedIn if you share your information publicly or in case of mutual connections

4. How do we use your data?

Shoes & Trends collects your data so that we can:

·Process your or your employers order in order to fulfil contractual obligations

·Get in contact with you

We use this information to provide you with goods and services you order from us. We do not sell personal information to anyone and only share it with third parties who are facilitating the delivery of our services such as our data processors. We do not intent to have any direct business with consumers or minors.

5. With whom do we share your data?

We may share your personal data with the following recipients:

·IT service providers (data processers) for hosting, maintenance and security services for our Website and IT infrastructure

·Competent governmental authority, such as supervisory, safety, trade or tax authorities, courts of law or other third parties who advise us in this context (e.g. lawyers or forensics experts) where disclosure is required (i) by law or regulation or (ii) to exercise, protect or defend our legal rights

·Insurances, banks and payment service providers where disclosure is required (i) by law or regulation or (ii) to fulfil our contractual obligation or (iii) based on our legitimate interest

·External business consultants and service providers such as tax advisors, public accountants, auditors, translators (i) if necessary for fulfilling a contractual obligation or (ii) based on our legitimate business interest

We do not otherwise reveal your personal data to persons or businesses for their independent use unless:

·you request or authorize it;

·it is to assist your employer with confirming receipt or consumption of a purchase they made on your behalf;

·the information is provided to comply with the law (including but not limited to comply with a search warrant, subpoena, or court order, tax purposes, anti-laundry and fraud regulations), enforce an agreement we have with you or your company/employer, or to protect our rights, property or safety, or the rights, property or safety of our employees or others;

·the information is provided to our agents, vendors or service providers who perform functions on our behalf and act as data processors;

·to address emergencies or acts of God; or

·to address disputes, claims, or to persons demonstrating legal authority to act on your behalf.

Some of these recipients may be located in countries outside the EU/EEA for which an adequate level of data protection has not been established by the EU Commission. It should be noted that the level of data protection in such countries may not be the same as within the EU/EEA. However, where personal data is transferred to such third countries, we implement appropriate safeguards to ensure that your rights are protected in accordance with the GDPR. In particular, this includes the execution of Standard Contractual Clauses (Art 46(2) c GDPR) as amended by the Decision of the EU Commission (EU) 2021/914 or we may obtain your explicit consent according to Art 49 (1) a GDPR. Further details on the implemented safeguards as well as copies of the concluded Standard Contractual Clauses are available on request.

6. How do we store and how long do we retain your data?

The personal information Shoes & Trends collects from you is stored in one or more databases hosted either directly by Shoes & Trends or by a third-party cloud hosting provider stored in the European Union. These third parties do not use or have access to your personal information for any purpose other than cloud storage and retrieval.

Unless specified otherwise, we generally retain your personal data for as long as it is necessary for the fulfilment of the purpose for which they were obtained, in particular, for the duration of our contractual or service relationship with you or your company/employer. Thereafter, we may keep your personal data to comply with our legal retention obligations (e.g. under tax or company laws), for archiving and backup purposes and as long as potential legal claims against us are not yet time barred. As soon as there are no legitimate grounds for any further storage of personal data, we will either securely delete or anonymize data.

7. What are your data protection rights?

You are entitled to the following rights:

·The right to access – you have the right to request a copy of the personal data we process about you.

·The right to rectification – you have the right to request a correction or a completion of any of your information you believe is inaccurate or incomplete.

·The right to erasure – you have the right to request an erasure of your personal data under certain circumstances.

·The right to restrict processing – you have the right to restrict processing of your personal data under certain circumstances.

·The right to object to processing – you have the right to object to processing of your personal data under certain circumstances.

·The right to withdraw your consent – you have the right to withdraw your consent at any time in case we solely process your personal data on the basis of your consent.

·The right to data portability – you have the right to request a transfer of your personal data that we have collected to another organization, or directly to you under certain circumstances.

·The right to lodge a complaint – you have the right to lodge a complaint with your competent supervisory authority in case you believe we infringed any of your rights or our data privacy obligations. Shoes & Trends supervisory authority is The National Supervisory Authority For Personal Data Processing / Autoritatea Naţională de Supraveghere a Prelucrării Datelor cu Caracter Personal, available at www.dataprotection.ro/

Please note, we do not process your personal data for the purpose of taking decisions based solely on automated processing, including profiling, which produces legal effects concerning you (Art 22 GDPR).

To exercise any of the above rights kindly send an email to info@shoes-trends.net.

8. Cookies and website data

What are cookies?

Cookies are small text files that may be placed on your device while browsing our Website and store certain information about you. They are generally used to make websites work better and more efficient, e.g. they can recognize you and remember important information that will make your visit of a website or cloud-based service more convenient (e.g., by allowing you to enter a password less frequently or remembering user preferences). For further information about cookies, you can visit allaboutcookies.org/ for more detailed information.

How do we use cookies?

As is true of most other websites, when you visit or use our website www.shoes-trends.net (our "Website") we collect information from you automatically through cookies or similar technology by using cookies to maintain and manage our Website. The cookies which are placed on our Website may be categorized as essential cookies and have been placed by Wix, which is our website creation platform.

Without essential cookies, the proper functioning of our Website would not be possible or only to a limited extent. The use of necessary cookies on our Website is possible without your consent. However, you can deactivate cookies at any time by modifying your browser settings. For more information which essential cookies have been placed, please visit: support.wix.com/en/article/cookies-and-your-wix-site.

Legal basis: Art 6(1) f GDPR – legitimate interest in maintaining functionality, stability and security of our Website.

Shoes & Trends has not placed any additional or non-essential cookies. In addition, we do not operate applications or services on our Website that request you to actively communicate with us. However, we will process your data if you voluntarily decide to contact us using the contact details of Shoes & Trends or the contact form provided on our Website.

How to manage cookies?

You can set your browser not to accept cookies. You can visit allaboutcookies.org/ to learn how to remove cookies from your browser. However, this may lead to cases where some of our Website features may not function as a result. Additionally, the following links explain how to access cookie settings in various browsers: