PRIVACY POLICY

CONTROLLER: GALMA SKINCARE, S.L., owner of the website www.twopoles.co (hereinafter the “Provider”), with tax number CIF B02975720, registered address in Badalona, Spain and email address: hello@twopoles.co.

DATA REQUESTED ON THE WEBSITE, FORMS AND PURPOSE OF PROCESSING:

• Contact form: information needed to respond and to make any direct contact;
• Purchase form: where the goods and/or services offered through the Website are contracted, information needed to maintain the contractual relationship, as well as to manage, administer, inform, provide and improve the service offered;
• Subscription form: information needed to send newsletters (newsletters), as well as commercial communications about promotions and/or advertising for the website.
• Login form: information needed to access the customer area, based on the data provided when creating the account.

Failure to provide the personal data requested or to accept this data protection policy means it is not possible to subscribe, register or receive information about the Provider's products and services. The User is solely responsible for the truthfulness and accuracy of the data sent to the Provider, releasing the Provider from any liability in this regard.

The Provider has no way of effectively verifying users' age, so it is understood that anyone under 16 has their parents' authorisation, and the Provider is released from any liability in this regard.

TRANSFER OF DATA TO THIRD PARTIES

The Provider states that it will not transfer personal data to third parties, except where legally required, with the exception of the credit institutions the Provider works with when processing payment for purchases made by the User. By accepting the sales terms of this website, the User accepts that transfer. This acceptance extends to third-party entities that need to access the User's data in order for the contracted service to be properly delivered. The details of the companies to which TWO POLES will transfer data are given below:

• KLARNA BANK AB (publ), registered in the Swedish Companies Register under company number 556737-0431 and with registered office at Sveavägen 46, 111 34 Stockholm: company used for instalment payments. The privacy policy and other legal information for this company can be found at the following link.

“In order to offer you Klarna's payment methods at checkout, we may pass on to Klarna during the purchase process your personal data included in the contact form and the order details, so that Klarna can assess whether you meet the requirements for its payment methods and tailor those payment methods to your profile. Your personal data is processed in accordance with Klarna's privacy policy.”

• SHOPIFY PAYMENTS, SHOPIFY (Shopify Inc., with registered address at 150 Elgin St., 8th Floor, Ottawa, ON K2P 1L4, Canada), which provides web hosting services. The privacy policy and other legal information for this company can be consulted at the following link: https://www.shopify.com/legal/privacy

• PAYPAL (Europe) S.à r.l. et Cie, S.C.A.: company used to process credit card payments on the website. Located at 22-24 Boulevard Royal L-2449, Luxembourg. The privacy policy and other legal information for this company can be found at the following link: https://www.paypal.com/es/webapps/mpp/ua/privacy-full?locale.x=es_ES

• CLEARPAY, S.A.U., with tax number C.I.F. A-85827335, registered address at Paseo de la Castellana 95, 28086 Madrid: company used for instalment payments. The privacy policy and other legal information for this company can be found at the following link.

 "Should you request to pay for your purchase in instalments, through financing with the entity CLEARPAY, S.A.U., provista de C.I.F. A-85827335, su domicilio en Paseo de la Castellana 95, 28086 de Madrid, we inform you that by accepting these sales terms you expressly consent to the transfer of your personal data to the financial entity indicated, for the sole purpose of facilitating and speeding up the process of arranging your financing with that entity."

DATA PROCESSORS

The data processors (or entities to which the User's data is transferred) involved at any stage of the processing are obliged to observe professional secrecy and to adopt the levels of protection and the technical and organisational measures within their reach that are necessary to guarantee the security of personal data. In compliance with the principles of information and transparency, these third parties are:

• SHOPIFY (Shopify Inc., with registered address at 150 Elgin St., 8th Floor, Ottawa, ON K2P 1L4, Canada), which provides web hosting services. The privacy policy and other legal information for this company can be consulted at the following link: https://www.shopify.com/legal/privacy

• KLAVIYO (Klaviyo, Inc.), with registered address at 225 Franklin St., Boston 02110, Massachusetts, USA, provides marketing campaign services. The privacy policy and other legal information for this company can be found at the following link: https://www.klaviyo.com/privacy

• Google LLC, with registered address at 1600 Amphitheatre Parkway, 94043, Mountain View (California), United States, which provides GSuite services, consisting of cloud computing and email services. The privacy policy and other legal information for this company can be found at the following link: https://www.google.com/intl/es/policies/privacy/

Google participates in and has certified its compliance with the framework of the agreement between the US and the European Union known as the Privacy Shield, having undertaken to apply the principles derived from the Privacy Shield to all personal information received from European Union member countries. Google's adherence to the Privacy Shield:  https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

RIGHTS OF THE DATA SUBJECT

The Provider guarantees the User the exercise of the rights of access, rectification, erasure, information and objection, restriction and portability, under the terms set out in current legislation. Accordingly, you may exercise your rights by sending an express request to the postal address given at the top and/or by sending an email to hello@twopoles.co, writing in the subject line: ARCO Rights, and attaching a photocopy of your ID document. The User also has the right to withdraw consent at any time. Withdrawing consent will not affect the lawfulness of the processing carried out before the withdrawal. You also have the right to lodge a complaint with the supervisory authority if you consider that your data protection rights may have been infringed, with the Spanish Data Protection Agency (AEPD), at calle Jorge Juan, 6, 28001 Madrid, or through the AEPD electronic office: https://sedeagpd.gob.es/sede-electronica-web/.

DURATION OF PROCESSING

The data provided by the User will be kept for as long as there is a mutual interest in maintaining the purpose of the processing and for the period during which legal liabilities may arise from the services provided.

The Provider reserves the right to amend this policy to adapt it to legislative or case-law developments.

For any matter relating to this privacy policy, the User can contact the Provider at the email address: hello@twopoles.co.

NEWSLETTER SUBSCRIPTION TERMS 

10% off when you redeem the coupon we will send you by email, to use on your first purchase, valid on all products on the website except gift cards and discounted products.

In compliance with the current legislation on the protection of personal data, Regulation (EU) 2016/679 of 27 April 2016 (GDPR), we inform you that the personal data we have processed (Galma Skincare, S.L.) in order to send this were provided by you at the time and are included in a database in my name. The data will be kept until either party states otherwise.. No transfer of data to third parties is envisaged except where legally required. We inform you that you have the right to withdraw your consent to the processing of your data at any time. You may also exercise your rights of access, rectification, erasure and portability of your data, and of restriction of or objection to processing, by sending an email to hello@twopoles.co. If you consider that the processing of personal data does not comply with current legislation, you have the right to lodge a complaint with the supervisory authority (www.agpd.es). You can consult additional, detailed information on Data Protection on the 'Privacy policy' page of our website."