CUSTOMERS DATABASE POLICY
Responsible for Treatment and Privacy Representative Managers
The person responsible for the processing of personal data is: MY WAY FOOTWEAR, S.L, whose registered office is at: “Parque Empresarial - Germán Bernácer, 65” (office 12) - 03203 Elche, Alicante, and with the telephone number 96 665 10 09.
Categories of data being processed and Purposes of the data processing
In general, the fact of visiting and consulting SLW Website does not entail the collection and processing of the user's personal data. The processing of the personal data of the user who visits the Website is limited to the so-called 'navigation data', that is, all the data that are necessarily transmitted to the Website by the computer systems responsible for its administration and the Internet's own communication protocols.
Navigation data includes, for example, the IP address or domain names of the customers’ computers that connect to the SLW Webpage, in addition to a series of parameters related to the type of operating system used by the user. Navigation data such as those mentioned above and, for example, the number or duration of visits to the Website of each individual, is collected and processed by SLW solely and exclusively for statistical purposes and anonymously, in addition to verifying the correct functioning of the Website and improving its operability and content.
Due to the own nature of the navigation data, this type of data may allow the identification of the user if they are associated with other data retained by third parties; however, SLW does not collect navigation data to associate with any identified users. Navigation data is deleted after the anonymous treatment of this data is completed. Such data may be used to debug responsibilities in the event of a cybercrime being committed against or through the Website. Except in the case indicated above, SLW retains the user's navigation data exclusively during the maximum period of time allowed by the applicable legislation before erasing it.
On the other hand, SLW carries out the collection and processing of personal data that the user voluntarily provides when interacting with the Website and when the user request the services offered there, for example, when subscribing to the Website , to our newsletter or mailing list; when purchasing products through the Website which includes all activities related to the purchase of products such as product delivery, billing, return and exchange of products, repayments, purchase and use of gift cards and electronic gift cards, and depending on the case, payment activities including fraud prevention, customer service and interaction with our call center; participating in promotions and other activities organized through the Website, such as competitions; when requesting information from SLW or sending questions, communications or opinions to SLW by traditional mail or through the Website.
We will handle the personal data of the user in order to comply with all the requirements established by the law, regulations and community legislation, and for the exercise of legal actions or procedural defense actions. We will be able to process the personal data of the user when he/she contacts our customer service and call center, which can communicate with the user and, therefore, carry out the processing of their personal data via email, chat and telephone.
The user may also finalize the purchase of our products by calling our call center, following the procedure specified in our Terms and Conditions. For the purposes of processing your personal data when making a purchase on our Website, consult the corresponding data protection policy.
The call center will help the user to finish the purchase by telephone and to process his order on his behalf and for this purpose; SLW will obtain the personal data and the data of the user's credit card. The call center will also record the telephone number of the user to call back and for back-office purposes in order to assist you and provide you with the information requested.
The described activities of marketing, statistics and creation of profiles can also be developed by our call center with the consent of the user. In some cases, and for the purpose of internal training, quality control and verification, calls may be recorded and e-mail messages may be stored unless prohibited by applicable law. The user will be informed before recording his communication and he/she may oppose such recording except when it is necessary to verify his purchase or for any other cause that contemplates the applicable legislation.
In addition, SLW may carry out the processing of the user's personal data with their consent, provided on an optional basis, for the purpose of preparing surveys and for marketing purposes. That is, to send the customer information and promotional material about the products and services of the SLW group, campaigns, promotions, special prices and events of the SLW group via e-mail or other electronic means of communication such as SMS, MMS, fax, etc.
Personal data of the user may also be shared with other companies of the SLW group for the development of marketing activities and creation of previously defined profiles. The user may oppose, at any time and free of charge, to the processing of their personal data for promotional material of the SLW group. Each communication will contain a specific section describing the procedure (easy to follow and free) to revoke this consent.
Personal data collected and processed by SLW include the name of the user and contact information such as address, telephone number, email address and other optional information provided by the user. The section of the Website on which the data collection takes place contain a declaration of informed consent. When required by the Data Protection Law, SLW will request the consent of the user before proceeding to process their personal data.
Personal data collected through the Website will be processed by SLW.
All the processing of personal data will be carried out exclusively by personnel specifically authorized and designated to access the data and carry out its treatment, including personnel designated to perform non-routine maintenance tasks on the Website.
Conditions and characteristics of the processing of personal data
The user's personal data will be processed in accordance with applicable data protection laws, which include security and confidentiality provisions, and will be kept only for the period of time strictly necessary to achieve the purposes pursued in each time and in accordance with applicable law.
For what purpose do we process your personal data?
On our website you will find different forms where personal data is collected:
- Product purchase form: billing, shipping and personal data are collected to process the purchase of items and delivery of commercial promotions.
- Account registration form: In this case, we request personal and shipping data to manage the registration of your account.
We inform you that the data you provide us will be located on the servers of “AXARNET COMUNICACIONES S.L.” (Slowwalk's hosting provider) within the EU.
In the event that you provide your data via email, the rest of the points indicated in the following paragraph will be applicable.
In MY WAY FOOTWEAR, S.L. we treat the information that interested persons provide us in order to manage the sending of the information requested by them, as well as to provide interested parties with offers of products and services that may be of interest to them. Likewise, we also treat the information provided to manage the relationship with our clients, as well as processing the contracting of a service or billing it. In order to offer them products and services in accordance with their interests, commercial profiles can be drawn up from the information provided.
Security and quality of personal data
SLW has made the commitment to ensure the security of the user's personal data. SLW carries out the processing of personal data in compliance with the security regulations established by the applicable laws in order to prevent the accidental loss or destruction of data, unauthorized access to data and illegal or improper use of the data. Computer systems and software programs are configured so that personal and identifying user data are used only when they are strictly necessary to achieve the specific purpose of the processing of the data pursued at the moment.
SLW uses advanced security technologies and procedures to help protect the user's personal data against any of the risks described above. For example, personal data provided by the user is stored on secure servers located in controlled locations. In addition, encryption techniques such as the Secure Socket Layer (SSL) protocol are used for the transmission of certain data over the Internet.
The user may help SLW to update and guarantee the accuracy of the personal data provided to SLW by notifying any change in address, treatment, telephone number or e-mail address. Registered users can carry out the aforementioned actions on-line following the instructions published on the user's profile page within the Website.
Scope of personal data communication
Who has access to your data?
The data you provide us with in order to send you our publications and promotions will be located on the servers of mDirector (email marketing provider) through its company “Marketing Manager Servicios de Marketing, S.L.U”, located in Spain. See
This Website uses Google Analytics service Google Analytics, this service uses "cookies" to collect information for analytical Web service and advertising service.
In order to achieve the purposes related to the management of the Website and the development of related activities (for example, for the purchase of products through the Website or by telephone through our call center) the user's personal data also may be communicated to other companies in the SLW group located in the European Economic Area which will process the personal data for the purposes specified above and in accordance with applicable laws, including marketing and profiling activities.
With regards to the purchase of products, the processing of the data will be carried out by the corresponding local SLW entity domiciled in the place where the delivery will take place. This entity will act as responsible for the processing of your personal data in accordance with applicable data protection laws, for the following purposes: billing, sending products, returning and exchanging of products, repayments, purchase and use of Electronic gift cards and gift cards, and in some cases, payment activities including fraud prevention.
Likewise, for the closing of operations and payment processing, we turn to third party service providers who are responsible for the management and support of the e-com platform. These providers are contractually obligated to take appropriate security measures to protect the security and confidentiality of personal data and credit card data of users.
Third parties who receive personal data of the user in the terms specified above, will carry out the treatment of said data in the name of Treatment Managers (local SLW entities), in accordance with the applicable legislation on protection data and for the same purposes specified above. Personal data may also be communicated to third parties in case of merger, acquisition or transmission of any of our assets, products, websites or operations.
These third parties will only receive the necessary information for the performance of their respective functions, and will be obliged to use the information received only for the purposes of the treatment specified above, to keep absolute reservation about said information, to protect and comply with the applicable legislation and the instructions they receive from SLW.
Third parties who receive your personal data are established within the European Economic Area and will process the data in accordance with current legislation on data protection for the purposes previously specified.
Except in the cases described above, the personal data of the user will not be shared with third parties, individuals or legal entities not linked to the SLW group or those who do not perform commercial, professional or technical functions for SLW. Likewise, the personal data of the user may be communicated to the legitimate recipients of the communications provided in the laws and regulations, such as, for example, in the context of legal proceedings, at the request of competent authorities, in compliance with other legal obligations and to protect and defend the rights and property of SLW and the Website.
User’s personal data will not be communicated to third parties for marketing purposes nor will they be divulged in any case.
Delivery of personal information
Except as stated above in relation to navigation data (see the previous section "Categories of data subject to processing, Purposes of data processing"), the supply of personal data by the user is necessary to provide the services and to provide the functionalities offered by the Website and needed by the user, such as managing the user's subscription to the Webpage, newsletter or mailing list, managing the purchase of products by the user through the SLW Website and the development of related activities, manage the user participation in promotions and other activities organized through the Website (like contests and sweepstakes), manage and respond requests for information, questions, communications or opinions sent to SLW, as well as managing the curriculum vitae (CV) sent by the user and any other information sent by the user.
The supply of user’s personal data to carry out the activities required to comply with applicable law is mandatory. The refusal by the user to provide their personal data in the aforementioned cases would prevent SLW from fulfilling its contractual obligations or providing the user with the services, products or information requested in the terms indicated above.
The supply of data by the user’s part for the preparation of surveys, development of marketing activities and creation of profiles in accordance with what is established above is optional; The refusal to provide your personal data in such circumstances will not in any way affect SLW's ability to fulfill its contractual obligations and provide the user with the services, products or information requested in the terms indicated above.
User rights in data protection matters
The user may exercise at any time the rights recognized by the current legislation on data protection, including but not limited, the right to verify at any time the existence of their personal data and the content, origin or accuracy of the data, request its integration, updating, modification or elimination of the data, and oppose (with a justified cause) to the processing of the data (including the right to oppose at any time and for free, to the processing of their personal data for direct marketing purposes).
If the user wishes to send any query or request regarding the processing of their personal data by SLW and exercise their rights recognized by the Data Protection Law, the user can contact SLW through the following contact details: at the postal address "MY WAY FOOTWEAR S.L. Parque Empresarial - Germán Bernácer, 65 “(office 12), 03203 Elche, Alicante (Spain); Or sending an email using the available form through the following link: contact.