PRIVACY and COOKIES POLICY

DATA TREATMENT

Latest version: 10/02/2023

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WHO IS THE DATA CONTROLLER FOR THE PROCESSING OF YOUR DATA?

The data controller for the processing of personal data is GOLD RIVER KFT. (“MANAWA Fashion”), corporate Tax id number: 12907760-2-13.

 

MANAWA Fashion contact details are as follows: 

- Mobile number +62 81 337 54 60 40

- e-mail: aloha@manawafashion.com

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WHAT TYPE OF PERSONAL INFORMATION DOES MANAWA FASHION COLLECT?

MANAWA Fashion may collect your personal information through the corresponding forms on the MANAWA Fashion website:

- name,

- e-mail address,

- postal address,

- telephone number and

- credit card (PAN+CVV2) in compliance with PCI DSS standards or bank account number (provided by the customer in the case of refunds) when you visit the web, you register, place an online order, contact MANAWA Fashion and/or participate in MANAWA Fashion promotions or questionnaires.

In addition, MANAWA Fashion will collect all information relative to your browsing on the WEB as well as your interaction with the brand.

All the personal data MANAWA Fashion collects originate from the data subject, with the exception of contact details that may be provided to us by friends and family for the sending of a gift voucher or other gift.

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FOR WHAT PURPOSE DO WE PROCESS YOUR PERSONAL DATA?

Your personal data will be processed for the following purposes, whichever apply: 

- Management of your registration on the web.

- Management of online sales and purchases. We use your personal information to process and deliver your order and to inform you of the status of the same via e-mail.

- Elaboration of a commercial profile based on your browsing on the web. Said profile will be elaborated through the use of your personal data and browsing information, such as products seen or added to the shopping bag, sections of the web visited, the country from which you visit us, etc., in order to evaluate your personal preferences and/or interests for the purpose of offering you web content, offers, services and products adapted to your profile.

- Management and sending of information on exclusive promotions and new products adapted to your profile via e-mail, and your postal address. This includes promotional actions, such as, for example, the management of competitions and prize draws organized by MANAWA Fashion.

- Prevention, detection, and control of abuse and fraud in the use of our services.

- Management of the alerts service to notify the availability of garments and accessories on the web. 

-  Management and sending of notifications relative to garments and accessories pending in your shopping bag.

- Management and issuing of proof of purchase documents: simplified e-receipt, sale, or Tax-Free invoice.

- Management of the MANAWA Fashion Gift Card. 

-  Response to the exercise of your privacy rights, and attend to queries, requests, and potential complaints you may make via the Customer Services channel.

-  Actions and quality surveys aimed at discovering your degree of satisfaction, in order to create and improve our services.

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HOW LONG DO WE KEEP YOUR PERSONAL DATA?

MANAWA Fashion will keep your personal data only for a period that is reasonably necessary given the requirements to respond to issues that are raised or to resolve problems, make improvements, activate services, and fulfill the requirements of the applicable legislation. This means that it may keep your personal data for a reasonable time, including after you have stopped using the services of MANAWA Fashion or have stopped using the web. After this period, your personal data will be blocked on all MANAWA Fashion systems.

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WHAT AUTHORISES ARE USED TO PROCESS YOUR PERSONAL DATA?

MANAWA Fashion has the following lawful bases to process your personal data:

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Execution of the contract

The lawful basis for the processing of your personal data is the execution of the sale and purchase agreement.  In this regard, you are obliged to provide the data necessary for its execution. Otherwise, it will not be possible to make the sale and purchase. 

With regard to the following purposes, the lawful basis for the processing of your personal data is the execution of the sale and purchase agreement:

 - Management of online sales and purchases.

- Management and the issue of the proof of sale and purchase documents: sale and purchase invoice and/or simplified e-receipt. 

- Management and the issue of the “Tax-Free” document in relation to the sale and purchase.

 

Fulfillment of a legal obligation

With regard to the following purposes, the lawful basis of the processing of your personal data is the fulfillment of a legal obligation:

- Management and the issue of the sale and purchase invoice.

- Response to the exercise of your privacy rights, and attend to queries, requests, and potential complaints you may make via the Customer Services channel.

 

Consent

With regard to the following purposes, the lawful basis of the processing of your personal data is consent, in cases where it has been given:

- Management of your registration on the web.

- Management and sending of information on exclusive promotions and new products.

- Elaboration of a commercial profile based on your browsing on the web.

- Management of the alerts service to notify the availability of garments and accessories on the web. 

- Management and sending of notifications relative to garments and accessories pending in your shopping bag.

- Management of the MANAWA Fashion Gift Card. 

The withdrawal of consent for such processing on your part will not affect the execution of the sale and purchase agreement between you and MANAWA Fashion.

 

Legitimate interest

With regard to the following purposes, the lawful basis of the processing of your personal data is legitimate interest:

- Prevention, detection, and control of abuse and fraud in the use of our services.

- Sending satisfaction surveys on products purchased or services used by you, in order to ask for your opinion and be able to offer improvements. 

Our legitimate interest consists of being able to guarantee you that our web is secure and to help MANAWA Fashion understand the needs, expectations, and your degree of satisfaction with the brand and therefore improve our services at all times. All these actions will be carried out to improve your degree of satisfaction and guarantee a unique browsing and shopping experience.

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TO WHICH ADDRESSES CAN WE COMMUNICATE YOUR PERSONAL DATA?

Your personal data can be communicated to the following addresses: 

- Public Administrations and Bodies, whenever required by the tax, employment, Social Security or any other applicable legislation. 

- Data processing companies (suppliers of fraud detection and prevention services, technological and analytical services, customer services, advertising and marketing services, etc.) and, in general, third-party suppliers necessary for the rendering of the services offered by MANAWA Fashion (suppliers of courier and transport services, etc.).

International data transfers may also occur between the communications hubs of the same, in which case MANAWA Fashion shall use the Standard Contractual Clauses adapted by the European Commission as a safeguard for transfers made to countries that are not covered by an adequacy decision of the European Commission. In all cases, third parties sharing certain personal data will have previously accredited the adoption of suitable technical and organizational measures for the correct protection of the same.

MANAWA Fashion does not, under any circumstances, sell customer data to third parties

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HOW DOES MANAWA FASHION PROTECT YOUR PERSONAL DATA?

The web uses data security technologies such as firewalls, access control procedures, and cryptographic mechanisms to prevent any unauthorized access to data and guarantee data confidentiality. In order to achieve said aims, users accept that MANAWA Fashion will obtain data for the purpose of authenticating access controls.

Furthermore, all transactions via the web will be made via secure payment systems. Confidential payment details are transmitted directly in encrypted format (SSL) to the corresponding entity.

MANAWA Fashion declares that it has adopted all the technical and organizational measures necessary to guarantee the security and integrity of the personal data it processes, and to prevent the loss, alteration, and/or unauthorized use of the same by third parties.

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WHAT ARE YOUR PRIVACY RIGHTS IN RELATION TO YOUR PERSONAL DATA?

You have the following privacy rights, which may be exercised via the e-mail address aloha@manawafashion.com. In order to process your request to exercise your rights, we may ask you to provide proof of your identity.

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- Right of access: You have the right to obtain confirmation whether MANAWA Fashion processing personal data that concern you, or otherwise, and to access the personal data MANAWA Fashion possesses about you.

- Right to rectification: You have the right to request that MANAWA Fashion rectifies personal data when they are incorrect or for them to be completed when they are incomplete. If you are registered on our web, it may be simpler for you to correct them directly by modifying your profile.

- Right to erasure/right to be forgotten: You can request that your personal data be erased when, among other reasons, the data is no longer necessary for the purposes for which they were collected.

- Right to restrict processing: You have the right to request the restriction of the processing of your data, in which case we will only keep them for the exercise or defense of legal claims.

- Right to data portability: You have the right to receive personal data in a structured, commonly used, and machine-readable format, and to transmit them to another controller when the treatment is based on consent or a contract and is transmitted electronically.

- Right to object: You can object to the processing of your personal details based on the public or legitimate interest pursued by MANAWA Fashion, including the profiling of data. In this case, MANAWA Fashion will stop processing the data, except for compelling legal grounds or the exercise or defense of possible legal claims. You also have the right to object to the processing of data for direct marketing purposes.

- Automated individual decisions: Wherever this applies, you have the right not to be subject to a decision based solely on automated processing, including data profiling, which has a legal or similarly significant effect on you. However, it will not be possible to exercise said right in cases where the decision is necessary for the formalization or execution of a contract between you and MANAWA Fashion; it is authorized by the law applicable to MANAWA Fashion whenever it establishes the appropriate measures to safeguard your rights, freedoms and legitimate interests; or where it is based on your explicit consent.

- Right to lodge a complaint: You have the right to lodge a complaint before the Data Protection Agency or the competent local Supervisory Authority.

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MODIFICATIONS TO THE PRIVACY AND COOKIES POLICY?

In the event that we modify the content of the Privacy and Cookies Policy, we will inform you via the web address whenever the changes substantially affect your privacy, so that you can analyze them and, wherever applicable, exercise your rights as a data subject.

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USE OF OUR WEBSITE

Users agree to use the Website content in an appropriate manner, undertaking to (i) true and exact information on the data requested in the registration form or order placement, and keep it up-to-date while using the Website; (ii) not incur in activities that are illicit, unlawful or contrary to good faith and public order; (iii) not publish content or propaganda of a racist, xenophobic or discriminatory nature based on race, gender, ideology, religion or act in any way contrary to the morality, public order, fundamental rights, public liberties, honour, intimacy or image of third parties and the applicable legislation in general; (iv) not damage the physical and logical systems of the Website, of MANAWA Fashion suppliers or third parties, or introduce or spread computer viruses into the network or any other physical or logical systems likely to result in the aforementioned damage; (v) not use the content of the Website and the information of the same for sending publicity, or sending messages for any other commercial purpose, or to collect and store the personal details of third parties; (vi) not attempt to access and, wherever applicable, use the e-mail accounts of other users and modify or tamper with their messages.

MANAWA Fashion reserves the right to make whatever modifications it considers appropriate to its Website without prior notice, and may change, delete or add content and services it provides via the same, such as the manner in which the same are presented or located on its website.

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INTELLECTUAL AND INDUSTRIAL PROPERTY

All intellectual and industrial property rights over the Website and its content, including, by way of example, the images, sound, audio, video, designs, texts, graphics, logos, icons, color combinations, structure, and buttons, in addition to the software, commercial names, trademarks, works, illustrations, photographs and industrial drawings and any other symbols for industrial and commercial use are the property of MANAWA Fashion or of third party owners of the same who have duly authorized their inclusion on the Website.

The reproduction, distribution, and public communication, including making part or all of the content of the Website available for commercial purposes, in any medium and by any technical means, is strictly prohibited without the authorization of MANAWA Fashion.

Users agree to respect the intellectual and industrial property rights owned by MANAWA Fashion. Users may use the Website and its content for their own personal and private use. Any other use is prohibited and shall require the user to obtain the prior, express, and written consent of MANAWA Fashion. Users shall refrain from deleting, altering, eluding, or tampering with any protective device or security system installed on the Website.

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RESPONSIBILITY DERIVED FROM THE USE OF THE WEBSITE

MANAWA Fashion shall not, under any circumstances, be liable for any damages of any nature they may occur, by way of example, as a result of errors or omissions in the content, unavailability of the website, or the transmission of viruses or malware in the content, in spite of having adopted all the technical measures required to prevent this.
Users may be redirected from the website to the content of third-party websites. Given that the provider cannot control the content introduced by third parties on its website at all times, the same cannot assume any liability in relation to said content. In all cases, the provider declares that it shall withdraw any content that may contravene national and international legislation, morality, or public order with immediate effect, through the immediate withdrawal of the redirection to said website, reporting said content to the competent authorities.

MANAWA Fashion shall not be liable for stored information and content, including but not limited to, on forums, chats, blog generators, comments, social networks, or any other medium that allows third parties to publish content independent from the Website. However, MANAWA Fashion shall make itself available to all users, authorities, and security forces and actively collaborate in the withdrawal or blocking of any content that may affect or contravene national or international legislation, third-party rights, morality, or public order. In cases where users consider that content that may be classified as such exists on the Website, they are asked to report this without delay to the Website Administrator: aloha@manawafashion.com
The Website has been checked and tested to ensure it works correctly. In principle, the correct operation of the same can be guaranteed 24 hours a day, 7 days a week, all year round. However, MANAWA Fashion cannot rule out the possibility that certain programming errors exist, or that access to the Website may be impeded owing to force majeure, natural disasters, industrial action, or other circumstances.
The introduction of hyperlinks for commercial purposes on third-party websites that allow access to the Website is forbidden without the prior written consent of MANAWA Fashion. MANAWA Fashion shall not be liable for the use or content of third-party websites which may be linked to MANAWAFashion.com.

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COOKIES POLICY

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WHAT ARE COOKIES AND HOW ARE THEY USED?

Cookies are files installed on the computer, telephone, tablet, or any other device of the user-designed to record its activity during the browsing session on the present webpage and/or mobile application of MANAWA Fashion (“Web”). The use of cookies allows the server in which the Web is located to recognize the browser used by the user, granting the registered user, for example, access to the areas and services without having to register in each visit and record his/her preferences with regard to language, country, etc. in future visits. Cookies are also used to measure the audience and traffic parameters, monitoring the progress and number of entries.

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WHO USES THE INFORMATION STORED IN THE COOKIES?

The information stored in the cookies of the Web is used by Gold River Kft. (“MANAWA Fashion”), with Corporate Tax ID no. 12907760-2-13:​

• Mobile number +62 81 337 54 60 40

• e-mail: aloha@manawafashion.com

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WHAT TYPE OF COOKIES DOES MANAWA FASHION USES?

Below we indicate the types of cookies used in the MANAWA Fashion Web according to their use and the organization that manages them (first and third-party cookies).

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Purpose/Description

- Performance Cookies: These allow us to count the visits to the Web and traffic sources, quantify the number of users, and therefore measure and conduct statistical analysis on the use made by users.

- Functional Cookies: These allow you to access the service with predefined characteristics in accordance with a series of criteria, for example, the language, the type of browser used to access the service, the regional configuration where the service is being accessed from, etc.

- Strictly Necessary Cookies: These are necessary for the browsing and the optimal performance of our Web. For example, they make it possible to monitor the traffic and communication of data, access restricted areas, perform the purchasing procedure for an order, use security elements, and store content in order to broadcast videos or share content via social networks.

- Targeted Cookies: These cookies store information on the behavior of users obtained through their browsing on the Web so that we can show you advertising related to your browsing profile.

- Social Media Cookies: These consist of a series of social media services we have added to the webpage to allow you to share our content with your friends and networks.

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Management 

- First-party cookies: These are cookies that are created or managed by MANAWA Fashion, with responsibility for the Web.

- Third-party cookies: These are cookies that are managed by service providers external to MANAWA Fashion. The third parties are listed in the "Set cookies" panel.

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HOW TO DISABLE COOKIES IN THE MOST COMMONLY-USED WEB BROWSERS

You can allow, block or delete the cookies installed on your computer in the settings options of your web browser. If you block them, certain services that require their use may not be available to you.

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Below, we provide some links to information on how to enable your preferences on the most commonly-used web browsers:

Google Chrome

Mozilla Firefox

Internet Explorer

Safari

Opera

If you have accepted the third-party cookies, you can delete them from your web browser options or from the system offered by the third party itself.

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CONSERVATION PERIODS

MANAWA Fashion will keep the personal data only for a period that is reasonably necessary given the requirements to respond to issues that are raised or to resolve problems, make improvements, activate its services and fulfill the requirements of the applicable legislation. This means that it may keep the personal data for a reasonable time, including after the interested party has stopped using the services of MANAWA Fashion or has stopped using the WEB. After this period, personal data will be blocked on the MANAWA Fashion system.

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DATA TRANSFERS TO THIRD COUNTRIES

In general, the data processing will be carried out by our service provider WIX which has been declared to offer an adequate level of protection.

International data transfers may also occur between the communications hubs of the same to third countries, in which case MANAWA Fashion shall use the Standard Contractual Clauses adapted by the European Commission as a safeguard for transfers made to countries that are not covered by an adequacy decision of the European Commission. In all cases, third parties sharing certain personal data will have previously accredited the adoption of suitable technical and organizational measures for the correct protection of the same.

MANAWA Fashion does not, under any circumstances, sell customer data to third parties.​

You can find out more information about transfers to third countries made by the third parties identified in this Cookies Policy, wherever applicable, in their corresponding policies.