Privacy Policy

Platform: https://platform.refashionable.eu/

Version: October 2024

1. PURPOSE OF THE PRIVACY POLICY

The objective of the company BLUE ROOM INNOVATION S.L. (hereinafter "BLUE ROOM" or the "Provider"), through the platform https://platform.refashionable.eu/ (hereinafter, the "Platform"), is to offer the user (the "User") a secure and reliable browsing experience and service through it and what is displayed or collected through it.

Therefore, we have implemented this Privacy Policy, which complies with the guidelines and security measures required by Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, and by the European Regulation on the Protection of Personal Data 679/2016, of April 27, regarding the protection of individuals with regard to the processing of personal data and the free movement of such data. All this is aimed at ensuring privacy and transparency in the use of user data.

2. DATA CONTROLLER AND CONTACT INFORMATION

As stated in the Legal Notice, the entity behind this Platform and, regarding data processing, considered the data controller, is:

For any needs as a User in relation to this privacy policy, you can contact us at the email address provided above or at our physical address.

3. WHERE DO WE COLLECT YOUR PERSONAL DATA ON OUR PLATFORM?

3.1. Corporate Emails

Through our email addresses: info@blueroominnovation.com and/or lopd@blueroominnovation.com, you can contact us and/or request the information you need to clarify doubts related to our services, the functioning of our platform, or our data protection policy.

3.2. Contacting the Company

Users can contact us to address their doubts, queries, comments, or any other communication they wish through the email address info@blueroominnovation.com or the following phone number: +34 722 43 47 56.

3.3. Forms

We collect user's personal data through our platform login. The collection of this data will occur when the user enters information in designated fields for this purpose, which will be clearly indicated. These forms will not collect any data until the user has given consent for the processing of their information, following this Privacy Policy.

3.4. Platform updates

To inform the user about platform updates, contents, spaces, followings, and any other communications that we consider may be of interest, the user can subscribe to to these notifications by selecting them in the platform profile settings, section “E-Mail Summaries” and section “Notifications”.

3.5. Behaviour and Habits on the Platform

We may also collect information about your behaviour on the platform through cookies; regarding this, you can refer to our Cookie Policy for more details.

3.6. Social Media

Finally, we may gather data and interact with the user through their user profile on the project social media platforms, detailed in section 12 of this policy, where we post current or interesting content for our followers.

4. PLATFORM UPDATES

We offer users the opportunity to subscribe to platform summaries updates and receive platform information from us via email. By subscribing, the user gives express consent to receive information about updates and interactions from our platform. Users can unsubscribe from this service at any time; each email sent will include a simple and clear link to unsubscribe, allowing them to withdraw their consent easily and free of charge.

The communications will include relevant and updated information about opportunities, updates from spaces, and other interesting updates related to the platform. The information collected for platform emails delivery will be used exclusively for this purpose and will not be shared with third parties without explicit consent, except as required by law.

5. WHAT IS THE PURPOSE OF DATA COLLECTION?

The purpose of data collection in all the sections mentioned in the previous point is:

• Maintaining direct and personalized contact with our users, using their data to address inquiries or information requests, manage their requests, and ensure an experience that adheres to the highest standards.
• Managing content relationship with https://platform.refashionable.eu/

In no case will users receive information from third parties without being informed and having given their prior consent, thus ensuring compliance with Spanish law and European regulations.

Additionally, users are informed that we will not make international transfers of their data, except in the exceptions outlined in our legal texts, if applicable. All servers we use for service provision are located within the European Economic Area.

6. USE OF PERSONAL DATA

BLUE ROOM informs its users that the personal data provided will be processed for the purposes outlined in point 1, detailed as follows:

1. Addressing and resolving user requests or queries.
2. Informing about updates on the platform.
3. Sending information considered to be of interest to the user related to the platform and project.

Users are warned that the information provided through the platform may reveal or allow others to deduce their nationality, ethnicity, gender, age, or other aspects of their private life. Thus, by providing this information voluntarily through any means on our platform, users are expressly and voluntarily accepting this Privacy and Personal Data Protection Policy.

7. SHARING INFORMATION WITH THIRD PARTIES

As established in the previous sections, BLUE ROOM will not share Users' data with third parties, defined as entities that have no direct connection with the User or that do not perform a function on behalf of or under the instructions of the service provider or data controller, in this case, BLUE ROOM, except in cases of legal obligation or with entities acting as Data Processors or other companies within the group. In both cases, we ensure that the necessary measures are taken to protect the User's data, including the signing of a contract that complies with the regulations. If we intend to share data, you will be informed in advance and your consent will be requested.

8. LEGAL BASIS: EXPRESS CONSENT FOR DATA PROCESSING

8.1. Consent of Individuals

In compliance with the Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights, and the European General Data Protection Regulation 679/2016, and following our internal policies, every time the user sends us personal data, they must give their express consent by clicking on the checkbox at the bottom of each form where their data is collected, or when writing to our contact email or any other enabled for specific functions of the platform, they are expressly agreeing that we can collect their data for the purpose or request indicated. With such action(s), they are manifesting freely and unequivocally their agreement that BLUE ROOM processes their data according to the purposes mentioned in the previous sections.

Likewise, the user guarantees that the personal data provided to BLUE ROOM is truthful and takes responsibility for communicating any changes to it.

The user's acceptance that their data be processed for the purposes referred to in this policy is always revocable, with no retroactive effects, in accordance with current legislation; therefore, the user has the right to withdraw their consent at any time, without affecting the legality of the treatment based on their previous consent, through the means provided in section 6 of this legal text.

8.2. Legal Age

To be a user of our platform and use our services, it is necessary to be of legal age and have the corresponding legal and acting capacity.

8.3. Legitimate Interest

Additionally, we may process user data based on our legitimate interest in accordance with applicable data protection regulations, as duly informed at each moment or in this Privacy Policy.

9. EXERCISING RIGHTS

The Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights and the European General Data Protection Regulation 679/2016 have implemented legal guarantees that allow the user to exercise rights and actions related to the processing of their data.

BLUE ROOM provides this legal guarantee, so at any time and/or when deemed appropriate, the user can exercise their rights of Access, Rectification, Deletion, Opposition, Portability, Forgetfulness, Limitation of treatment, and not to be subject to automated individual decisions, by writing to the contact email we have provided for this: lopd@blueroominnovation.com or by sending a request by physical mail to Calle Gran Via Carles III, 98 - Floor 10, 08028, Barcelona, accrediting or justifying their identity and expressly indicating the request they wish to make: access, rectification, deletion, opposition, portability, forgetfulness, limitation of treatment, or not to be subject to automated individual decisions.

It is important for the user to be aware that information shared with others through any means may continue to be visible, and BLUE ROOM disclaims all responsibility for the deletion of this information.

Likewise, BLUE ROOM does not control the renewal system of third-party search mechanisms, and certain information from the public profile that has already been cancelled may still be contained in these mechanisms due to its redistribution on the internet. In such cases, we recommend contacting the managers of those platforms to request cancellation or the exercise of the right to be forgotten.

Below, we briefly explain what each of the rights the user can exercise entails.

Access	Through the exercise of this right, you can find out what personal data of yours are being processed by us; their purpose, origin, or possible transfer to third parties.
Rectification	It allows you to modify your personal data whenever they are inaccurate or incomplete, specifying in the request which data you want to be modified.
Suppression	Allows the cancellation of your personal data if it is inappropriate or excessive.
Opposition	With the right to opposition, you can object to the processing of your data in cases such as advertising and commercial prospecting activities or when the processing aims to make a decision about you based solely on automated processing of your personal data.
Portability	You can receive your personal data provided in a structured, commonly used, and machine-readable format and transmit them to another controller, whenever technically possible.
Forgetfulness	You can request the deletion of personal data without undue delay when certain circumstances occur. For example, unlawful processing of data, or when the purpose that motivated the processing or collection has disappeared.
Limitation of Processing	In general, in cases where it is not clear whether personal data should be deleted, you can exercise your right to limit processing. This right exists in the following cases: (i) when the accuracy of the data is in doubt, (ii) when you do not want the data to be deleted, (iii) when the data is no longer necessary for the original purpose but cannot be deleted for legal reasons, (iv) when the decision of your objection to processing is pending. Limitation means that your personal data can only be processed with your consent for the formulation, exercise, or defense of legal claims, for the protection of the rights of another natural or legal person, or for reasons of public interest of the EU or a specific EU member state. As a user, you must be informed before the lifting of such limitation.
Not to be Subject to Automated Individual Decisions	You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects on you or significantly affects you in a similar way.

Likewise, as a User, you have the right to file a complaint with the relevant Control Authority, the AEPD https://www.aepd.es/en, if you believe that the processing of personal data concerning you violates the provisions of data protection legislation and regulations. This is without prejudice to any other administrative remedy or legal action.

You are also informed that the processing of your data will not involve making decisions about your information based solely on automated processing - automated decisions, nor will there be profiling. In other words, the automated processing - and without human intervention - of your personal data to evaluate personal aspects about you, based on the data you provide, is not allowed.

Such processing will be subject to appropriate safeguards, including specific information about you as the interested party and the right to human intervention, if necessary. You also have the right to express your point of view, receive an explanation of the decision made after such evaluation, and challenge the decision when applicable.

10. DATA COLLECTION SECURITY MEASURES

To ensure security on the platform, we have integrated a security system that allows us to maintain the confidentiality and integrity of the data of our Users that have been submitted or collected through the means mentioned in the first point.

Thus, BLUE ROOM maintains the levels of data protection security required by the Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights, and the European General Data Protection Regulation 679/2016, of April 27. It has implemented all technical means at its disposal to prevent the loss, misuse, alteration, unauthorized access, and theft of data provided through the platform.

As a user, you understand, accept, and comprehend that internet security measures are not impregnable. Therefore, you are obliged to take the necessary security measures that allow you to trust the truthfulness of our platform, where you are entering your data. We will also do our best to ensure the privacy and security of that personal information at all times, using the utmost diligence and implementing necessary measures.

In this regard, you are informed that you will be solely responsible for the security measures you implement regarding the protection of your data. BLUE ROOM is not responsible for situations where appropriate security measures have not been implemented, nor for their consequences, including causes or damages caused by third parties outside the business, including fortuitous events and/or force majeure.

According to the foregoing, BLUE ROOM cannot guarantee that unauthorized third parties may become aware of the class, conditions, characteristics, and circumstances of the use that Users make of the services offered on the platform. However, some usage conditions have been established in our Legal Notice.

11. PERSONAL DATA RETENTION PERIOD

The personal data provided will be kept for the time necessary to fulfill the purpose for which it is collected and to determine the possible responsibilities that may arise from that purpose, in addition to the periods derived from applicable legislation.

12. SOCIAL MEDIA

Refashionable has a corporate profile on the social media platforms Facebook, Instagram, and LinkedIn.

Thus, in accordance with the data protection regulations and legislation applicable, the company is the "Data Controller" due to the existence of such profiles on social media and the fact that the User follows us and we can follow them.

This means that if you decide to join our corporate profile as a follower or give a "Like" to our content or profile, you accept this policy, where we explain your rights and how we use your data.

As the data controller, we guarantee the confidentiality of the processing and compliance with your rights, always under the effects of the legislation and regulations referred to in this policy. Moreover, we inform you that we will use these social media platforms to announce news or relevant information related to the services we provide or on topics we consider to be of interest to users. Using the functionalities of these platforms, you may receive news with this type of information on your wall or profile.

However, we also want to inform you that there is no connection between Refashionable and these platforms or social media, so you will accept their usage policy and conditions once you access them and/or validate their notices, terms, and conditions in the registration process. BLUE ROOM is not responsible for the use or processing of your data outside the strict relationship and provision of services indicated in this policy.

13. COOKIES

We inform you that our website uses cookies, as explained to the User through the corresponding Cookie Policy

14. MODIFICATION OF THIS PRIVACY POLICY

BLUE ROOM reserves the right to modify this policy to adapt it to future legislative or jurisprudential developments, as well as to future uses that it plans to make of the personal data of the Users of the platform. In case such modification affects you regarding the processing of your data, for example, because additional processing is going to be carried out, not previously informed, we would notify you.

It is recommended that the User, in any case, reads the Privacy Policy or Personal Data Protection of the platform each time they access it.

15. INTEGRATION WITH OTHER LEGAL TEXTS

This privacy policy is complemented by the Legal Notice, the Cookie Policy, and other applicable legal texts, if any.