PRIVACY MANAGEMENT POLICY

WALKEMORE S.A.

PRIVACY MANAGEMENT POLICY

1. Application

The Privacy Management Policy presents the commitment of Walkemore, S.A. in relation to the privacy management of the personal data of data holders, as well as compliance with the General Regulation on Data Protection, identified as Regulation (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27^th April 2016.

Taking into account the inventory of personal data that Walkemore, S.A. keeps updated, all the data considered private and / or sensitive managed according to the requirements of the General Regulation on Data Protection in order to guarantee the data holders rights.

2. Confidentiality and Privacy of Personal Data

For Walkemore, S.A. personal data holders are all contractual corporate customers, web clients, company employees and suppliers / service providers (subcontractors).

Personal and/or sensitive data that are placed in custody of Walkemore, S.A. are accessed by company employees formally authorized to perform such tasks.

The data are used only for activities that were previously authorized by the data holders through prior, informed and free consent.

Therefore, in the commitment to guarantee the privacy of personal data, confidentiality is also guaranteed.

The guarantee of confidentiality is ensure through the celebration, with Walkemore, S.A. employees, of agreements for the protection of personal data that they access and work in the course of their professional activities.

3. Identification of the Responsible for Personal Data Treatment

The responsible for the personal data treatment is Walkemore, S.A., headquartered in Rua das Casas Queimadas, nº567, 4415-439 Grijó, Vila Nova de Gaia, Portugal, VAT nr. PT 513 165 703.

4. Collection, Treatment, Sharing and Retention of Personal Data

4.1 Collection of Personal Data

4.1.1 Situations that do not involve Web tools

Personal data are collected directly from the following sources: form filling in Walkemore, S.A. website, job application with curriculum vitae sharing, filling out paper forms, capturing images and videos, biometric data, e-mail adresse or phone.

Personal data can also be collected indirectly by importing Curriculum Vitae content into the internal candidate management platform.

No other method of indirect collection of personal data will be executed.

The collection of sensitive personal data will only be carried out in strictly necessary cases justified by legislation, in particular, and as exemple, for the work medicine.

4.1.2 Situations Involving Web Tools

Personal data are collected directly through the Walkemore, S.A.official Web tools, such as online shopping sites, or indirectly through “marketing automation” tools and “online” advertising through duly authorized and fully compliant subcontracting partners with privacy management policy

There are also indirect collections through subcontracting partners regarding order placement, such as Amazon and Overcube.

The cookie management policy complements this topic by presenting the "opt-in" and "opt-out" options that are available at Walkemore, S.A.official website.

The data holder can also “opt out” of online advertising services in Walkemore, S.A. social tools, namely Facebook, Google Ads and Instagram.

Walkemore, S.A. assumes that in no case will a manual or computerized form have pre-filled options. All alternatives are selected by the data holder.

The collection of personal data will always be minimized for activities strictly necessary to the legitimate commercial interest of Walkemore, S.A..

4.2 Personal Data Treatment

Authorized personal data will only be used by Walkemore, S.A. with the strict objective of sustaining its commercial activities and legal obligations.

4.2.1 Situations that do not involve Web tools

Included Activities:

Justification	Purpose of Treatment	Grounding
Management of job applicants	Curriculum analysis and interview selection	Life cycle management of employee hiring
	Curriculum Vitae export data to internal candidate management platform
	Contact with the job applicant at different stages of the process
	Communication of data to the job applicant in case of selection
	Data retention for future opportunities
	Contact the job applicant for new opportunities and for updating data
Human Resource Management	Administrative management of human resources Wage processing	Operational management of the organizational support area
Human Resource Management	Employee card and placement in company contacts and access directory	Operational management of the organizational support area
Physical Security	Access control Images of video surveillance Attendance record	Physical security control of buildings
Internal and External Communication	Publication of news, testimonies, images and videos on the company's website, internal newsletter and social networks	Promotion of the company and the events in which it participates
Commercial Management	Customer Registration in ERP and Customer Form Registration and archiving of commercial proposals	Customer relationship management
Financial Management	Billing and Collection Information Shared with External Accounting Service	Operational management of the organizational support area
Purchasing Management	Supplier registration in ERP and supplier form Supplier contact query and activity log	Operational management of the organizational support area
Technical Assistance	ERP registration for technical assistance Marking the beginning and end of technicians route for record of distance covered	Operational management of the organizational support area
Information Systems Management	E-mail system account management and related services	Access control
	Preparation of machines to delivery to the employee Retention of employee data for the previous objective	Employee service provision
	Partner contacts query	Partner Relationship Management
	Consultation and custody of customer databases	Provision of application software maintenance service

No data will be used for the creation and use of sales profiles or indicators of products, regions or trends.

4.2.2 Situations Involving Web Tools

Included Activities:

Justification	Purpose of Treatment	Grounding
E – Commerce	User registration on online store or marketplaces	Legitimate interest for Web client service providing
	Online order management on websites
	Communication with the user/customer in the different stages of the ordering process
	Data transfer to logistics and freight providers
	Retention of customer data with registration for new purchases
	Data transfer to the platform for sending promotional digital marketing newsletters
	Data transfer for online advertising on social networks
	Customer service (online or by phone)

4.3. Personal Data Sharing

4.3.1 Situations that do not involve Web tools

Personal data sharing will be made for strictly necessary and authorized purposes by the data holder as a support for the development of Walkemore, S.A., activities, including:

Sharing Destination	Data Shared	Grounding
Portuguese Legal Authorities	Number, address, tax identification number, social security number, admission data, ID card number	Social security inscription Communication with tax authority, customs or other legal entities
Portuguese Control Authority for the Protection of Personal Data	Number, address, E-mail address, phone number, ID card number	Communication of complaints or breaches of privacy DPO communication
Work Medicine	Name, birthdate, admission data, social security number	Work Medicine services registration Medical form creation
Insurers	Name, tax identification number, address, birthdate, admission data	Employee inscription in the work accident insurance
Bank Entities	Name, international bank account number	Salary processing and expenses payment
Accounting Services Providers	Name, tax identification number, address, ID card number	Compliance with tax obligations and management of company accounting
Legal Services Providers	Name, tax identification number, address, ID card number	Conflict management Contracts signing
Informatic Service Providers	Name, job history	Candidates presentation for outsourcing service

Any additional requirements will be subject to a supplemental request for informed consent to the respective data holders.

These data-sharing will be fully realized in the European Union.

Regarding these principles, personal data may be transmitted to subcontractors who, by means of a formal agreement specific to each case, undertake to comply with the necessary security controls in accordance with the privacy management policy of Walkemore, S.A..

4.3.2 Situations Involving Web Tools

Personal data sharing will only be done with subcontracting partners who have signed the security management agreement in accordance with the determinations of the privacy management policy of Walkemore, S.A..

Sharing Destination	Data Shared	Grounding
Marketing Automation	Gender, age and birthdate	Customized Campaigns for the Customer
Sending Newsletters and / or SMS	Name, e-mail address, address, birthdate, phone number	Sending personalized news, campaigns and offers to the customer
Online Advertising	E-mail address	Google Ads, Facebook and Instagram Advertising
Logistics and Delivery	E-mail address, name, phone number, shipping and billing address, birthdate, payment method, tax identification number	Operational requirements for interconnection with Chronopost, CTT and DHL
Online Payment	Bank card number and ATM reference (if applicable)	Operational requirements for interconnection with HiPay and Paypal

There is data sharing with formally authorized subcontractors for digital marketing purposes. The personal data involved in these actions are subject to the consent of the data holder and, at any time, there is the possibility of “opt-out”.

In case of targeting digital marketing campaigns with intercontinental subcontracting partners, these actions can lead to the transfer of data outside the European Union.

In these cases, Walkemore, S.A. will implement appropriate security controls to each identified risk situation, also ensuring data holders the guarantee of unconditional execution of their rights and all the requirements of the General Regulation on Data Protection.

4.4 Personal Data Storage

For each treatment purpose Walkemore, S.A., will retain the personal data, for the maximum periods indicated below:

Purpose of Conservation	Retention Time	Grounding
Legal Documents	10 years	Current legal requirements
Employment Application Data	5 years
Human Resources Data	1 year
Work Medicine Data	5 years
Biometric Data	Until role change or end of contract
Video Surveillance	1 month
Communication publications containing employees personal data	Until end of contract	Depending on the operational needs and communication strategy of the organization
Communication publications containing personal data	3 years
Contract Customer Orders Data	3 years	Depending on the organization operational needs
Web Clients Orders Data	3 years	Depending on the organization operational needs
Marketing and Advertising Data	Until "opt-out"	Include cookies, "newsletters” and SMS
Complaints and Privacy Violations	5 years	Legal proceedings support (if necessary)
Audit Records and Evidence	5 years	Legal proceedings support (if necessary)

Retention is the secure storage of data, in digital or paper format, in resource(s) under the responsibility of Walkemore, S.A., which guarantees the conditions of longevity and use in function of the defined time.

5. Data Holder Rights

Walkemore, S.A., ensures that data holders will be able to exercise their rights, f provided for and described in the General Regulation on Data Protection, and for this purpose a Data Protection Officer (DPO) has been appointed.

Data holder, in order to exercise their rights and/or submit any question related to this subject, namely the presentation of complaints, should send their request, in writing, to the email address dpo@wockshoes.com.

In the event of a breach of privacy, the data holder may communicate through this same route or directly with the controlling authority.

Following the complaint or privacy violation records, Walkemore, S.A. ensures the execution of a communication procedure with the data holder, informing, in a timely manner, and in accordance with the provisions of the General Regulation on Data Protection, at each stage of the processing of the complaint, and in strict compliance with the deadlines and conditions defined by the regulation.

6. Roles and Responsibilities

Walkemore, S.A. management ensures that the Privacy Management Policy is aligned with the company's strategy, in addition to ensuring its continuous improvement.

Data Protection Officer has the role of ensuring compliance with the requirements of the General Regulation on Data Protection in a continuous and systematic manner, that all rights of the data holders are being met and that the security controls are adequate for these purposes.

All Walkemore, S.A. employees, as well its subcontractors, have the responsibility to comply with and enforce the commitments of the Privacy Management Policy.

7. Review and Continuous Improvement

Privacy Management Policy will be reviewed annually, or whenever there are significant changes in the personal data inventory and/or in the informatics or documentary supports that warrant the rights of data holders.

Each revision will give rise to a new version of the Privacy Management Policy.

8. Disclosure and Publication

The Privacy Management Policy will be disclosed to all data holders who interact with Walkemore, S.A. and will be available upon request, as the information contained therein is classified as publicly accessible.

The Privacy Management Policy is available on the institutional website, on the Internet tools that support the business and also in the social networks where Walkemore, S.A. is present.

COOKIE MANAGEMENT POLICY
WOCK's online store uses cookies. Cookies are data files that can hold small amounts of info and are stored on your device (computer, smartphone, etc.) when you first visit a website.
Our online store uses cookies to recognize users when they make a new visit.
This allows WOCK to improve the easiness of use of our online store and adjust it to the needs of our users. The cookies stored in the users' computers are valid for an unlimited period of time after the first visit to our website.
You can control these through your browser settings. You can also not accept this online store's cookies. However, if you don't accept them, you might have limited access to some features.

This online store uses the following cookies:

Required Cookies:
These cookies are necessary to allow basic features of the online store. They're used to improve the user's experience by remembering its preferences, such as the acceptance (or not) of cookies, login and password, favourite products, products added to the cart, as others. These cookies do not store any identifiable personal data.
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These cookies allow us to analyze the online store use to measure and improve its performance. They're used to assess the number of visitors, make usage analyses of users' behaviour to improve the graphics and texts provided in the online store.
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These cookies are used by advertising companies to promote relevant ads for you. These cookies store data about users behaviour that allows the display of advertising relevant to the user's profile. These are the cookies that provide a more enjoyable and personalized experience navigating the Internet and social media.
The apps used to collect cookies by third-party companies are:
- Google Analytics
- Google Tag Manager
- Facebook Connect
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These companies can also use the collected data to enhance their offers and services to other companies.
INTELLECTUAL PROPERTY RIGHTS
All elements of the website www.wockshoes.com are either visual or audible, including the underlying technology which is protected by copyright, trade marks or patents. Consequently they are the exclusive property of WOCK®. Any user, who has a personal website on the Internet and would like to put on the website a simple direct hyperlink to our website www.wockshoes.com, must seek authorisation from WOCK®. It will not, in this case, be an implicit agreement of affiliation or partnership. On the other hand, any hyperlink directed to the website of www.wockshoes.com and using the technique of framing or in-line linking is strictly prohibited. In all cases, any hyperlink, even tacitly permitted, should be withdrawn if requested by WOCK®.