Privacy policy
By means of this Privacy Policy, Suïssa, SLU (hereinafter, we or The Embassy Store) informs you about the personal data we collect, how we treat them, and the rights that the Personal Data Protection regulations applicable to us grant you in relation to them.
Applicable regulations
Law 29/2021, of October 28, 21, Qualified Law on Personal Data Protection of the Principality of Andorra (hereinafter referred to as the LQPD), and the regulations that develop it, and
Regulation (EU) 679/2016 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as "the RGPD").
In the following table you will find links to facilitate your access to the points of this policy that are of interest to you, although we recommend that you read it in its entirety:
1. To whom does this Privacy Policy apply?
This Policy applies to visitors to this website (our Website), users of the services offered by The Embassy Store for the purposes described in section 4 of this Policy, and to all persons whose personal data (for example, their images) may appear on our Website or in the context of those services.
2. Who is responsible for the processing of your personal data?
The sole party responsible for the use of your personal data as indicated in the previous section is the owner of this website: Suïssa, SLU (The Embassy Store), with NRT L-707499-B and registered office at Avinguda Meritxell, 31. AD500 Andorra la Vella, Principality of Andorra. We have a Data Protection Delegate who can be contacted at dpd@suissajoiers.com.
The Embassy Store is not responsible for the activities carried out by other websites, even if they are accessed through links on our website. We therefore strongly recommend that you carefully read the information provided to you by these other parties before giving them your personal data (especially the privacy and cookie policies of each website you visit), and that you contact that party if you have any concerns or questions.
3. How do we obtain your personal data?
In general, it is you who, directly, provide us with your personal data - for example, when you call us by telephone or fill in the forms on this website. The only exceptions to this rule are:
Your image, when it is eventually collected by our video surveillance cameras;
Data provided to us by third parties (e.g. a company) who book or purchase products or services from The Embassy Store or any of The Embassy Store's affiliated and associated entities on your behalf;
Photographs in which you may appear at events we organise or participate in;
Images which correspond to any news item where we consider that the public interest and the right to information outweigh the possible interests of the persons whose image or other personal data is published on our website;
Details about you which may appear in reservations of which the holder has made you a beneficiary, or which are provided to us about you in e-mails we receive;
The last four digits of your credit card, which together with the amount of the purchase and the transaction number are returned to us by our payment service provider, as they will be necessary in the event that you wish to consult or revoke the transaction;
The contact details provided to us by our service and product providers when you act as their commercial or contractual representative; and
Cookies on this website, about which you will find more information in our cookie policy.
4. What do we use your data for and on what legal basis?
To manage your bookings or purchases by phone
We process the data you provide in relation to the reservation or purchase of our products and services (for example, when you reserve a piece of jewellery or a perfume) to formalise your purchase or reservation and to communicate to you by email or telephone any information related to the same, as well as to manage and issue documents accrediting the reservation or purchase and any related communication necessary for the formalisation of the same. In particular, we may collect the number and expiry date of one of your credit cards, together with the name of the cardholder and the code on the back of the card, as a guarantee of the reservation and for fraud control purposes.
We may also use the data you provide during the purchase or reservation to manage, administer, provide, extend and improve the services or products contracted, and to extract statistics in relation to the interest aroused by these and our promotions.
The basis for this processing is the contract of sale or reservation agreement for the product or service that you sign when completing the purchase or reservation, and our legitimate interest in improving the quality of the services we offer you.
To analyse how you rate our services and the interest in our marketing campaigns, in order to improve our marketing campaigns.
We may process the information you provide to us, for example, during the purchase or booking of products or services, to ask you to rate the service you received.
We may also extract aggregated statistics (i.e. where the statistical result does not include personal information of any kind) in relation to interest in our marketing campaigns.
The basis for this processing is our legitimate interest in improving the quality of our services and the events we manage or promote, as well as our marketing campaigns.
To send you information, promotions and discounts of your interest.
We process your email address when you subscribe to our newsletter service, to inform you about news, events, exclusive content and promotions so that you can make the most of our facilities, services and products.
The legal basis for this processing is your consent, and you may withdraw your consent at any time by exercising your right as indicated below in this policy, or via the link at the bottom of each email. The only consequence of withdrawing your consent is that you will no longer receive the information we send you or be able to participate in promotions, contests or sweepstakes reserved for our subscribers.
To deal with your requests, queries or complaints
We collect the personal data you provide to us in your e-mails, by telephone, or through the form on the contact page or when you request us to exercise your rights, in order to deal with your requests, queries or complaints in relation to our services or the rights you have regarding your personal data.
The legal basis for this processing is the consent you express by sending or giving us this data, our legal obligation to respond to your rights requests, and our legitimate interest in responding to you. The provision of your personal data is therefore voluntary, but if you do not provide us with the personal data we require, we will not be able to process your request, query or complaint. You may revoke your consent whenever you wish, although such revocation will also make it impossible to continue processing your request, query or complaint.
To handle any future complaints
We retain data that may be necessary to handle your, or our, potential claims on the basis of our legitimate interest in defending ourselves in order to safeguard our rights.
To control access to our facilities, events or services by means of tickets or credentials
We use your reservation or invitation details and your ID card or passport, and even a document proving your Covid-19 protection status (the latter only if we are legally obliged to do so), to authorise or deny you access to our facilities and, eventually, to the restricted areas of our events or services, as well as to analyse and control the occupancy and logistics of the different areas, and to ensure your health and safety (including the prevention of the spread of diseases and contact tracing of persons affected by Covid-19).
The legal basis for this processing is the contract of sale of your room or the service contract to which you are a party, and in the event that we request documents proving your Covid-19 protected status, our legal obligation.
For the safekeeping and return of your lost property in our facilities.
If you have lost a mobile phone or any other item containing personal data, we will store such personal data until the rightful owner of the lost item successfully claims it at our customer service point or, after a reasonable period of time, we hand it over to the law enforcement authorities to arrange for its safekeeping and eventual return.
The basis on which we are entitled to process the personal data of mobile phones, wallets, backpacks and other objects that may contain personal data is our legitimate interest in preventing theft and returning them to you.
To provide media coverage of events
If you participate in person at our events, the independent press and our own professionals may record your image and, on pre-arranged occasions, your voice, in the context of the event or award presentation.
The legal basis for this processing of your image is our legitimate interest in media coverage of the events we organise or sponsor for the purpose of using the recordings in their promotional materials, including our website and social media accounts.
You are not obliged to appear in a recording. If you wish, you have the right to object to our legitimate interest and ask us to remove material in which you are identified. In order to assess your objection against our legitimate interest, and where appropriate immediately remove the images that identify you, we will ask you to tell us where you have seen them.
To promote our facilities, products and services
If you have signed a contract or an image rights consent with us, we may collect photographs or videos of our facilities, products or services in which you are identified, and perhaps heard, to be used in promotional campaigns or published in the media such as national or international press, our website, or our social networks. If you have signed a consent for the transfer of image rights, we inform you that you can revoke it at any time so that we can remove your image from our website and/or our networks, without the revocation having any effect on the dissemination of your image that has taken place prior to processing it.
In addition, we may graphically record the ambience of our premises to promote our premises, products and services and, from time to time, your image and your voice may appear in such graphic material. In contrast to the previous paragraph, in this case the legal basis for the processing of your images is our legitimate interest, which you can object to at any time if you consider it to be contrary to your own interests. In order to assess your objection against our legitimate interest and, if necessary, immediately remove the images that identify you, we will ask you to tell us where you have seen them.
To initiate or maintain a relationship with our suppliers
If you represent a supplier of products or services, we collect your contact details and your signature for the purposes of:
Managing our relations of all kinds with the supplier you represent.
Manage the corresponding file on our list of approved suppliers.
To manage the quotations and invoices of the supplier you represent.
The processing operations linked to purposes a) and b) are legitimised by the employment or service contract you have signed with the supplier you represent and our legitimate interest in contacting this supplier. And the processing operations linked to the purpose c) are legitimated to be necessary for the execution of the contract you have signed with us.
To preserve security through video surveillance
We collect your image and your voice through our video surveillance systems in order to preserve the security of people, property and the facilities themselves.
The basis of legitimacy for the aforementioned processing is the public interest in public safety, our legitimate interest in the security of our establishments, and the legitimate interest of third parties who wish to seek legal protection for a crime that can be accredited by a few minutes of a recording.
To select and recruit our staff
We process the CV data that you voluntarily send us to manage the relationship with candidates for a job at The Embassy Store or one of the entities that hosts The Embassy Store, including the search process, filtering and storage of the CVs of potential candidates, the recruitment process and the hiring process.
The basis of legitimacy for the aforementioned processing is your consent, which you express by sending us your CV, the execution of pre-contractual measures, and if we do not have an open recruitment process or you are not selected and we consider that you may fit in future selection processes, our legitimate interest in keeping your CV to be included in such future processes.
To ensure the proper functioning of our website (functional cookies)
We use functional cookies to ensure the proper functioning of our website.
As these cookies are necessary for the proper functioning of the website, their use does not require your express consent, and the basis that legitimises us to use them is our legitimate interest in being able to offer you the services of our website.
You can find more information about these cookies in our cookies policy.
To extract aggregated statistics on visitors' use of our website (analytical cookies)
We use analytical or statistical cookies to identify the most and least visited pages, analyse what content is of most interest to our visitors, and measure the success of our information campaigns, all with the aim of improving the services we offer you through the Web. All these purposes provide aggregated results, in which it is not possible to identify the interests of any specific person.
As these cookies are not necessary, we will not use them until we have your consent, and not giving or withdrawing your consent will have no effect other than to hinder our aim of improving the website by analysing aggregated statistics on our visitors' browsing habits.
You can find more information about these cookies in our cookies policy.
To send you personalised direct advertising (advertising cookies)
We use our own and third-party advertising cookies to send you personalised advertising, either from us or from our partners.
As these cookies are not necessary, we will not use them until we have your consent, and your failure to give or withdraw your consent will have no effect other than that your visit to our website cannot be used to improve the interest of the advertising you receive.
You can find more information about these cookies in our cookie policy.
In order to use Google cookies
In addition, as an obligation that Google LLC, of which Google Ireland Ltd is a subsidiary, imposes on entities, such as ourselves, that use the Google Analytics and Google Ads tools, we inform you that these two services are operated by Google Inc. located at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, and that Google Inc. is a beneficiary of these services.
The information generated by the cookies about your use of this website and your advertising preferences is generally transmitted to a Google server in the USA and stored there. For more information, please refer to the page describing how Google uses the information on our website and/or Google's privacy policy with regard to the aforementioned services.
Please note that we have activated the IP anonymisation feature on our website to add additional safeguards to the standard contractual clauses protecting this international transfer of data in the USA. With this, Google will shorten your IP address before transmitting it to the USA (identity obfuscation process). Only in exceptional cases is the full IP address sent to a Google server in the USA and shortened there. Google guarantees that the IP address transmitted by your browser to Google Analytics will not be processed together with any other data held by Google.
You can view the categories of personal data processed by these services at privacy.google.com/businesses/adsservices.
For other purposes not incompatible with the foregoing
We may use your personal data for other purposes that are not incompatible with the above (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) provided that this is permitted by applicable data protection laws, and of course, acting in accordance with these and all other applicable laws.
5. With whom can we share your personal data?
We do not pass on your personal data to anyone, unless:
You ask us to do so yourself.
We are legally obliged to do so (for example, we are legally obliged to provide copies of invoices to the Tax and Border Department of the Government of Andorra when requested to do so).
You contract our products or services through intermediaries (for example, a personal shopper) to whom we have to deliver products or services that they have purchased on your behalf.
We are jointly responsible for the collection of data, so that, always with your consent, other entities process them on our behalf. This is the case of:
Google Ireland Ltd, with registered office at 4 Gordon House Street, Barrow - Dublin, Ireland, which acts as a processor for The Embassy Store for the processing of cookie data that is necessary to use its Analytics and Ads services, and as a separate controller for all processing it carries out on your behalf in accordance with its privacy policy. We transfer data to Google Ireland Ltd on the basis of the data protection agreement that this EU-based company includes in the addendum to the standard contract for countries compliant with the GDPR, such as Andorra, to which we add the additional safeguard of activating the anonymisation of the IPs that collect the cookies.
We need to protect your rights, ours, those of our employees, or those of third parties (which may require disclosure to the police for security purposes or to health authorities to prevent the spread of disease, e.g. for contact tracing purposes). for example:
If our video surveillance cameras record a burglary on our premises, or.
If a third party requests video surveillance images from us on the basis of their legitimate interest in seeking legal protection in respect of the commission of a criminal offence or seeking compensation for damages evidenced by the transferred images, and provided that the third party undertakes in writing to use the images only for the purpose of reporting the offence or claiming damages, and to keep the transfer of images to the minimum necessary to fulfil the purpose for which the images were provided.
We need them to be processed by our service providers, on our behalf, under the terms and conditions of the relevant processor contract.
You expressly authorise us to share data collected by advertising cookies with third party advertising companies in order to publish their own advertisements in the spaces provided for this purpose on our website. We are jointly responsible for the collection of your personal data through these cookies, provided that you consent to it, since without our website such data would not be collected, and third party companies use them so that these third parties can show you more personalised advertisements according to the interests that can be deduced from your browsing on the Internet. In our cookies policy you will see which advertising cookies we offer you and how to configure them.
Any international transfer that we may need to make will comply with the provisions of the regulations in force that apply to us at any given time.
6. How long do we keep your personal data?
The Embassy Store retains your personal data only for the duration of the processing that requires it and thereafter we will keep it blocked for as long as it takes for any legal liability that applies to us from time to time arising from the processing in question (including the obligation to be able to demonstrate that we have complied with your request for the destruction of personal data).
For example:
We will retain video surveillance recordings for a maximum of 30 days where they contain no incidents, and, if exceptionally a security incident has occurred during that period or there is evidence of a criminal offence (e.g. theft), we will extract a copy of the part of the recording that records the incident which will be retained until it is provided to the police or the data subject concerned who requires it from us to prove their request for legal guardianship.
We keep your email address for the purpose of sending you newsletters until you revoke your consent to receive them.
Where we do not have a legitimate purpose for processing some of your personal data, we will delete or anonymise it, and if this is not possible (for example, because it is backed up), we will store it securely and block it to isolate it from further processing until such time as it can be deleted.
7. What rights do you have?
You have the right to obtain confirmation as to whether or not The Embassy Store holds any of your personal data.
We remind you that, when you share personal data with other data controllers, you should exercise your rights directly with those controllers, following the instructions provided in their own privacy policies. Specifically, in relation to the data that our cookies share with Google, we inform you that you can install in your Chrome, Internet Explorer, Safari, Firefox and/or Opera browser, the add-on to not send data from Google Analytics to Google Inc.
Below, we explain what other rights you have and how to exercise them.
Your rights
In accordance with the provisions of the LQPD and the RGPD, you can ask us to execute the following rights:
Access to your personal data.
Rectification of any of your personal data, specifying the reason.
Deletion of some or all of your personal data.
Limitation of the processing of your data, specifying the reason for the limitation.
Opposition to the processing of your personal data.
Portability of your data when the legitimate basis for its collection has been your consent or a contract.
Right not to be subject to automated individual decisions.
Where and how you can exercise your rights
You can exercise your rights:
By sending a written request, addressed to The Embassy Store at our postal address indicated in section 4 of this policy, indicating a means of contact so that we can respond to your request, or ask you for further information if necessary. We would be grateful if you could indicate on the envelope "Exercise of Personal Data Protection Rights".
By sending the form associated with the right you wish to exercise, or a message containing such information, to the e-mail address dpd@suissajoiers.com, indicating Exercise of Personal Data Protection Rights in the subject line. You will find these forms further on in this section of the privacy policy.
In both cases, if we are unable to verify that you are who you say you are, we will ask you to please send us proof of your identity, to ensure that we respond only to the data subject or his or her legal representative.
Likewise, if you consider that you have not obtained full satisfaction in the exercise of your rights, we inform you that you may lodge a complaint with the national supervisory authority in your country, or by contacting the Andorran Data Protection Agency (APDA) for this purpose.
Forms for exercising your rights
In order to make it easier for you to exercise your rights, we recommend that you use the appropriate application forms from among the following:
Form for exercising the right of access
Form for exercising the right of correction
Form for exercising the right to object (form A, i form B)
Form for exercising the right of erasure
Form for exercising the right to restrict the processing of personal data
Form for exercising the right to portability
Form for exercising the right not to be the subject of automated individual decisions
8. What responsibilities do you have?
By providing us with your details, you guarantee that they are accurate and complete. Likewise, you confirm that you are responsible for the veracity of the personal data that you have provided us with and that you will keep them suitably updated so that they correspond to your real situation, and that you are responsible for any false or inaccurate personal data that you may provide us with, as well as for any damages, direct or indirect, that may derive from their inaccuracy.
You may not provide us with other people's personal data unless it is justified in relation to the services you request from us. In any case, if you provide us with the personal data of third parties, you are responsible for informing such third parties prior to providing us with their personal data. This information that you must provide to third parties whose data you provide to us must include all the provisions set out in this privacy policy, and it is you who is responsible for the lawfulness of such personal data and for conveying to the data subjects the rights they have in relation to their personal data.
In cases where you are required to provide us with personal data of a child under the age of 16 or of a person whose rights are restricted, you are obliged to obtain the consent of the holders of parental or guardianship rights in doing so. Without this authorisation, you are prohibited from providing us with any personal data of such persons.
9. How do we protect your personal data?
We are fully committed to protecting your privacy and your personal data. We have drawn up a record of all personal data processing activities carried out by The Embassy Store, we have analysed the risk that each of these activities may pose to you, and we have implemented appropriate legal, technical and organisational safeguards to prevent, as far as possible, the alteration of your personal data, its misuse, loss, theft, unauthorised access, or unauthorised processing. We keep our policies appropriately up to date to ensure that we provide you with all the information we have about how we process your personal data, and to ensure that our staff are given appropriate guidance about how they should treat your personal data. We have signed data protection clauses and data processor agreements with all our service providers, taking into account the need for each to process personal data. We restrict access to personal data to those employees who really need to know it in order to carry out any of the processing mentioned in this policy, and we have trained and made them aware of the importance of confidentiality and maintaining the integrity and availability of their information, as well as of the disciplinary measures that any possible infringement in this area would entail.
10. Modificaciones de esta PolÃtica de Privacidad
We will update this policy from time to time to reflect any changes to the law or our processing. If the changes are material, we will notify you before they take effect by sending you a notice or by prominently posting a notice on this website, and you will have the option to exercise your rights as set out in a previous section. In any event, we encourage you to periodically review this privacy policy to understand how we protect your personal information.
If you have any questions about this policy, please do not hesitate to contact us at dpd@suissajoiers.com.
Last updated: 10 May 2022