Privacy Policy
SDV-Sociedade de Distribuição de Vestuário SA (CODE) recognises the importance of maintaining the confidentiality, integrity and security of your personal data ("Personal Data") and informs you that the Personal Data you provide to CODE through the website code.pt, as well as the Personal Data you provide in a Code store, will be processed in accordance with European privacy laws (Regulation (EU) 2016/679 – "GDPR") and national laws (Law No. 58/2019 of 8 August).
Type and source of data
Browsing data
The computer systems and software processes used in code.pt collect, during their normal operation, certain personal data (namely, log files). The transmission of such data is inherent to the use of internet communication protocols. Such information is not collected in order to be associated with data subjects, but due to its nature, it may allow users to be identified through the processing and integration of data held by third parties. This information includes the IP addresses and/or domain names of the computers used when you visit code.pt, URIs (Uniform Resource Identifiers) of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response issued by the server (completed, error, etc.) and other parameters relating to the user's operating system and computer environment. This data is used for the sole purpose of obtaining anonymous statistical information about your access to code.pt and for its proper functioning.
Cookies
The website code.pt uses cookies to ensure its efficiency and improve our services. Cookies are small files sent to your computer (usually to your browser) by the websites you visit on the internet. Cookies are stored on your computer so that they can be recognised by those websites on your subsequent visits. For more information about cookies, the types of cookies used on our website, how to disable them and how to withdraw your consent, please see our cookie policy.
Personal data voluntarily provided by the data subject
CODE collects and processes the Personal Data that you voluntarily provide on code.pt when you make an online purchase and/or register on code.pt and/or subscribe to our Newsletter and/or contact our Customer Service. In addition, when you voluntarily identify yourself on code.pt or send an email to apoioaocliente@code.pt, we collect your email address so that we can respond to any request, as well as any Personal Data contained in your message.
Purpose of processing
Your Personal Data will be processed as necessary for our services for the following purposes:
(a) responding to your requests and managing your relationship with CODE;
(b) executing the online purchase order and carrying out all management acts relating to the purchase (including administrative management of the contract, delivery of products, payment processing, handling of complaints and disputes and fraud prevention), as well as complying with applicable legislation and regulatory obligations.
With your prior consent, your Personal Data may be included in CODE's customer database and processed together with the details of your purchases, for the following purposes:
(c) profiling: carrying out individual or group studies, analyses and statistical and/or market research on your product preferences, so that we can offer a personalised service and promote cultural and recreational activities that may be of interest to you;
(d) marketing/sales: to promote CODE products, contact you and/or send you (by post, SMS, telephone, email and any other form of electronic communication) information and promotions, including commercial information, newsletters, advertising material and catalogues.
Processing methods
Your Personal Data will be processed by appropriate electronic or automated means and computerised tools, or manually and on paper, exclusively for the purpose for which it was collected, ensuring the security and confidentiality of all information processed. Your Personal Data will only be processed by CODE employees who are duly authorised to carry out processing in the performance of their duties. Your Personal Data may also be processed by third parties when necessary and/or decisive for the purposes described above. Third parties will act on behalf of CODE as subcontractors (for example, service providers, carriers, IT technicians or any other suppliers appointed by CODE to carry out and/or manage promotional campaigns for products and services, etc.).
Nature of the communication of personal data
The communication of your Personal Data is optional. However, if you wish to purchase products offered on code.pt and/or receive information about products and services and/or contact our Customer Service, you must fill in all mandatory fields of the applicable forms.
The processing of your Personal Data for the purposes set out in points (c) and (d) of no. 2 above is subject to your prior express consent. Refusing your consent may prevent us from offering a personalised service and informing you about activities that may interest you.
You may withdraw your consent to the processing of your Personal Data at any time by writing to SDV-Sociedade de Distribuição de Vestuário, SA, with registered office at Avenida 1º de Maio 1666, 4485-105, Fajozes, or by sending an email to dados.pessoais@code.pt, or by using the "unsubscribe" link included in all our promotional electronic communications, and/or by using any other appropriate procedure available.
Transfer and disclosure of data
Whenever necessary and/or decisive for the purposes set out above, your Personal Data may be processed by other entities acting as processors on behalf of CODE.
Under no circumstances will your Personal Data be used for advertising or for promoting products, services or initiatives of third-party entities outside the scope of code.pt, nor will it be disclosed to other entities.
Retention period
Your personal data will be processed and kept for as long as necessary to fulfil the purposes for which it was collected and in accordance with the retention period established by applicable legislation, or until your consent to its processing is withdrawn. After that period, your Personal Data will be automatically and permanently deleted or anonymised.
Data controller
The data controller is SDV-Sociedade de Distribuição de Vestuário, S.A. You may contact the Data Controller by writing to SDV-Sociedade de Distribuição de Vestuário, SA, with registered office at Avenida 1º de Maio 1666, 4485-105, Fajozes, or by sending an email to dados.pessoais@code.pt.
Rights of the data subject
Please note that you may exercise the rights provided for in articles 15 to 21 of the GDPR and, in particular, the right to request information about the processing of your Personal Data, as well as the right of access, rectification and erasure of your Personal Data, the right to object to processing and/or the right to transfer such Personal Data to another Data Controller, always within legal limits.
You also have the right to withdraw your consent at any time with regard to the purposes that depend on consent. Withdrawing your consent will not affect processing carried out on the basis of your consent given prior to withdrawal. You may also lodge a complaint with the Portuguese Data Protection Authority (Comissão Nacional de Protecção de Dados).
Contacts
Any request regarding your Personal Data, this Privacy Policy or how to exercise your rights may be made free of charge by contacting the Data Controller, through the contacts indicated in no. 7.
CODE reserves the right to modify this Privacy Policy at any time.
Notes on the Portuguese source text:
- The text refers to "n. 2" (purposes) and "n. 7" (contacts), but the sections have no numbers, so these references don't work as written. If the site numbers the sections, check that these two point to the right ones.
- The "Transfer and disclosure of data" section says data may be processed by third parties as processors, and then that it is never disclosed to other entities. It is consistent legally (processors vs. third parties), but the wording may be worth reviewing with your legal team.
- In the Portuguese text, "desativa-los" is missing an accent ("desativá-los") and "contato" appears alongside "contactos". I kept the English neutral.
- I translated "Comissão Nacional de Protecção de Dados" as "Portuguese Data Protection Authority" and kept the original name in brackets. The official name has since changed to "Comissão Nacional de Proteção de Dados", so you may want to update it in the source.
