PRIVACY POLICY

Last updated: 25 July 2026

1. Introduction

At Secondo Passo, we respect your privacy and are committed to handling your personal data carefully, transparently and securely.

This Privacy Policy explains what personal data we collect when you visit secondopasso.com, place an order, subscribe to our newsletter, contact our Concierge, submit a review, use our Trade-In service or otherwise interact with Secondo Passo.

It also explains why we process your personal data, how long we retain it, with whom it may be shared and what rights you have under applicable data protection laws, including the General Data Protection Regulation (GDPR).

2. Who Is Responsible for Your Personal Data?

Secondo Passo is responsible for the processing of personal data described in this Privacy Policy.

Business name: WW EZ
Trade name: Secondo Passo
Chamber of Commerce number: 88994511
Business location: The Hague, The Netherlands
Email: concierge@secondopasso.com

For questions about this Privacy Policy or the processing of your personal data, please contact us using the email address above.

3. Personal Data We Collect

Depending on how you interact with Secondo Passo, we may collect the following categories of personal data:

Identity and contact information

This may include:

• Your name
• Billing and delivery address
• Email address
• Telephone number
• Country or region
• Account information, where applicable

Order and transaction information

This may include:

• Products ordered
• Order number
• Purchase date
• Order value
• Payment status
• Shipping and delivery information
• Returns, refunds and customer-service history

Payment information

Payments are processed through Shopify and authorised payment service providers. Secondo Passo does not normally receive or store your complete payment-card details.

We may receive limited payment information, such as:

• Payment method
• Payment status
• Transaction reference
• The final digits of a payment card, where provided by the payment provider

Communications

When you contact our Concierge, communicate with us through WhatsApp, email, a contact form or social media, we may collect:

• Your contact details
• The contents of your message
• Product enquiries
• Sizing information or measurements you provide
• Photographs or documents you choose to send
• Our correspondence with you

Newsletter and marketing information

When you subscribe to our newsletter or agree to receive marketing communications, we may collect:

• Your name
• Email address
• Marketing preferences
• Subscription and unsubscribe history
• Interaction with marketing emails, where permitted and enabled

Trade-In information

When you use our Trade-In service, we may collect:

• Your name and contact details
• Information about the items you offer
• Brand, model, size and condition
• Photographs of the items
• Offer and valuation information
• Shipping and payment details
• Correspondence regarding the Trade-In request

Reviews

When you submit a review, we may collect:

• Your name or chosen display name
• Email address
• Order or transaction information used for verification
• Rating
• Review text
• Your consent or permission to publish the review

Your email address and order details will not be published as part of a review.

Technical and usage information

When you visit our website, certain information may be collected automatically, including:

• IP address
• Browser and device type
• Operating system
• Approximate location based on your IP address
• Pages visited
• Referral source
• Date and time of access
• Cookie identifiers
• Website interactions
• Shopping-cart and checkout activity

The collection of information through non-essential cookies or similar technologies is subject to your consent where required by law.

4. How We Collect Personal Data

We collect personal data:

• Directly from you when you place an order, contact us, create an account, subscribe to our newsletter, submit a review or use our Trade-In service
• Automatically when you use our website, through cookies, log files and similar technologies
• From service providers involved in payments, shipping, website hosting, fraud prevention, analytics or marketing
• From marketplaces or communication platforms when you contact or transact with us through those platforms
• From publicly available information where this is relevant and legally permitted

5. Why We Use Your Personal Data

We process personal data for the following purposes:

Processing and fulfilling orders

We use your information to:

• Process your order
• Accept and verify payments
• Arrange delivery
• Provide order updates
• Handle returns and refunds
• Provide customer service

Legal basis: performance of a contract and taking steps at your request before entering into a contract.

Customer service and Concierge enquiries

We use your information to answer questions, provide product information, assist with sizing, provide measurements and photographs, and resolve complaints.

Legal basis: performance of a contract, taking pre-contractual steps and our legitimate interest in providing effective customer service.

Trade-In requests

We use your information to assess products, provide offers, arrange shipping, process payments or trade-in credit, and communicate about your request.

Legal basis: taking steps at your request before entering into a contract and performance of a contract.

Accounting and legal obligations

We process and retain certain order, invoice, payment and transaction information to meet accounting, tax, administrative and other legal obligations.

Legal basis: compliance with a legal obligation.

Fraud prevention and security

We may use personal data to:

• Protect our website, business and customers
• Verify transactions
• Detect suspicious activity
• Prevent fraud, misuse or unauthorised access
• Establish, exercise or defend legal claims

Legal basis: our legitimate interests in protecting our business, customers and services, and compliance with legal obligations where applicable.

Improving our website and services

We may analyse how customers use our website to improve its functionality, navigation, product presentation, performance and customer experience.

Where this involves non-essential cookies or tracking technologies, we will request your consent where required.

Legal basis: your consent and, where permitted, our legitimate interest in improving our services.

Marketing and newsletters

We may send newsletters, product updates, restock alerts and promotional messages where you have subscribed or where this is otherwise permitted by law.

You can unsubscribe at any time by using the unsubscribe link in an email or by contacting us.

Legal basis: your consent or, where legally permitted, our legitimate interest in informing existing customers about relevant products and services.

Publishing reviews

We use submitted reviews to display customer experiences and improve trust in our services. We may verify that a review originates from a genuine customer or completed transaction before labelling it as verified.

Legal basis: your consent to publication and our legitimate interest in collecting genuine customer feedback.

6. Shopify

Our online store is hosted by Shopify. Shopify provides the ecommerce platform that enables us to display products, process orders, manage customers and operate our online store.

Depending on the Shopify services and settings we use, Shopify may process personal data as our service provider or processor. For certain enhanced services, Shopify may also process information for its own described purposes, subject to applicable privacy settings and customer consent choices.

Shopify and its affiliated companies may process personal data in countries outside the European Economic Area. Appropriate legal safeguards are used for these transfers as described in Section 10 of this Privacy Policy.

More information about Shopify's processing of personal data is available through Shopify's Consumer Privacy Policy and Privacy Portal.

7. Cookies and Similar Technologies

Secondo Passo and its service providers may use cookies and similar technologies.

Strictly necessary cookies

These cookies are required for the website to function and may be used for:

• Shopping-cart functionality
• Checkout
• Payment processing
• Security
• Fraud prevention
• Remembering privacy preferences

These cookies generally cannot be disabled through our cookie banner because the website cannot function properly without them.

Analytics cookies

With your consent, analytics cookies may help us understand:

• How visitors use the website
• Which pages are visited
• How customers navigate through the store
• Whether technical problems occur
• How the website can be improved

Marketing and advertising cookies

With your consent, marketing technologies may be used to:

• Measure advertising performance
• Understand whether advertisements result in visits or purchases
• Display more relevant advertisements
• Limit how often advertisements are shown

You can accept, reject or adjust non-essential cookies through the cookie preferences tool displayed on our website. You can change or withdraw your consent at any time through the same preferences tool.

Additional information about individual cookies, providers and retention periods should be displayed in the cookie preferences tool.

8. Who We Share Personal Data With

We only share personal data where this is necessary, legally required or otherwise permitted.

Recipients may include:

Shopify

For website hosting, order processing, customer administration, checkout, fraud prevention, analytics and other ecommerce functionality.

Payment service providers

For processing and verifying payments, refunds and chargebacks.

Shipping and logistics providers

For preparing, tracking and delivering orders or Trade-In shipments.

Email and communication providers

For sending transactional emails, customer-service messages and newsletters.

Analytics and advertising providers

Where enabled and subject to required consent, for measuring website usage and advertising performance.

Professional advisers

Such as accountants, bookkeepers, insurers, IT providers, legal advisers and other professional service providers.

Government authorities

Where disclosure is required by law, court order or a valid request from a competent authority.

Business transactions

If Secondo Passo or its activities are sold, transferred, reorganised or merged, relevant information may be disclosed to professional advisers and prospective buyers, subject to appropriate confidentiality and data-protection safeguards.

We do not sell personal data in the ordinary meaning of selling customer information in exchange for money.

9. Service Providers and Third-Party Platforms

Our website may contain integrations or links to third-party services, such as:

• Payment providers
• Delivery providers
• WhatsApp
• Social-media platforms
• Review services
• Google services
• Advertising platforms

When you choose to use or visit a third-party service, that organisation may process your personal data under its own privacy policy. Secondo Passo is not responsible for the privacy practices of independent third parties.

Where a third party processes personal data on our behalf, we take reasonable steps to ensure that appropriate contractual and security arrangements are in place.

10. International Transfers

Some of our service providers, including Shopify and certain technology, payment, communication, analytics or advertising providers, may process personal data outside the European Economic Area.

Where personal data is transferred to a country that has not been recognised as providing an adequate level of protection, we or our service providers use appropriate safeguards where required, such as:

• European Commission adequacy decisions
• Standard Contractual Clauses
• Data-processing agreements
• Additional technical and organisational safeguards

You may contact us for more information about the safeguards used for relevant international transfers.

11. How Long We Retain Personal Data

We do not retain personal data for longer than necessary for the purposes for which it was collected, unless a longer period is required by law.

The following general retention periods apply:

Order, invoice and accounting information

Generally retained for seven years to comply with Dutch tax and accounting obligations. A longer period, such as ten years, may apply where required under specific tax or cross-border VAT regulations.

Customer accounts

Retained while the account remains active and afterwards only for as long as necessary for legal, administrative, security or dispute-resolution purposes.

Customer-service and Concierge correspondence

Generally retained for up to two years after the enquiry has been resolved, unless the information relates to an order, complaint, legal claim or other matter requiring longer retention.

Trade-In requests

Unsuccessful or incomplete Trade-In enquiries are generally retained for up to two years after the last contact. Where a transaction is completed, relevant transaction and accounting information may be retained for the applicable statutory period.

Newsletter information

Retained until you unsubscribe or withdraw your consent. We may retain limited information demonstrating your unsubscribe request so that we can respect your preference.

Reviews

Published reviews may be retained for as long as they remain relevant to our services. Verification and contact information is retained only for as long as reasonably necessary to verify and manage the review.

Cookie and analytics information

Retained for the periods indicated in our cookie preferences tool or by the relevant service provider.

Fraud prevention and legal claims

Information may be retained for as long as reasonably necessary to prevent fraud, investigate suspicious activity or establish, exercise or defend legal claims.

12. How We Protect Personal Data

We use reasonable technical and organisational measures designed to protect personal data against:

• Loss
• Misuse
• Unauthorised access
• Unauthorised disclosure
• Alteration
• Destruction

These measures may include access controls, secure connections, password protection, limited staff access and the security measures provided by Shopify and our other service providers.

No method of electronic transmission or storage is completely secure. We therefore cannot guarantee absolute security, but we take appropriate steps to reduce foreseeable risks.

13. Your Privacy Rights

Subject to applicable law, you may have the right to:

Access

Request confirmation of whether we process your personal data and receive a copy of that data.

Correction

Ask us to correct inaccurate or incomplete personal data.

Deletion

Ask us to delete your personal data where there is no longer a lawful reason for retaining it.

Restriction

Ask us to temporarily restrict the processing of your personal data in certain circumstances.

Data portability

Receive personal data you provided to us in a structured, commonly used and machine-readable format, where legally applicable.

Object

Object to processing based on our legitimate interests, including certain forms of direct marketing.

Withdraw consent

Withdraw consent at any time where processing is based on consent. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.

Complain to a supervisory authority

You have the right to submit a complaint to the Dutch Data Protection Authority, the Autoriteit Persoonsgegevens, or another competent data-protection authority in your country of residence.

To exercise your rights, contact:

concierge@secondopasso.com

Please clearly state which right you wish to exercise. We may request additional information to verify your identity before processing your request.

We aim to respond within one month. In complex cases or where multiple requests are received, this period may be extended where permitted by law. We will inform you if an extension is necessary.

Some rights are not absolute. We may be legally required or otherwise entitled to retain certain information, for example for tax administration, fraud prevention or legal claims.

14. Marketing Preferences

You can unsubscribe from marketing emails at any time by:

• Clicking the unsubscribe link in an email
• Adjusting your customer preferences, where available
• Contacting concierge@secondopasso.com

After unsubscribing, you may still receive service-related communications, such as order confirmations, shipping updates, return information or responses to enquiries.

15. Automated Processing

We may use automated tools provided by Shopify, payment providers or security services to identify potential fraud, payment risks or suspicious activity.

We do not intend to make decisions based solely on automated processing that produce legal or similarly significant effects for customers without appropriate safeguards.

16. Children's Privacy

Our website and services are not directed at children under the age of 16.

We do not knowingly collect personal data from children. If you believe that a child has provided personal data to us, please contact us so that we can take appropriate action.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

• Changes to our services
• Changes to the Shopify platform or installed applications
• Changes to our data-processing practices
• Changes in legal or regulatory requirements

The latest version will always be published on this page. The date at the top of the Privacy Policy indicates when it was last updated.

Where required, we will provide additional notice of material changes.

18. Contact

For questions, requests or concerns about privacy or the use of your personal data, please contact:

Secondo Passo
Trade name of WW EZ
Chamber of Commerce number: 88994511
The Hague, The Netherlands

Email: concierge@secondopasso.com