PRIVACY POLICY
ÍNIDCE
1.- OUR COMMITMENT TO PRIVACY
2.-WHO ARE WE? WHO IS OUR DATA PROTECTION REPRESENTATIVE?
3.- PERSONAL DATA
4.- COLLECTION OF PERSONAL DATA AND PURPOSES OF PROCESSING
5.- PROFILING
6.- WHO CAN ACCESS YOUR PERSONAL DATA?
7.- INTERNATIONAL TRANSFERS
8.- HOW LONG DO WE KEEP YOUR PERSONAL DATA?
9.- IS MY PERSONAL DATA STORED SECURELY?
10.- LINKS TO THIRD PARTY SITES AND SOCIAL LOGIN
11.- SOCIAL MEDIA AND USER-GENERATED CONTENT
12.- YOUR RIGHTS AND OPTIONS
13.- CONTACT
1.- OUR COMMITMENT TO PRIVACY
VMV Cosmetic Group considers the protection of your personal data to be of vital importance. Therefore, in a clear and simple manner, with the utmost honesty and transparency, we have drawn up this privacy policy in which we will inform you of how we collect and process your data, in application of the current regulations on the protection of personal data.
This Privacy Policy sets out the basis on which we will VMV Cosmetic Group processes your personal data when you provide it to us during your experience through any of the following websites and/or mobile applications (hereinafter “Webs”):
We would like to remind you that each time that when using any of our Websites you provide us with or it is necessary for us to access any type of information that due to its characteristics allows us to identify you, such as your name and surname, e-mail, billing or delivery addresses, telephone number, type of device or debit or credit card number, etc. (hereinafter, “Personal Data”), whether to browse the same, buy our products or make use of its services or features, will be under the application of this Privacy Policy, along with the Terms of Use of the Web that you will find in the Legal Notice, and other documents referenced in the same in force at all times. This Privacy Policy may be modified at any time. Remember that it is your responsibility to read them periodically, as those in force at the time of use of any of the Webs will be applicable.
Please note that, in the field of distance selling, it is mandatory to provide certain personal information, as this information is necessary both to process and deliver your orders and to prepare your invoices. If you do not wish to provide your personal data, please note that we will not be able to complete the sale and purchase of the order.
Our commitment to privacy is always based on the following principles:
- We respect your privacy, choices and decisions.
- We ensure that privacy and security are built into everything we do.
- We will not send you marketing communications unless you expressly request it and you may change your mind at any time by notifying us.
- We will never offer or sell your personal data.
- We are committed to keeping your data safe and secure and are therefore committed to working with trusted partners who apply strict Data Protection policies.
- We are committed to being open, honest and transparent about our use of your data in a clear and simple way.
- We will only use your data for the purpose for which we have collected it and of which we have previously informed you.
- We respect your rights and will always try to accommodate your requests, as far as possible, in accordance with our own legal and operational responsibilities.
Below, we would like to inform you of the type of personal data we may collect or hold about you, how we may use it, with whom we may share it, how we protect it, and how you can exercise your rights in relation to that data.
When you share your Personal Data with us or when we collect Personal Data about you, we use it in accordance with this Privacy Policy (“Policy”).
Please read this Privacy Policy carefully. If you have any questions or concerns about your personal data, you can contact us whenever you need to by sending us an email at protecciondatos@grupovmv.com.
2.-WHO ARE WE? WHO IS OUR DATA PROTECTION REPRESENTATIVE?
VMV Cosmetic Group is made up of a group of companies, including the company that provides corporate services to the rest of the companies, which is called VMV GROUP DE SERVICIOS Y GESTION SL, with VAT number B62938584 and registered address in the municipality of Llissá de Vall, 08185 Barcelona, Spain, at P.I. Cantallops, Avenida Cantallops, s/n, which is the company responsible for the purposes of data protection regulations.
Our Data Protection Officer at VMV Cosmetic Group en:
Oscar Clavell
Plaza Víctor Martínez s/n
Lliçà de Vall
08185 Barcelona
Spain
Contact e-mail: protecciondatos@grupovmv.com
You can consult all the brands that form part of the VMV Cosmetic Group by clicking here.
3.-PERSONAL DATA
It is understood that Personal Data any information that can identify you directly (e.g. your name and/or surname) or indirectly (e.g. your ID number).. Personal Data includes information such as email / home address / mobile phone, user names, profile pictures, personal preferences and shopping habits, user-generated content and financial information and social welfare information, among others. It may also include unique numeric identifiers such as the IP address of your computer or the MAC address of your mobile device, as well as certain information obtained through cookies.
This Policy covers all personal data collected and used by VMV Cosmetic Group. The specific data processed will depend on the services used at any given time, as detailed in this Policy.
4.- COLLECTION OF PERSONAL DATA AND PURPOSES OF PROCESSING
Remember that before you start using any of our services or functionalities you should read this Privacy Policy, as well as the Terms of Use of the specific section on that service and/or functionality. In that section you will be able to see if there are any particular conditions for its use, or if a specific treatment of your Personal Data is required. Failure to provide certain information marked as mandatory may mean that it is not possible to manage your registration as a user or the use of certain features or services available through the Webs.
Remember that you must always ensure that the Personal Data provided is true and accurate and that you undertake to notify us of any changes or modifications to the Personal Data.
Any loss or damage caused to the Websites, the Data Controllers or any third party through the communication of erroneous, inaccurate or incomplete information in the registration forms will be your responsibility.
4.1. What data do we collect from you?
VMV Cosmetic Group believes that you are the very heart of what we do. We love getting to know you, learning and creating, and delivering products and services you can enjoy, so we are constantly talking and interacting with you. That's why there are many and varied ways in which we can collect your data.
Thus, we may collect or receive your data through our websites, forms, apps, devices, products and/or social media brand pages. In some cases, you will provide us with Personal Data directly (e.g. when you create an account, when you contact us, when you shop on our websites/apps or in our stores/beauty salons) and in other cases, we collect it (e.g. by using cookies to see how you interact with us). We also sometimes receive your data from other third parties.
To make it easier and clearer for you, here is a table in which you can identify in a concise, transparent and easily accessible way:
1) For what purposes may we use your Personal Data? In this column we explain what we may do with your Personal Data and the purposes for collecting it.
2) What is the legal basis for using your Personal Data? In this column we explain why we may use your Personal Data.
Although you will find more specific information in the table below, the legal basis for the processing of your Personal Data, depending on the scenario in which it was collected, may be:
- Your explicitly given consent;
- Our legitimate interest, which includes:
(i) Conducting statistics to help us better understand your needs and expectations and thereby improve our services, websites/applications/devices, products and brands.
(ii) To enable the operation of our website/applications through technical and functional cookies that allow us to keep our tools (websites/applications/devices) safe and secure and to ensure that they work properly.
(iii) Profiling and statistics for the personalised sending of commercial communications.
(iv) To provide you with our customer service.
(v) The performance of a contract: to perform the services you request from us.
(vi) Compliance with legal obligations involving the processing of your personal data.
When we collect your Personal Data, we always indicate fields that are mandatory by means of asterisks. The data we ask you for is necessary for, as the case may be:
(i) To perform our contract with you (for example, to deliver the products you have purchased on our websites to the address you have provided);
(ii) To provide you with the service you have requested from us (for example, to provide you with a newsletter);
(iii) Comply with legal requirements (e.g. to make the invoice).
3) What Personal Data may we collect about you? In this column we explain what types of Personal Data we may collect about you depending on the scenario we are in.
4) In which scenario may your Personal Data be collected? In this column we explain what activity or scenario you are in when we use or collect your Personal Data.
5) Who can have access to your Personal Data? In this column we explain which third parties may have access to your Personal Data.
For what purposes may we use your Personal Data?
| What is the purpose of the processing? | What is the legal basis for processing your personal data? | What personal data may we collect about you? | In which scenarios may your personal data be collected? | Who can have access to your personal data? |
| Sending of commercial and promotional communications including: (i) Sending you marketing and communication communications; (ii) Sending you invitations to events; (iii) Sending you product samples; (iv) Promoting our products; (v) Offering you personalised services based on your beauty characteristics; (vi) Showing you advertisements on our websites to give you a more personalised experience when you visit us.
We may also show you online advertisements about products that may interest you, based on how you have browsed in the past; (vii) Show you advertisements and content on your social networks; (viii) Create a profile of your tastes and interests, to tailor communications and advertisements. |
Your Consent | (i) First and last name; (ii) Gender; (iii) E-mail address; (iv) Postal address; (v) Telephone number; (vi) Photo; (vii) Date of birth or age range; (viii) Nationality;
(ix) ID, user name and password; (x) Personal description or preferences; (xi) Order details; (xii) Social media profile; (xiii) Other information you share with us, such as photos or reviews, skin or hair type, questions from our social media profiles, websites and/or apps, available on some websites/apps or by participating in a contest, game or survey; (xiv) Purchase history information, including information about transactions. |
(i) Account creation and management; (ii) Newsletter subscription form; (iii) Registration or subscription to games, promotions, offers, surveys, etc.; (iv) When requesting and/or placing an order through any of our sales channels; (v) In our hairdressing salons and beauty centres; (vi) In our Academy; (vii) In our wig and hair extensions sales centres;
(viii) From the contact form on the website or from comments posted on our blogs and social networks. |
(i) Your personal data may be disclosed to the companies that are part of the VMV Cosmetic Group,which are clearly and simply identified in the second section of this policy (Who we are); and (ii) third party service providers who help us provide IT services, such as platform providers, hosting, maintenance and support services on our databases, as well as on our software and applications that may contain data about you; (iii) advertising, marketing, digital media and social media agencies who help us to show you campaigns and advertisements, analyse how effective they are, and manage contact with you and respond to your enquiries;
(iv) Third parties that help us provide digital and e-commerce services such as social listening, shop locator, loyalty programs, identity management, ratings and reviews, CRM, web analytics and search engine; (v) Also, when we use Google's advertising services on our websites or apps, some of your data may be shared with Google LLC, located at 1600 Amphitheatre Parkway, Mountain View, California 94043 (USA). This is done under an agreement between both parties (us and Google), which you can view here. This processing is only carried out if you give us your consent. If you would like to know more about how Google uses your personal data for advertising purposes, we recommend that you review their Privacy Policy. In addition, this international transfer of data is protected by the standard contractual clauses approved by the European Commission, ensuring that your data is secure. We also work with advertising services offered by Meta Platforms Ireland Limited (Meta Ireland), so your data may also be shared with them. Meta is located at Block J, Serpentine Avenue, Dublin 4, Ireland. In this case, both VMV Cosmetic Group As Meta we share the responsibility for the processing of your data, This means that we are both responsible for how that data is used. Within this agreement, Meta is in charge of guaranteeing their data protection rights, such as:
Thanks to this partnership with Meta, we can show you advertisements that are more relevant and tailored to your interests. If you would like more information about how Meta handles your personal data or how to exercise your rights in relation to it, you can consult its Privacy Policy and Joint Processing Conditions. Finally, we also work with advertising services offered by TikTok Technology Limited (TikTok Ireland), Your data may also be shared with that entity. In this case, both VMV Cosmetic Group as TikTok we share responsibility (co-responsibility) for the processing of your personal data, which means that we are both responsible for how that data is collected and used. Within this co-responsibility agreement, TikTok is responsible for guaranteeing your data protection rights, such as:
Through this partnership with TikTok, we are able to show you more relevant and personalised ads tailored to your interests. If you would like more information about how TikTok handles your personal data or how to exercise your rights in relation to them, you can consult your Privacy Policy. |
| What is the purpose of the processing? | What is the legal basis for processing your personal data? | What personal data may we collect about you? | In which scenarios may your personal data be collected? | Who can have access to your personal data? |
| Management of the contractual relationship including:
(i) Managing your orders. (ii) Sending orders to the address you have indicated. (iii) Answering your questions and interacting with you. (iv) Contacting you to indicate the steps to follow to finalise the order when the shopping cart has been saved without finalising the payment process. (v) Informing you of the availability of a product. (vi) Processing and following up on your orders. (vii) Manage the payment of your orders. (viii) Loyalty programmes for VMV Cosmetic Group. (ix) Handle any incident related to a purchase. (x) Measure your satisfaction with the entire purchasing process. (xi) Manage your participation in contests, games and surveys. (xii) Publish their criticisms and/or comments. (xiii) Provide you with the requested service (e.g. testing our products). (xiv) Show you to your nearest shop |
Fulfilment of the contractual relationship: maintenance, fulfilment, development, control and execution of the contractual relationship established with you. | (i) First name and surname (ii) Gender (iii) E-mail address (iv) Postal address (v) Telephone number (vi) Photo
(vii) Date of birth or age range (viii) ID, user name and password. (ix) Personal description or preferences (x) Order details (xi) Location/ Geolocation (xii) Other information you share with us, such as skin and/or hair type, etc. (xiii) Transaction information, including products purchased. (xiv) History of your purchases. (xv) The information requested in the payment gateway (credit card number, pay pal information,...). The payment information is not collected by us, but by the payment service provider. (xvi) Academic record, financial data for the award of study grants. |
(i) Account creation and management (ii) information that may have been provided during the purchase process through our websites/applications/social networks or online shop (iii) Newsletter subscription form (iv) Registration or subscription to games, contests, promotions, offers, surveys... (v) When requesting and/or ordering an order/service through any of our sales channels.
(vi) Registration for our courses, conferences, seminars, galas and other organised events. |
(i) Your personal data may be disclosed to the companies that are part of the VMV Cosmetic Group which are clearly and simply identified in the second section of this policy (Who we are); and (ii) to third party service providers who help us provide IT services, such as platform providers, hosting, maintenance and support services on our databases, as well as on our software and applications that may contain data about you. (iii) third parties who help us provide digital and e-commerce services such as social listening, shop locator, loyalty programs, identity management, ratings and reviews, CRM, web analytics and search engine services. |
| What is the purpose of the processing? | What is the legal basis for processing your personal data? | What personal data may we collect about you? | In which scenarios may your personal data be collected? | Who can have access to your personal data? |
| Basic classification for:
(i) To improve our websites/applications; (ii) To enrich your profile if you make a purchase using your account information; (iii) To monitor and improve our applications and devices; (iv) To analyse your wellness characteristics and recommend appropriate products (including tailored products) and routines to you; (v) For reporting and statistical purposes; (vi) To know how users react to our advertising campaigns; (vii) To improve our offers; (viii) To find out how you discovered our websites/applications. |
To ensure that our websites/applications remain secure, to help us better understand your needs and expectations and thereby improve our services, products and brands. Also, to help us better understand our customers' needs and expectations and therefore improve our services, products and brands. | (i) First name and surname (ii) Gender (iii) E-mail address and telephone number (iv) Postal address (v) Telephone number (vi) Picture
(vii) Date of birth or age range (viii) ID, user name and password (ix) Personal description or preferences (x) Order details (xi) Location/ Geolocation (xii) Personal description or other information you share with us, such as skin and/or hair type, etc; (xiii) Transaction information, including products purchased; (xiv) History of your purchases. |
(i) Account creation and management (ii) Subscription form for newsletters or bulletins (iii) Registration or subscription to games, competitions, promotions, offers, surveys, etc. (iv) When requesting and/or placing an order through any of our sales channels. | (i) Your personal data may be disclosed to the companies that are part of the VMV Cosmetic Group which are clearly and simply identified in the second section of this policy (Who we are); and (ii) third party service providers who help us provide IT services, such as platform providers, hosting, maintenance and support services on our databases, as well as on our software and applications that may contain data about you. (iii) advertising, marketing, digital media and social media agencies who help us to show you campaigns and advertisements, analyse how effective they are, and manage contact with you and respond to your enquiries.
(iv) Third parties that help us provide digital and e-commerce services such as social listening, shop locator, loyalty programmes, identity management, ratings and reviews, CRM, web analytics and search engine. |
| What is the purpose of the processing? | What is the legal basis for processing your personal data? | What personal data may we collect about you? | In which scenarios may your personal data be collected? | Who can have access to your personal data? |
| Maintenance of up-to-date suppression lists to avoid being contacted if you request it. | The GDPR enables us to keep your details on a suppression list if you have asked us not to send you any further marketing communications. | (i) First and last name (ii) Email address (iii) Social media profile (when you use the login or share this personal information with us). | Subscription to newsletters and commercial communications. | (i) Your personal data may be disclosed to the companies that are part of the VMV Cosmetic Group which are clearly and simply identified in the second section of this policy (Who we are); and (ii) third party service providers who help us provide IT services, such as platform providers, hosting, maintenance and support services on our databases, as well as on our software and applications that may contain data about you. (iii) advertising, marketing, digital media and social media agencies who help us to show you campaigns and advertisements, analyse how effective they are, and manage contact with you and respond to your enquiries.
(iv) Third parties that help us provide digital and e-commerce services such as social listening, shop locator, loyalty programmes, identity management, ratings and reviews, CRM, web analytics and search engine. |
| What is the purpose of the processing? | What is the legal basis for processing your personal data? | What personal data may we collect about you? | In which scenarios may your personal data be collected? | Who can have access to your personal data? |
| To enable the operation of our website/applications through technical and functional cookies. (i) Appropriate display of content; (ii) Creating and remembering your login; (iii) Interface customisation, such as language; (iv) Enhancing our websites/applications; (v) Ensuring that the website or application is safe and secure;
(vi) Prevent visitors' data from being saved twice; (vii) Enable sharing of our content on social networks (share buttons to display the site); (viii) Analyse your wellness characteristics and recommend appropriate products (including tailor-made products) and routines.
|
Ensure that we provide you with websites/applications, which function correctly, securely and continuously improve your perception. | (i) Data relating to your use of applications or websites; (ii) Data relating to the website from which you came; (iii) Registration details; (iv) Pages and videos you have visited; (v) Advertisements you click on; (vi) Products you search for;
(vii) Location; (viii) Duration of your visit; (ix) Products you have selected to create your basket; (x) IP address; (xi) Browser information; (xii) Device information; (xiii) Unique identifier for each visitor; (xiv) Gender; (xv) Interests; general; (xvii) Number of sessions per user; (xviii) Behavioural flow during your browsing (e.g. which pages you have visited in a single session). |
Information collected through cookies or similar technologies as part of your browsing on the websites/applications of VMV Cosmetic Group. For more information about Cookies, please see our Cookie Policy. | (i) Your personal data may be disclosed to the companies that are part of the VMV Cosmetic Group which are clearly and simply identified in the second section of this policy (Who we are); and (ii) to third party service providers who help us provide IT services, such as platform providers, hosting, maintenance and support services on our databases, as well as on our software and applications that may contain data about you; (iii) third parties who help us provide digital and e-commerce services such as social listening, shop locator, loyalty programs, identity management, ratings and reviews, CRM, web analytics and search engine. |
| What is the purpose of the processing? | What is the legal basis for processing your personal data? | What personal data may we collect about you? | In which scenarios may your personal data be collected? | Who can have access to your personal data? |
| Profiling and statistics for the personalised sending of commercial communications. (i) Show you online advertisements for products that may be of interest to you, based on your past behaviour; (ii) Show you advertisements and content on social media platforms; (iii) Create and remember your shopping cart; (iv) Send you recommendations, marketing or content based on your profile and interests; (v) offering enhanced personalisation when you visit our website, remembering aspects such as language, or location; (vi) remembering your movements between web pages so as not to ask you again for information that has already been provided; (vii) personalising advertisements on third party websites you visit, about products and services from companies that are part of VMV Cosmetic Group, (viii) To enable and facilitate the measurement of the performance of our advertising campaigns; (ix) To improve the profile we have of you; (x) To be able to count the number of visits and traffic sources in order to measure and improve the performance of our website. | Your consent | (i) Data related to the use of applications or websites; (ii) Data related to the website you came from; (iii) Pages and videos you visited; (iv) Advertisements you clicked on; (v) Products you searched for; (vi) Location;
(vii) Duration of your visit. (viii) Products you have selected to create your basket. (ix) IP address (x) Browser information. (xi) Device information. (xii) Unique identifier for each visitor. (xiii) Behavioural flow during your browsing (e.g. which pages you have visited in a single session). (xiv) Gender. |
Information collected through cookies or similar technologies as part of your browsing on the websites/applications of VMV Cosmetic Group. For more information about Cookies, please see our Cookie Policy. | (i) Your personal data may be disclosed to the companies that are part of the VMV Cosmetic Group which are clearly and simply identified in the second section of this policy (Who we are); and (ii) to third party service providers who help us provide IT services, such as platform providers, hosting, maintenance and support services on our databases, as well as on our software and applications that may contain data about you.(iii) third parties who help us provide digital and e-commerce services such as social listening, shop locator, loyalty programs, identity management, ratings and reviews, CRM, web analytics and search engine services. |
| What is the purpose of the processing? | What is the legal basis for processing your personal data? | What personal data may we collect about you? | In which scenarios may your personal data be collected? | Who can have access to your personal data? |
| To offer you our customer service (i) Respond to questions you may ask us through our websites/applications, social media, email and chats. | To respond to your requests and questions regarding our products and services. | (i) First and last name; (ii) Telephone number, postal address and e-mail address; (iii) Other information you may share with us at the time of your enquiry. | Information collected when you contact us with questions, or when you respond to surveys about issues relating to the products of VMV Cosmetic Group and its use. | (i) Your personal data may be disclosed to the companies that are part of the VMV Cosmetic Group which are clearly and simply identified in the second section of this policy (Who we are); and (ii) to third party service providers who help us provide IT services, such as platform providers, hosting, maintenance and support services on our databases, as well as on our software and applications that may contain data about you.(iii) third parties who help us provide digital and e-commerce services such as social listening, shop locator, loyalty programs, identity management, ratings and reviews, CRM, web analytics and search engine services. |
| What is the purpose of the processing? | What is the legal basis for processing your personal data? | What personal data may we collect about you? | In which scenarios may your personal data be collected? | Who can have access to your personal data? |
| Statistical realisation (i) Generating statistical analyses; (ii) Evaluation of user response to our advertising campaigns; (iii) optimisation of our promotions and offers; (iv) identification of how users find our website. | In order to better understand the needs and expectations of our customers, so that we can improve our services, products and brands. | (i) Name and surname; (ii) Gender; (iii) E-mail address and telephone number; (iv) Postal address (delivery and billing); (vi) Photo;
(vii) Date of birth or age range; (viii) nationality; (ix) ID, user name and password; (x) Personal description or preferences; (xi) Order details; (xii) Location/ Geolocation; (xiii) Personal description or other information that you share with us, such as skin and/or hair type, etc.; (xiv) Transaction information, including products purchased; (xv) History of your purchases; (xvi) Social media profiles (where used for login or sharing such information); (xvii) web pages visited; (xviii) videos viewed; (xix) advertisements you clicked on; (xx) products you are looking for; (xxi) duration of your browsing on our website; (xxii) products selected for your basket; (xxiii) other information you may share with us at the time of enquiry. |
Information collected when you contact us with questions, or when you respond to surveys about issues relating to the products of VMV Cosmetic Group and its use. | (i) Your personal data may be disclosed to the companies that are part of the VMV Cosmetic Group which are clearly and simply identified in the second section of this policy (Who we are); and (ii) to third party service providers who help us provide IT services, such as platform providers, hosting, maintenance and support services on our databases, as well as on our software and applications that may contain data about you.(iii) third parties who help us provide digital and e-commerce services such as social listening, shop locator, loyalty programs, identity management, ratings and reviews, CRM, web analytics and search engine services. |
4.2. Do we process data of minors?
Our products are not intended for use by minors.
However, if you are under 16 years of age and wish to register on our website or make a purchase, you must have prior permission from your parent, guardian or legal representative.
Likewise, if you share images on our social networks showing children under the age of 16, it is your responsibility to ensure that you have obtained prior authorisation from their parents or legal guardians.
VMV Cosmetic Group reserves the right to ask you at any time for proof of such authorisation.
5.- PROFILING
When we send or display personalised communications or content, we may use certain techniques called or qualified as “profiling” (i.e. any form of automated processing of personal data that consists of using such data to evaluate certain personal aspects of an individual, in particular to analyse or predict aspects related to that individual's personal preferences, interests, financial situation, behaviour, location, reliability or movements). With this technique we can centralise the information and analyse it to assess and predict your personal preferences and/or interests. Once the analysis is done, we send or display communications and/or content tailored to your interests/needs and/or tastes.
This means that we may collect personal data about you in the various situations described above (such as when you create an online account, purchase one of our products, subscribe to our newsletter or browse our websites). We may also receive personal information about you from our business partners, provided that you have consented to this.
Once collected, this data can be centralised and pseudonymised (i.e. we replace your personal data with a unique identifier) for analysis to understand and anticipate your personal preferences and interests.
On the basis of this analysis:
- We send you personalised promotional communications, where you have given your consent.
- We display advertisements tailored to your interests, both on our websites and on third-party websites, including those of brands you have not yet interacted with directly.
- We also use your data to identify other people with similar characteristics within our database, in order to show them advertising that may be of interest to them.
Please note: in order to show you personalised advertising on third party sites, we need to share some of your identifying information (such as first name, last name and contact details) with them, in encrypted form. This allows them to locate your profile among their users and to display advertisements about our products and services to you and to users with similar profiles.
In certain activities, we work together with these third parties as joint data controllers, as explained above.
These partners also provide us with reports with aggregated, non-identifiable information on the performance of our advertising campaigns, which allows us to continuously improve them.
Such profiling and the use of your data for advertising purposes will only take place if you have given us your prior consent.
We remind you that you can always object to the processing of your personal data on the basis of profiling. Please see the section “Your rights and options” below.
6.- WHO CAN ACCESS YOUR PERSONAL DATA?
(i) We share your personal data between the companies that form part of the VMV Cosmetic Group
As mentioned in the table above in the column “Who/whom may have access to your Personal Data”, your data may be disclosed/shared with any of the companies that are part of the VMV Cosmetic Group, which are clearly and simply identified in the second section of this policy and always under the obligation to keep your details on a suppression list in case you ask us not to receive any further commercial communications.
(ii) Your personal data may also be processed by our trusted third party providers.
We contract with trusted third parties to perform a variety of business operations on our behalf. We only provide them with the essential information they need to perform the service, and we require them not to use your personal information for any other purpose. Please note that we always make our best efforts to ensure that all third parties we work with maintain the security of your personal data by signing rigorous data protection contracts.
Remember to refer to the table above, in which, in the form of a simple and clear, In the column “Who may have access to your Personal Data” you can find out which categories of third party service providers require access to your personal data.
(iii) Possibility to share your data with our business partners
We may share your personal data with search engines and social networks of which you are a user for the purposes of targeted advertising. As mentioned in the section on profiling, and subject to your consent, we may share with these platforms the personal information you have provided to us (such as your first name, last name, gender, email address, telephone number, postcode, city and date of birth).
These platforms include social networks such as Meta Platforms Ireland Limited (owner of Facebook and Instagram), based at Block J, Serpentine Avenue, Dublin 4, Ireland, and TikTok Technology Limited, located at 0 Earlsfort Terrace, Dublin, D02 T380, Ireland. Search engines such as Google LLC, located at 1600 Amphitheatre Parkway, Mountain View, California 94043, USA, or other platforms such as Amazon Europe Core Sarl, located at 38 avenue John F. Kennedy, L-1855, Luxembourg, among others, may also be included.
The purpose of this data exchange is to identify your profile on these platforms and to show you, as well as people with similar characteristics, advertisements related to our products and services, tailored to your interests.
It should be noted that this data sharing does not mean that our partners directly access information that fully identifies you (such as your full name or postcode). Instead, the data is shared in a pseudonymised form, which means that it does not allow direct identification.
In other situations, the information shared is aggregated, anonymous data, which we and our partners use to create groups of users (audiences) with common characteristics (such as geographic area or age range) to better target our advertising campaigns.
In certain activities, we share responsibility for data processing with these companies, as detailed in the table above.
Remember that you can rest assured that never, We will not, under any circumstances, offer or sell your personal data to third parties.
7.- INTERNATIONAL TRANSFERS
In VMV Cosmetic Group we undertake that your Personal Data will not be transferred or stored outside the European Economic Area (“EEA”), unless it is strictly necessary for the provision of a service or functionality requested.
In certain cases, technology providers such as Google LLC (1600 Amphitheatre Parkway, Mountain View, California 94043, USA) or Meta Platforms, Inc. (1 Hacker Way, Menlo Park, California 94025, USA) may access your data when you agree to use their advertising or analytics services.
These international transfers are carried out under adequate safeguards, in particular through the application of the Standard Contractual Clauses approved by the European Commission and, where appropriate, the accession of these suppliers to the EU-US Data Privacy Framework (Commission adequacy decision of 10 July 2023).
You may at any time request additional information about these warranties or a copy of these warranties by writing to us at protecciondatos@grupovmv.com.
8.- HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We only keep your Personal Data for as long as we need it and for the purpose for which we have collected it., to meet your needs or to comply with our legal obligations.
To determine the data retention period of your Personal Data, we use the following criteria:
| Data type | Retention period of your Personal Data |
| Personal Data obtained when purchasing our products and services. | For the duration of our contractual relationship, and for a period of 5 years after the end of the contractual relationship. |
| Personal Data obtained by participating in a promotion, contest or sweepstakes. | For the duration of the promotional offer, contest and/or sweepstakes, and for a period of 1 year from the end of the promotional offer, contest and/or sweepstakes. |
| Personal Data obtained when contacting us for an enquiry. | For as long as it takes to deal with your query, and for a period of 1 year from the resolution of the query. |
| Personal Data obtained when creating an account. | Until you cancel the subscription and/or demand that we delete it, and for a period of 5 years after the end of your activity. |
| Personal Data obtained by giving your consent to receive commercial communications and Newsletters. | Until you unsubscribe and/or request that we delete it, and for a period of 5 years after such request. |
| Personal Data obtained when you consent to receive advertising tailored to your interests while browsing third party websites. | Until you withdraw your consent and/or request that we delete it, and for a period of 5 years thereafter. |
| Cookies that are installed on your computer. | As long as necessary to achieve its purposes (e.g. during a session for shopping cart cookies or session ID cookies) and always for a maximum of 365 days. |
| Personal Data collected for statistical analysis | Until you withdraw your consent and/or request that we delete it, and for a period of 5 years after such a request. |
Notwithstanding the above, please note that we may retain some personal data to comply with our legal or regulatory obligations, as well as to administer our rights (e.g. to enforce our claims in court) or for statistical or historical purposes.
Once we no longer need to use your personal data, we will either delete it from our systems and records or anonymise the information so that it cannot be associated with your identity.
9.- IS MY PERSONAL DATA STORED SECURELY?
We are committed to protecting your Personal Data and to taking all reasonable precautions to do so. We contractually require trusted third parties who handle your Personal Data to do the same.
We always use our best efforts to protect your Personal Data and once we have received your personal information, we use strict procedures and security features to try to prevent unauthorised access. As the transmission of information via the internet is not completely secure, we cannot guarantee the security of your data transmitted to our site. Therefore, you should always bear in mind that any transmission is always at your own risk.
- LINKS TO THIRD PARTY SITES AND SOCIAL LOGIN
Our websites and applications may contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and are outside our control, for which we cannot be responsible. You should always check their policies before you submit any personal data to these websites.
We may also on certain occasions offer you the opportunity to use your social media login to register. If you do so, please note that you share your social profile information with us. The personal data shared depends on the settings of your social media platform. Please visit the social media platform in question and review its privacy policy to understand how it is shared and how it is used.
11.- SOCIAL MEDIA AND USER-GENERATED CONTENT
Some of our websites and apps allow users to submit their own content. Please remember that any content submitted to one of our social media platforms may be viewed by the public, so you should take care when providing certain personal data (e.g. financial information or address details).
Please note that these platforms are beyond our control, so we can never be held responsible for their treatment of your personal data. Always remember to read their policies before sharing your personal data.
12.- YOUR RIGHTS AND OPTIONS
VMV Cosmetic Group has established a strict policy of privacy and treatment of your Personal Data. Remember that it is very important that you are always in control of your personal data. For this reason, we would like to remind you of your rights:
(i) Right to information
You have the right to obtain clear, transparent, intelligible and easy to understand information about how we use your personal data and about your rights. You can find all this information in this policy. And remember, if you have any questions, you can contact us easily by sending an email to protecciondatos@grupovmv.com.
(ii) Right of access
You have the right to access all personal data that we hold about you. However, please note that manifestly unfounded, excessive or repetitive requests may not be granted.
To exercise this right, you can contact us by sending an email to protecciondatos@grupovmv.com.
(iii) Right of rectification
You have the right to have your personal data rectified if they are inaccurate or no longer valid or to have them completed if they are incomplete.
To exercise this right, please contact us by sending an e-mail to protecciondatos@grupovmv.com. Do not forget to indicate who you are.
(iv) Right to erasure/right to be forgotten
You have the right to have your personal data erased or deleted. However, it should be noted that this is not an absolute right, as it will sometimes be necessary for legal and/or legitimate reasons to keep it.
To exercise this right, please contact us by sending an e-mail to protecciondatos@grupovmv.com.
(v) Right to object to direct marketing, including profiling.
You may unsubscribe from our marketing communications and/or the sending of commercial communications at any time.
The easiest way to do this is to click on the “Unsubscribe” link in any email or communication we have sent you. You can also exercise this right by sending an email to protecciondatos@grupovmv.com.
(vi) The right to withdraw consent at any time where the data processing is based on their consent.
You may withdraw your consent to the processing of your personal data at any time.
You can see in which cases the processing is based on your consent in the table under “What data do we collect from you” in the column “What is the lawful basis for processing your Personal Data”.
Withdrawal of consent will not affect the lawfulness of the processing of your Personal Data prior to such withdrawal.
If you wish to withdraw your consent, you can easily do so by sending an e-mail to the following address protecciondatos@grupovmv.com.
(vii) The right to object to processing on the grounds of legitimate interests.
You can object to our processing of your data at any time where the processing is based on the satisfaction of legitimate interests. To inform you about cases where processing is based on legitimate interests, simply refer to the table under “What data do we collect from you” in the column “What is the lawful basis for processing your Personal Data?.
If you wish to exercise this right, you can easily do so by sending us an e-mail to the following address protecciondatos@grupovmv.com.
(viii) It has Right to lodge a complaint with a supervisory authority
You have the right at any time to complain to the Spanish Data Protection Agency about the privacy and data protection practices of VMV Cosmetic Group.
Please do not hesitate to contact us for any questions and/or clarifications you may have. You can do so by sending us an e-mail to the following address protecciondatos@grupovmv.com.
(ix) Right to data portability
You have the right to move, copy or transfer data from our database to another database.
You may only exercise this right in respect of data which you have provided, where the processing is based on the performance of a contract or on your consent and the processing is carried out by automated means.
To inform you of cases where the processing is based on a contract or consent, please refer to the table under “What data do we collect from you” in the column “What is the lawful basis for processing your Personal Data”.
Remember that you can send us an e-mail to the following address protecciondatos@grupovmv.com if you have any questions.
(x) Right to restriction of processing
You have the right at any time to request the restriction of the processing of your data. If you exercise this right, the processing of your data will be subject to limitations, so we may store it, but we may no longer use or process it.
This right can only be exercised in certain circumstances provided for in the General Data Protection Regulation. When:
- The data subject challenges the accuracy of the personal data, during the period of time that allows the controller to verify the accuracy of the data;
- The processing is unlawful and the data subject objects to the erasure of the personal data and requests instead the restriction of their use;
- The controller no longer needs the personal data for the purposes of the processing but the data subject needs them for the purposes of making, exercising or defending claims;
- The data subject has objected to the processing pursuant to Article 21(1) while it is being verified whether the legitimate grounds of the controller outweigh those of the data subject.
If you wish to exercise this right, you can easily do so by sending us an e-mail to the following address protecciondatos@grupovmv.com.
(xi) Right to deactivate Cookies
You have the right to disable Cookies. Internet browsers are usually set by default to accept Cookies, but they can be easily disabled by changing the browser settings.
Many cookies are used to improve the usability or functionality of websites/applications; therefore, disabling cookies may prevent you from using certain parts of our websites/applications as outlined in the Cookie Policy.
If you wish to limit or block all cookies set on our websites/applications, you can easily do so through your browser settings. If you would like to find out how, simply go to our Cookie Policy.
We can also help you by sending an email to the following address protecciondatos@grupovmv.com.
(xii) The right not to be subject to automated decisions
You have the right not to be subject to a decision based solely on automated processing of your personal data, including profiling, which produces legal effects concerning you or similarly significantly affects you.
This right shall not apply where:
- The decision is necessary for the conclusion or performance of a contract.
- The decision is authorised by the applicable Union or Member State law, provided that appropriate measures are in place to safeguard their rights, freedoms and legitimate interests.
- The decision is based on their explicit consent.
13.- CONTACT
Remember that we will be happy to help you. If you have any questions or concerns about how we process and use your personal data or wish to exercise any of the rights described above, you can do so in the way that is most convenient and simple for you:
- By sending us an e-mail to the following address protecciondatos@grupovmv.com.
- Or you can write to us at the address Plaza Víctor Martínez s/n, P.I. Cantallops, Lliçà de Vall (Barcelona - 08185)
14.- COMPLAINTS CHANNEL VMV COSMETIC GROUP
We would like to inform you about the existence of our whistleblowing channel. The Whistleblowing Channel is an essential part of the VMV Cosmetic Group's compliance system, as one of the processes established to ensure the effective application of the regulations and guidelines of the Code of Ethics and Conduct.
The channel is also a means to help employees, customers, suppliers and other third parties to report, anonymously and confidentially, any breaches of the Code of Conduct and/or applicable laws that they observe.
The Compliance Department will handle complaints received diligently and promptly, promoting their verification and promoting measures for their resolution. All information will be analysed objectively, impartially and confidentially.
The information shall be made known exclusively to those areas whose collaboration is necessary for the verification proceedings, avoiding damaging the result of the investigation or the good name of the persons concerned.
Those who report facts or leads to the Whistleblower Channel will not be subject to retaliation or suffer any other adverse consequences as a result of such reporting.
The Complaints Channel is available 24 hours a day, 365 days a year on the website https://vmvcosmeticgroup.com/denuncias/.
You may also submit your complaint by e-mail to the e-mail address: canaldedenuncias@vmvcg.com