Privacy Policy

PRIVACY POLICY

1.- OUR PRIVACY COMMITMENT

VMV Cosmetic Group considers the protection of your personal data to be of vital importance. Therefore, in a clear and simple way, with the utmost honesty and transparency, we have drawn up this privacy policy to inform you how we collect and process your data, in accordance with the legislation in force on the protection of personal data.

This Privacy Policy sets out the basis on which 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, the “Websites”):

https://aleacosmetics.com/
https://www.arkhecosmetics.com/
http://azaleacolortotal.com/
https://azaleacosmetics.com/
https://beautystudiocenter.com/
https://besalonbarcelona.com/
https://colortalent.salerm.com/
https://cosmeticsmysalon.com/
https://crioxidil.com/
https://firsthair.es/
https://firsthair.eu/
https://lendan.com/
https://pelucasmarvi.com/
https://pelucasypostizosenbarcelona.com/
https://www.salerm.com/
https://salermacademy.com/
http://www.salermproline.com/
https://salonseleccion.com/
http://secretcodecosmetics.com/
https://vmvcosmeticgroup.com/
https://vmveshop.com/

We would like to remind you that every time you use any of our Websites and provide us with, or it is necessary for us to access, any type of information which, due to its characteristics, allows us to identify you, such as your first and last name, e-mail address, billing or shipping addresses, telephone number, type of device or debit or credit card number, etc. (hereinafter, “Personal Data”), whether to browse the Website, purchase our products or use its services or functionalities, it will be subject to this Privacy Policy, together with the Terms of Use of the Website that you will find in the Legal Notice, and other documents referenced therein in force at any given time. This Privacy Policy may be modified at any time. Remember that it is your responsibility to read it periodically, as the one applicable will be that which is in force at the time you use any of the Websites.

Please note that, in the context 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 issue invoices. If you do not wish to provide your personal data, please remember that we will not be able to complete the purchase and sale of your order.

Our privacy commitment 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 them and, at any time, you may change your mind by letting us know.
We will never offer or sell your personal data.
We are committed to keeping your data safe and secure and, therefore, we work with trusted partners who apply strict Data Protection policies.
We are committed to being open, honest and transparent about how we use your data, in a clear and simple way.
We will use your data solely for the purpose for which it was collected and about which we will have informed you in advance.
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 about the type of personal data that 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 such 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 (hereinafter, the “Policy”).

Please read this Privacy Policy carefully. If you have any questions or concerns about your personal data, you can always contact us whenever you need by sending an email to [email protected].

2.- WHO ARE WE? WHO IS OUR DATA PROTECTION OFFICER?

VMV Cosmetic Group is made up of a group of companies, among which is the one that provides corporate services to the rest of the companies, called VMV GROUP DE SERVICIOS Y GESTION SL, with tax ID B62938584 and registered address in the municipality of Llissà de Vall, 08185 Barcelona, Spain, in the P.I. Cantallops, Avenida Cantallops, s/n, which is the company responsible for the purposes of the data protection regulations.

Our Data Protection Officer at VMV Cosmetic Group is:

Oscar Clavell
Plaza Víctor Martínez s/n
Llissà de Vall
08185 Barcelona
Spain
Contact e-mail: [email protected]

You can consult all the brands that are part of VMV Cosmetic Group by clicking here.

3.- PERSONAL DATA

“Personal Data” means any information that can identify you directly (for example, your first and/or last name) or indirectly (for example, your ID card number). Personal Data includes information such as email address / private postal addresses / mobile phone number, usernames, profile images, personal preferences and shopping habits, user-generated content and financial and social assistance information, among others. It may also include unique numerical 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 relating to that service and/or functionality. In that section you will be able to see whether there is any particular condition for its use, or whether specific processing of your Personal Data is required. Failure to provide certain information indicated as mandatory may result in it not being possible to manage your registration as a user or the use of certain functionalities or services available through the Websites.

Remember that you must always ensure that the Personal Data provided is true and accurate and that you undertake to notify any change or modification of it.

Any loss or damage caused on the Websites, to the Data Controllers or to any third party by 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 at the very heart of what we do. We love getting to know you, learning and creating, and delivering products and services that you can enjoy, so we are constantly talking and interacting with you. For this reason, there are many and varied ways in which we may collect your data.

Thus, we may collect or receive your data through our websites, forms, applications, devices, products and/or brand pages on social media. In some cases, you will provide the Personal Data directly to us (for example, when you create an account, when you contact us, when you purchase on our websites / applications or in our shops / beauty salons) and, in other cases, we collect it ourselves (for example, by using cookies to see how you interact with us). In some cases, we may even receive your data from other third parties.

To make it simpler and clearer, below we have included a table where, in a concise, transparent and easily accessible way for you, you will be able to identify:

1) For what purposes can we use your Personal Data? In this column we explain what we can 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 the reason why we can use your Personal Data.

Although the table presented later includes more specific information, the legal basis for the processing of your Personal Data, depending on the scenario in which it was collected, may be:

Your explicit consent;
Our legitimate interest, which includes:
- (i) Producing statistics to help us better understand your needs and expectations and therefore improve our services, websites / applications / devices, products and brands.
- (ii) Enabling 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 ensure that they function properly.
- (iii) Profiling and carrying out statistics for the personalised sending of commercial communications.
- (iv) Offering you our customer service.
- (v) Performance of a contract: providing the services you request from us.
- (vi) Compliance with legal obligations that entail processing your personal data.

When we collect your Personal Data, we always indicate the fields that are mandatory with asterisks. The data we request is necessary in order to, as the case may be:

(i) Fulfil our contract with you (for example, to deliver to the address you have indicated the products you have purchased on our Websites);
(ii) Provide you with the service you have requested from us (for example, to provide you with a newsletter);
(iii) Comply with legal requirements (for example, to issue an invoice).

3) What personal data can we collect about you? In this column we explain what types of Personal Data we may collect about you depending on the scenario in which we find ourselves.

4) In what scenario can your Personal Data be collected? In this column we explain in 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 can we use your Personal Data?

Sending commercial and promotional communications which includes: (i) Sending marketing and communication materials; (ii) Invitations to events; (iii) Sending product samples; (iv) Promotion of our products; (v) Offering personalised services based on your beauty characteristics; (vi) Showing you advertisements on our websites so that you have a more personalised experience when you visit us. We may also show you online advertising about products that may interest you, based on how you have previously browsed; (vii) Showing you advertisements and content on your social networks; (viii) Creating a profile of your tastes and interests, in order to tailor communications and advertisements.

Legal basis: Your consent.

Personal data we may collect: (i) First and last name; (ii) Gender; (iii) Email address; (iv) Postal address; (v) Telephone number; (vi) Photo; (vii) Date of birth or age range; (viii) Nationality; (ix) ID, username 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 through our social media profiles, websites and/or applications, available on some websites / applications or by participating in a competition, game or survey; (xiv) Information on purchase history, including transaction information.

Scenarios in which they are collected: (i) Account creation and management; (ii) Subscription form for newsletters; (iii) Registration or subscription to games, promotions, offers, surveys, etc.; (iv) Request and/or placement of 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 extensions sales centres; (viii) Through the contact form on the website or comments posted on our blogs and social networks.

Who may have access: (i) Your personal data may be transferred to the companies that form part of VMV Cosmetic Group, which are clearly and simply identified in section two of this policy (Who are we?); and (ii) to third-party service providers who help us provide IT services, such as platform providers, hosting services, maintenance and support for our databases, as well as for our software and applications that may contain data about you; (iii) Advertising, marketing, digital media and social media agencies that help us show you campaigns and advertisements, analyse how effective they are, and manage contact with you and respond to your queries; (iv) Third parties that help us provide digital and e-commerce services such as social listening, store locator, loyalty programmes, identity management, ratings and reviews, CRM, web analytics and search engine; (v) Likewise, when we use Google 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 consult 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 its Privacy Policy. In addition, this international data transfer is protected by the standard contractual clauses approved by the European Commission, which guarantees that your data is kept 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 and Meta share responsibility for the processing of your data, which means that both of us are responsible for how that data is used. Within this agreement, Meta is responsible for guaranteeing your data protection rights, such as: Access, Rectification, Erasure, Restriction of processing, Portability. Thanks to this collaboration with Meta, we can show you more relevant ads tailored to your interests. If you would like more information on how Meta handles your personal data or how to exercise your rights with them, you can consult its Privacy Policy and Joint Controller Addendum. Finally, we also work with advertising services offered by TikTok Technology Limited (TikTok Ireland), so your data may also be shared with that entity. In this case, both VMV Cosmetic Group and TikTok share responsibility (joint controllership) for the processing of your personal data, which means that both of us are responsible for how these data are collected and used. Within this joint controllership agreement, TikTok is responsible for ensuring your data protection rights, such as: Access, Rectification, Erasure, Restriction of processing, Portability. Thanks to this collaboration with TikTok, we can 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 with them, you can consult its Privacy Policy.

Management of the contractual relationship which includes: (i) Management of your orders; (ii) Sending orders to the address you have indicated; (iii) Responding to your questions and interacting with you; (iv) Contacting you to indicate the steps to follow to complete the order when the shopping cart has been saved without completing the payment process; (v) Informing you of the availability of a product; (vi) Processing and tracking your orders; (vii) Managing the payment of your orders; (viii) VMV Cosmetic Group loyalty programmes; (ix) Managing any incident related to a purchase; (x) Measuring your satisfaction with the entire purchase process; (xi) Managing your participation in competitions, games and surveys; (xii) Publishing your reviews and/or comments; (xiii) Providing you with the requested service (for example, trying our products); (xiv) Showing you your nearest store.

Legal basis: Fulfilment of the contractual relationship: maintenance, fulfilment, development, control and execution of the contractual relationship established with you.

Personal data we may collect: (i) First and last name; (ii) Gender; (iii) Email address; (iv) Postal address; (v) Telephone number; (vi) Photo; (vii) Date of birth or age range; (viii) ID, username 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) Your purchase history; (xv) Information requested in the payment gateway (credit card number, PayPal information, etc.). Payment information is not collected by us, but by the payment service provider; (xvi) Academic history, financial data for the granting of study scholarships.

Scenarios: (i) Account creation and management; (ii) Information that may have been provided during the purchase process carried out through our websites/applications/social networks or online shop; (iii) Subscription form for newsletters; (iv) Registration or subscription to games, competitions, promotions, offers, surveys…; (v) Request and/or placement of an order/service through any of our sales channels; (vi) Enrolment in our courses, conferences, seminars, galas and other events organised.

Basic profiling for: (i) Improving our websites / applications; (ii) Enriching your profile if you make a purchase using your account information; (iii) Monitoring and improving our applications and devices; (iv) Analysing your wellbeing characteristics and recommending appropriate products (including bespoke products) and routines to follow; (v) Producing reports and statistics; (vi) Understanding user responses to our advertising campaigns; (vii) Improving our offers; (viii) Knowing how you found our websites/applications.

Legal basis: To ensure that our websites/applications remain secure, to help us better understand your needs and expectations and, therefore, to improve our services, products and brands. Likewise, to help us better understand the needs and expectations of our customers and, therefore, improve our services, products and brands.

Personal data: (i) First and last name; (ii) Gender; (iii) Email address and telephone number; (iv) Postal address; (v) Telephone number; (vi) Photo; (vii) Date of birth or age range; (viii) ID, username 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) Your purchase history.

Scenarios: (i) Account creation and management; (ii) Subscription form for newsletters; (iii) Registration or subscription to games, competitions, promotions, offers, surveys, etc.; (iv) Request and/or placement of an order through any of our sales channels.

Maintaining suppression lists updated to avoid contacting you if you so request.

Legal basis: The GDPR allows us to keep your details on a suppression list if you have asked us not to send you any further marketing communications.

Personal data: (i) First and last name; (ii) Email address; (iii) Social media profile (when using social login or when you share this personal information with us).

Scenario: Subscription to newsletters and commercial communications.

Enabling the operation of our website / applications through technical and functional cookies (i) Proper display of content; (ii) Creation and remembering of your login; (iii) Customisation of the interface, such as language; (iv) Improvement of our websites / applications; (v) Ensuring that the website or application is safe and secure; (vi) Preventing visitor data from being saved twice; (vii) Enabling our content to be shared on social media (share buttons to display the website); (viii) Analysing your wellbeing characteristics and recommending appropriate products (including bespoke products) and routines to follow.

Legal basis: Ensuring that we provide you with websites / applications that work properly, securely and that continually improve your experience.

Personal data: (i) Data related to the use of the applications or Websites; (ii) Data related to the website from which you came; (iii) Registration details; (iv) Pages and videos you have visited; (v) Ads you click on; (vi) Products you search for; (vii) Location; (viii) Length 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) General interests; (xvii) Number of sessions per user; (xviii) Behavioural path during your browsing (for example, which pages you have visited in the same session).

Scenario: Information collected through cookies or similar technologies as part of your browsing of VMV Cosmetic Group’s websites / applications. For information about cookies, please refer to our Cookies Policy.

Profiling and statistics for the personalised sending of commercial communications: (i) Showing you online advertisements for products that may be of interest to you, based on your previous behaviour; (ii) Showing you advertisements and content on social media platforms; (iii) Creating and remembering your shopping cart; (iv) Sending 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 websites so that you are not asked again for information that has already been provided; (vii) Personalisation of advertisements on third-party websites that you visit, about products and services of companies that form part of VMV Cosmetic Group, in accordance with information about your preferences that has been collected from your browsing on our websites (such as pages visited, uncompleted shopping carts, etc.); (viii) Enabling and facilitating the measurement of the performance of our advertising campaigns; (ix) Improving the profile we have about you; (x) Being able to count the number of visits and traffic sources in order to measure and improve the performance of our website.

Legal basis: Your consent.

Personal data: (i) Data related to the use of the applications or websites; (ii) Data related to the website from which you came; (iii) Pages and videos you have visited; (iv) Ads you click on; (v) Products you search for; (vi) Location; (vii) Length 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 path during your browsing (for example, which pages you have visited in the same session); (xiv) Gender.

Scenario: Information collected through cookies or similar technologies as part of your browsing on VMV Cosmetic Group’s websites / applications. For information about cookies, please refer to our Cookies Policy.

Providing you with our customer service (i) Responding to any questions you may ask us through our websites / applications, social networks, email and chats.

Legal basis: To respond to your requests and questions regarding our products and services.

Personal data: (i) First and last name; (ii) Telephone number, postal address and email address; (iii) Any other information you may share with us when making your enquiry.

Scenario: Information collected when you contact us to make enquiries, or when you respond to surveys on matters relating to VMV Cosmetic Group products and their use.

Producing statistics (i) Generating statistical analyses; (ii) Evaluating user responses to our advertising campaigns; (iii) Optimising our promotions and offers; (iv) Identifying how users find our website.

Legal basis: In order to gain a better understanding of the needs and expectations of our customers and thereby improve our services, products and brands.

Personal data: (i) First and last name; (ii) Gender; (iii) Email address and telephone number; (iv) Postal address (delivery and billing); (vi) Photo; (vii) Date of birth or age range; (viii) Nationality; (ix) ID, username and password; (x) Personal description or preferences; (xi) Order details; (xii) Location/Geolocation; (xiii) Personal description or other information you share with us, such as skin and/or hair type, etc.; (xiv) Transaction information, including products purchased; (xv) Your purchase history; (xvi) Social media profiles (when used for login or when such information is shared); (xvii) Web pages visited; (xviii) Videos viewed; (xix) Ads you clicked on; (xx) Products you search for; (xxi) Length of your browsing on our website; (xxii) Products selected for your basket; (xxiii) Any other information you may share with us when making your enquiry.

Scenario: Information collected when you contact us to make enquiries, or when you respond to surveys on matters relating to VMV Cosmetic Group products and their use.

4.2. Do we process data of minors?

Our products are not intended for minors.

However, if you are under 16 years old and wish to register on our website or make a purchase, you must have the prior permission of your mother, father, guardian or legal representative.

Likewise, if you share on our social networks images in which minors under 16 years of age appear, it is your responsibility to ensure that you have obtained the corresponding authorisation from their parents or legal guardians beforehand.

VMV Cosmetic Group reserves the right to ask you at any time for proof that you have such authorisation.

5.- PROFILING

When we send or display personalised communications or content, we may use certain techniques known or qualified as “profiling” (that is, any form of automated processing of personal data consisting of using such data to evaluate certain personal aspects of an individual, in particular to analyse or predict aspects related to personal preferences, interests, economic situation, behaviour, location, reliability or movements of that person). With this technique, we can centralise the information and analyse it to evaluate and predict your preferences and/or personal interests. Once the analysis has been carried out, 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 creating an online account, purchasing one of our products, subscribing to our newsletter or browsing our websites). We may also receive personal information about you from our business partners, provided that you have given your consent to do so.

Once obtained, these data may be centralised and pseudonymised (that is, we replace your personal data with a unique identifier) for analysis so that we can learn about and anticipate your preferences and personal interests.

From 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 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 with them some of your identifying data (such as your first and last name and contact details), in encrypted form. This allows them to locate your profile among their users and show you advertisements about our products and services, both to you and to users with similar profiles.

In certain activities, we work together with these third parties as joint controllers of the data processing, as explained above.

These partners also provide us with reports containing aggregated and non-identifiable information about the performance of our advertising campaigns, which allows us to continuously improve them.

This type of profiling and the use of your data for advertising purposes will only be carried out if you have given us your prior consent.

We remind you that you may always object to your personal data being subject to processing based on profiling. You can consult 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 VMV Cosmetic Group

As mentioned in the table above in the column “Who can have access to your Personal Data?”, your data may be transferred/shared with any of the companies that form part of VMV Cosmetic Group, which are clearly and simply identified in section two of this policy and always under the obligation to keep your details on a suppression list if you ask us not to receive any further marketing communications.

(ii) Your personal data may also be processed by our trusted suppliers (third parties).

We enter into contracts with trusted third parties to carry out 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 that they do not use your personal data for any other purpose. We always use our best efforts to ensure that all third parties with whom we work maintain the security of your personal data by signing strict data protection agreements.

Please refer to the table above where, in a simple and clear way, in the column “Who can have access to your Personal Data?” you can find the categories of third-party service providers who require access to your personal data.

(iii) Possibility of sharing 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 personalised advertising purposes. As mentioned in the section on profiling, and provided that we have 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, based at 0 Earlsfort Terrace, Dublin, D02 T380, Ireland. They may also include search engines such as Google LLC, with registered office at 1600 Amphitheatre Parkway, Mountain View, California 94043, USA, or other platforms such as Amazon Europe Core Sarl, based at 38 avenue John F. Kennedy, L-1855, Luxembourg, among others.

The purpose of this data sharing is to identify your profile on these platforms and 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 have direct access to 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 for direct identification.

In other situations, the information shared corresponds to aggregated and anonymous data, which both we and our partners use to create groups of users (audiences) with common characteristics (such as geographical area or age range), in order to better target our advertising campaigns.

In certain activities, we share responsibility for data processing with these companies, as detailed in the table above.

Please remember that you can rest assured that we will never, under any circumstances, offer or sell your personal data to third parties.

7.- INTERNATIONAL TRANSFERS

At VMV Cosmetic Group we are committed to ensuring 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 requested service or functionality. 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 accept the use of their advertising or analytics services.

These international transfers are carried out under appropriate safeguards, in particular through the application of the Standard Contractual Clauses approved by the European Commission and, where applicable, the adherence of these providers to the EU–US Data Privacy Framework (Commission’s adequacy decision of 10 July 2023).

You may request additional information on these safeguards or a copy of them at any time by writing to us at [email protected].

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 collected it, in order to meet your needs or to comply with our legal obligations.

To determine the retention period of your Personal Data, we use the following criteria:

Type of data	Retention period of your Personal Data
Personal Data obtained when purchasing our products and services.	As long as our contractual relationship lasts, and for a period of 5 years from its termination.
Personal Data obtained when participating in a promotion, competition or prize draw.	For the duration of the promotional offer, competition and/or prize draw, and for a period of 1 year from its end.
Personal Data obtained when contacting us with an enquiry.	For the time necessary to deal with your enquiry, and for a period of 1 year from its resolution.
Personal Data obtained when creating an account.	Until you cancel your subscription and/or request that we delete it, and for a period of 5 years after your activity has ended.
Personal Data obtained when you give your consent to receive commercial communications and newsletters.	Until you cancel your subscription and/or request that we delete it, and for a period of 5 years from such request.
Personal Data obtained when you give your 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 following such request.
Cookies installed on your computer.	The time necessary to achieve their purposes (for example, during one session for shopping cart cookies or session identification cookies) and always for a maximum of 365 days.
Personal Data obtained for statistical analysis.	Until you withdraw your consent and/or request that we delete it, and for a period of 5 years from such request.

Notwithstanding the above, please bear in mind that we may retain some personal data to comply with our legal or regulatory obligations, as well as to manage our rights (for example, to enforce our claims in court) or for statistical or historical purposes.

Once we no longer need to use your personal data, we will delete it from our systems and records, or anonymise the information so that it can no longer be associated with your identity.

9.- ARE MY PERSONAL DATA STORED SECURELY?

We are committed to protecting your Personal Data and 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 over the internet is not completely secure, we cannot guarantee the security of your data transmitted to our site. Therefore, you should always be aware that any transmission is at your own risk.

10.- 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 beyond our control, so we cannot be held responsible. You should always consult their policies before submitting personal data to these websites.

In certain cases, we may also offer you the opportunity to use your social media login to register. If you do so, please note that you are sharing your social profile information with us. The personal data shared depends on the settings of your social media platform. Please visit the relevant social media platform and review its privacy policy to understand how data are shared and how they are used.

11.- SOCIAL MEDIA AND USER-GENERATED CONTENT

Some of our websites and applications allow users to submit their own content. Remember that any content submitted to one of our social media platforms can be viewed by the public, so you should be careful when providing certain personal data (for example, financial information or details of your address).

Please bear in mind that these platforms are beyond our control, so we can never be held responsible for the processing they may carry out on 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 privacy and Personal Data processing policy. Remember that it is very important that you always remain in control of your personal data. Therefore, we would like to remind you of your rights:

(i) Right to information

You have the right to obtain clear, transparent, intelligible and easily understandable 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 easily contact us by sending an email to [email protected].

(ii) Right of access

You have the right to access all personal data we hold about you. However, please note that manifestly unfounded, excessive or repetitive requests may not be dealt with.

To exercise this right, you can contact us by sending an email to [email protected].

(iii) Right to rectification

You have the right to have your personal data rectified when it is inaccurate or has ceased to be valid or to have it completed when it is incomplete.

To exercise this right, you only need to contact us by sending an email to [email protected]. 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 deleted or erased. However, it should be noted that this is not an absolute right, as in some cases it will be necessary, for legal and/or legitimate reasons, to retain it.

To exercise this right, you only need to contact us by sending an email to [email protected].

(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 by clicking on the “Unsubscribe” link in any email or communication we have sent you. You can also exercise this right by sending an email to [email protected].

(vi) Right to withdraw consent at any time where data processing is based on your consent

You may withdraw your consent to the processing of your personal data at any time. You can see in which cases processing is based on your consent in the table included in the section “What data of yours do we collect?” in the column “What is the legal 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 email to [email protected].

(vii) Right to object to processing based on the satisfaction of legitimate interests

You may object at any time to the processing of your data where the processing is based on the satisfaction of legitimate interests. To find out in which cases processing is based on legitimate interests, simply refer to the table included in the section “What data of yours do we collect?” in the column “What is the legal basis for processing your Personal Data?”.

If you wish to exercise this right, you can easily do so by sending us an email to [email protected].

(viii) Right to lodge a complaint with a supervisory authority

You have the right at any time to lodge a complaint with the Spanish Data Protection Agency regarding VMV Cosmetic Group’s privacy and data protection practices.

Please do not hesitate to contact us to resolve any questions and/or clarifications you may need. You can do so by sending us an email to [email protected].

(ix) Right to data portability

You have the right to transfer, copy or transmit data from our database to another database.

You can only exercise this right with respect to data you have provided, where processing is based on the performance of a contract or on your consent and the processing is carried out by automated means.

To find out in which cases processing is based on a contract or on consent, you can consult the table included in the section “What data of yours do we collect?” in the column “What is the legal basis for processing your Personal Data?”.

Remember that you can send us an email to [email protected] 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 them, but we will not be able to continue using or processing them.

This right can only be exercised in certain circumstances provided for in the General Data Protection Regulation. When:

The data subject contests the accuracy of the personal data, for a period enabling the controller to verify the accuracy of the data;
The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
The controller no longer needs the personal data for the purposes of the processing, but the data subject needs them for the establishment, exercise or defence of legal claims;
The data subject has objected to processing pursuant to Article 21(1) while it is verified whether the legitimate grounds of the controller override those of the data subject.

If you wish to exercise this right, you can easily do so by sending us an email to [email protected].

(xi) Right to disable Cookies

You have the right to disable Cookies. Internet browser settings are usually set by default to accept Cookies, but they can easily be disabled by changing the browser settings.

Many cookies are used to improve the usability or functionality of websites/applications; therefore, disabling them may prevent you from using certain parts of our websites/applications as indicated in the Cookies Policy.

If you wish to limit or block all cookies set by our websites/applications, you can easily do so through your browser settings. If you want to know how, simply refer to our Cookies Policy.

We can also help you if you send us an email to [email protected].

(xii) Right not to be subject to automated decision-making

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 will not apply where:

The decision is necessary for entering into or for the performance of a contract.
The decision is authorised by Union or Member State law applicable to the controller, which also lays down suitable measures to safeguard your rights, freedoms and legitimate interests.
The decision is based on your explicit consent.

13.- CONTACT

Please remember that we are always happy to help you. If you have any questions or concerns about how we process and use your personal data or if you wish to exercise any of the rights described above, you can do so in whichever way is most convenient and easy for you:

By sending us an email to [email protected].
Or by writing to us at Plaza Víctor Martínez s/n, P.I. Cantallops, Lliçà de Vall (Barcelona – 08185).

14.- VMV COSMETIC GROUP WHISTLEBLOWING CHANNEL

Below, we would like to inform you about the existence of our whistleblowing channel. The Whistleblowing Channel is an essential part of VMV Cosmetic Group’s compliance system, as one of the processes established to ensure the effective application of the regulations and the guidelines of the Code of Ethics and Conduct.

The channel is also a means to help employees, customers, suppliers and other third parties report, anonymously and confidentially, any breaches of the Code of Conduct and/or applicable legislation they may detect.

The Compliance Department will handle complaints received with diligence and promptness, promoting their verification and taking steps to resolve them. All information will be analysed objectively, impartially and confidentially.

The information will be disclosed only to those areas whose cooperation is necessary for the verification actions, avoiding any prejudice to the outcome of the investigation or to the reputation of the people concerned.

Those who report facts or indications to the Whistleblowing Channel will not be subject to retaliation or suffer any other adverse consequences as a result of such communication.

The Whistleblowing Channel is available 24 hours a day, 365 days a year on the website https://vmvcosmeticgroup.com/denuncias/.

You can also submit your report by email to the following address: [email protected].