PERSONAL DATA PROCESSING - TEST

Below we inform you about the processing of the personal data you provide when taking the TEST. Please also see our Privacy Policy.

DATA CONTROLLER

FRESHLY COSMETICS, S.L., with its registered address in Reus (Tarragona), c/ Nicaragua, 36, registered in the Commercial Registry of Tarragona in Volume 2,899, Page 18, Sheet number T-48,804, with Tax reference (CIF) no. B-55666143 and email address [email protected] (“FRESHLY COSMETICS”).

Data Protection Officer: [email protected]

PERSONAL DATA BEING PROCESSED

  • ✔ Identification details. Name and email address.
  • ✔ Health-related data.

OBTAINING THE PERSONAL DATA

The data we process are:

  • ✔ Those that you provide at the moment of taking the TEST.

PERSONAL DATA OF MINORS

TEST is not designed for minors. However, those aged under 16 who wish to take the TEST must have authorisation from their father/mother/guardian or legal representative.

FRESHLY COSMETICS reserves the right to request evidence of such authorisation at any time.

PURPOSE AND LEGAL BASIS FOR THE PROCESSING

FRESHLY COSMETICS may process your personal data for the following purposes and on the following legal basis:

  • ✔ Purpose: To allow the TEST to be taken, to create profiles and to send commercial notifications based on your preferences.
  • ✔ Legal basis: Our legitimate interest in informing you about our products. When the processing of your data implies the creation of commercial profiles and/or when the information about our products is provided by email, FRESHLY COSMETICS will first obtain your consent. You may withdraw this consent at any time by sending an email to the following address: [email protected]

If FRESHLY COSMETICS needs to process your data for purposes other than those mentioned above, it will ask for your express consent for that, which you may unilaterally withdraw at any moment.

COMMUNICATION OF PERSONAL DATA

Your personal data will only be communicated to those people or entities that need to access them within the framework of the processing set out in the previous sections (Data Processors). In any other case, FRESHLY COSMETICS will not transfer your data to third parties without having first obtained your express consent in the legally required terms.

FRESHLY COSMETICS only enters into agreements with Data Processors who guarantee compliance with the personal data protection legislation, protecting the security and confidentiality of the information.

International Personal Data Transfers

In the framework of our commercial management, we may outsource the processing of some of our customers’ data to providers of marketing services, as well as to providers of cloud computing services. This processing may imply access to your data and, at times, their storage, on servers located outside the European Economic Area (international transfers of personal data). FRESHLY COSMETICS only enters into agreements with providers who perform international transfers of personal data within the scope of an adequacy decision by the European Commissionor in Standard Contractual Clauses.

Currently, our providers who may store your data outside the European Economic Area are the following:

  • GOOGLE ANALYTICS:  https://privacy.google.com/businesses/processorterms/
  • AMAZON WEB SERVICES INC.: https://d1.awsstatic.com/legal/aws-gdpr/AWS_GDPR_DPA.pdf
  • KLAVIYO: https://www.klaviyo.com/privacy/dpa
  • SEGMENT: https://segment.com/legal/privacy/

PERSONAL DATA RETENTION PERIOD

Your personal data will be retained for the time necessary to fulfil the purposes for which they were collected. After this time, FRESHLY COSMETICS will erase them from its systems, without prejudice to the possibility of retaining them under the terms established in the applicable legislation, restricting their processing to the exercise and defence of claims.

SECURITY MEASURES APPLICABLE TO THE PROCESSING OF THE DATA

FRESHLY COSMETICS applies security measures to guarantee the confidentiality, availability and resilience of the personal data processing systems. Similarly, we carry out processes to verify and evaluate the technical and organisational measures implemented, in order to guarantee the security of the personal data at all times.

What rights do you have?

You may exercise the rights listed below by sending an email to the following address: [email protected]

  • ✔ Request, at any time, that FRESHLY COSMETICS confirmswhether or not it is processing your personal data.
  • ✔ Access your personal data, request the rectification of any that are inaccurate or, where appropriate, request their erasure when, among other reasons, they are no longer necessary for the purposes for which they were collected.
  • ✔ In certain cases, request the restriction of the processing of your data. In this circumstance, we can only retain your data for the exercise or defence of claims.
  • ✔ In certain circumstances, object to the processing of your data.
  • ✔ Request the portability of your data.
  • ✔ Withdraw the consent that, where relevant, you have granted for the processing of your data by FRESHLY COSMETICS.
  • ✔ Submit a claim to the Agencia Española de Protección de Datos (Spanish Data Protection Agency).