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, and 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 regulations 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/

Please note that whenever, when using any of our Websites, you 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 name and surname, 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 make use of its services or functionalities, your data will be processed under this Privacy Policy, together with the Website’s Terms of Use found in the Legal Notice and any other referenced documents in force at any given time. This Privacy Policy may be amended at any time. Please remember that it is your responsibility to read it periodically, as the version in force at the time you use any of the Websites will apply.

Please also note that, in the context of distance selling, you are required to provide certain personal information, since this data is necessary both to process and deliver your orders and to issue invoices. If you do not wish to provide your personal data, please bear in mind that we will not be able to complete the sale and purchase of the 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 embedded in 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 informing us.
• We will never offer or sell your personal data.
• We are committed to keeping your data safe and protected 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 only for the purpose for which it was collected and about which we have previously informed you.
• We respect your rights and will always try to accommodate your requests, to the extent 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 regarding 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 may contact us at any time by sending an email to protecciondatos@grupovmv.com.

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 (CIF) B62938584 and registered office in the municipality of Llissá de Vall, 08185 Barcelona, Spain, in the industrial area P.I. Cantallops, Avenida Cantallops, s/n, which is the company responsible for the purposes of data protection regulations.

Our Data Protection Officer for VMV Cosmetic Group is:

Oscar Clavell
Plaza Víctor Martínez s/n
Llissá de Vall
08185 Barcelona
Spain
Contact e-mail: protecciondatos@grupovmv.com

You may 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 name and/or surname) or indirectly (for example, your ID or passport number). Personal Data includes information such as email address, home postal addresses, mobile phone number, usernames, profile pictures, personal preferences and shopping habits, user-generated content and financial or 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

Please remember that before you start using any of our services or functionalities, you must read this Privacy Policy as well as the Terms of Use of the specific section for that service and/or functionality. In that section you can see whether there are any particular conditions for its use or whether specific processing of your Personal Data is required. Failure to provide certain information marked as mandatory may result in us being unable to manage your registration as a user or the use of certain functionalities or services available through the Websites.

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

Any loss or damage caused to the Websites, to the Data Controllers or to any third party through the communication of erroneous, inaccurate or incomplete information in the registration forms will be your sole responsibility.

4.1. What data do we collect from you?

VMV Cosmetic Group believes that you are at the heart of what we do. We love to get to know you, learn and create, and to provide you with products and services that you can enjoy, which is why we are constantly talking and interacting with you. For this reason, there are many and varied ways in which we may collect your data.

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

To make it easier and clearer, below we provide an explanation of what we use your data for, the legal basis, what types of data we collect, in which scenarios and who may have access to it.

Sending commercial and promotional communications

Purpose: Sending marketing and communication messages; invitations to events; sending product samples; promoting our products; providing personalised services based on your beauty characteristics; displaying ads on our websites and social networks; and creating a profile of your tastes and interests.

Legal basis: Your consent.

Data processed: First name and surname, gender, email address, postal address, phone number, photo, date of birth or age range, nationality, ID, username and password, personal description or preferences, order details, social media profile, other information you share with us (photos, reviews, skin or hair type, questions, etc.), purchase history information.

Scenarios: Creation and management of accounts, subscription to newsletters, registration for games, promotions, offers or surveys, requests and orders, use of hair salons and beauty centres, the Academy, wig and extensions centres, contact forms, comments on blogs and social media.

Access to the data: Companies within VMV Cosmetic Group and IT service providers, advertising agencies, marketing, digital media and social media agencies, third-party digital and e-commerce service providers (social listening, store locator, loyalty programmes, CRM, web analytics, etc.), as well as Google, Meta and TikTok on the terms explained in this Policy.

Management of the contractual relationship

Purpose: Managing orders, shipments, responding to queries, order tracking, loyalty programmes, handling incidents, measuring satisfaction, participation in contests and surveys, publishing reviews and comments, providing requested services and locating the nearest store.

Legal basis: Performance of the contractual relationship.

Data processed: First name and surname, gender, email address, postal address, phone number, photo, date of birth or age range, ID, username and password, personal description or preferences, order details, location/geolocation, information about skin and/or hair, transaction information, purchase history, data required by the payment gateway, academic history and financial data for study grants.

Scenarios: Creation and management of accounts, purchase processes, newsletter subscription, registration in promotions, contests and surveys, requests for orders/services, enrolment in courses, conferences, seminars, galas and other events.

Access to the data: Companies within VMV Cosmetic Group and IT and digital/e-commerce service providers.

Basic classification and analysis

Purpose: Improving our websites/applications, enriching your profile, monitoring and improving our applications and devices, analysing your characteristics and recommending products and routines, producing reports and statistics, understanding responses to our campaigns and improving our offers.

Legal basis: Legitimate interest in ensuring the security and continuous improvement of services, products and brands.

Data processed: First name and surname, gender, contact details, postal address, photo, date of birth or age range, ID, username and password, personal description or preferences, order details, location/geolocation, personal description or other information you share with us, transaction information and purchase history.

Scenarios: Creation and management of accounts, subscription forms for newsletters, registration in contests and promotions, order requests.

Access to the data: Companies within VMV Cosmetic Group, IT service providers, advertising agencies and third-party digital and e-commerce service providers.

Maintenance of suppression lists

Purpose: Maintaining up-to-date lists to avoid sending commercial communications to those who have requested not to receive them.

Legal basis: Obligation arising from the GDPR.

Data processed: First name and surname, email address, social media profiles.

Scenarios: Subscription to newsletters and commercial communications.

Access to the data: Companies within VMV Cosmetic Group, IT service providers, advertising agencies and third-party digital and e-commerce service providers.

Technical and functional cookies

Purpose: Enabling the operation of the website/applications (displaying content, remembering login details, interface customisation, website/app improvements, security, avoiding duplicate visitor records, sharing content on social networks, analysis and personalised recommendations).

Legal basis: Legitimate interest in providing secure, quality services.

Data processed: Data relating to the use of applications or Websites, referring page, registration details, pages and videos visited, ads clicked, products searched and selected, location, length of visit, IP address, browser and device information, unique identifiers, gender, general interests, number of sessions and browsing behaviour.

Scenarios: Browsing using cookies or similar technologies. See the Cookies Policy.

Access to the data: Companies within VMV Cosmetic Group and IT and digital/e-commerce service providers.

Profiling for advertising purposes

Purpose: Displaying personalised ads based on your behaviour, remembering shopping carts, sending recommendations and content based on your profile, personalising ads on third-party sites, measuring campaign performance and counting visits and traffic.

Legal basis: Your consent.

Data processed: Data relating to the use of applications or websites, referring page, pages and videos visited, ads clicked, products searched and selected, location, length of visit, IP address, browser and device information, unique identifiers, browsing behaviour and gender.

Scenarios: Browsing using cookies or similar technologies. See the Cookies Policy.

Access to the data: Companies within VMV Cosmetic Group and IT and digital/e-commerce service providers.

Customer service

Purpose: Responding to questions you may ask us through our websites, applications, social networks, email and chats.

Legal basis: Legitimate interest in responding to your requests and questions.

Data processed: First name and surname, phone number, postal address, email address and any other information you share with us in your query.

Scenarios: When you contact us to ask questions or respond to surveys.

Access to the data: Companies within VMV Cosmetic Group and IT and digital/e-commerce service providers.

Statistics

Purpose: Generating statistical analyses, assessing response to our campaigns, optimising promotions and offers, and identifying how users find our website.

Legal basis: Legitimate interest in understanding the needs and expectations of our customers.

Data processed: Identification and contact data, order and geolocation data, information on skin and/or hair, transaction information, purchase history, social media profiles, pages visited, videos watched, ads clicked, products searched, browsing duration, products selected in the cart and any other information you share with us.

Scenarios: When you contact us and participate in surveys and activities related to VMV Cosmetic Group products.

Access to the data: Companies within VMV Cosmetic Group and IT and digital/e-commerce service providers.

4.2. Do we process data of minors?

Our products are not intended for minors.

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

Likewise, if you share images on our social networks in which minors under 16 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 to provide proof that you have such authorisation.

5.- PROFILING

When we send or display personalised communications or content, we may use certain techniques referred to as “profiling”. With this technique we centralise the information and analyse it in order to assess and predict your personal preferences and/or interests. Once the analysis has been carried out, we send or display communications and/or content tailored to your interests, needs and preferences.

This means that we may collect personal data about you in the different situations described above. We may also receive personal information about you from our commercial partners, provided that you have given your consent.

Once obtained, this data may be centralised and pseudonymised so that we can analyse it and anticipate your personal preferences and interests.

Based on this analysis, we may send you personalised promotional communications, display advertisements tailored to your interests on our websites and on third-party sites, and identify other people with similar characteristics in our database.

To display personalised advertising on third-party sites, we need to share some of your identifying data in encrypted form with those third parties. In certain activities we work together with these third parties as joint controllers of the data.

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.

Please remember that you can always object to your personal data being processed based on profiling. You can refer to the “Your rights and choices” section below.

6.- WHO CAN ACCESS YOUR PERSONAL DATA?

(i) We share your personal data among the companies that are part of VMV Cosmetic Group.

Your data may be transferred/shared with any of the companies that are part of VMV Cosmetic Group, identified in section 2 of this Policy, and always under the obligation to maintain your details on a suppression list if you ask us not to receive further commercial communications.

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

We enter into contracts with trusted third parties to perform a variety of business operations on our behalf. We only provide them with the information they need to perform the service and we require them not to use your Personal Data for any other purpose.

(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, such as Meta Platforms Ireland Limited, TikTok Technology Limited, Google LLC, Amazon Europe Core Sàrl, among others, under the terms explained in this Policy.

This data sharing is carried out in pseudonymised or aggregated form, so that it does not allow your direct identification. In certain activities we share responsibility for data processing with these companies.

Please be 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 undertake not to transfer or store your Personal Data 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 or Meta Platforms, Inc. 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, by the adherence of these providers to the EU–US Data Privacy Framework.

You may at any time request additional information about these safeguards or a copy of them by writing to protecciondatos@grupovmv.com.

8.- HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

We only retain your Personal Data for as long as we need it for the purpose for which we collected it, to meet your needs or to comply with our legal obligations.

To determine the retention period we use the following criteria:

We may retain some personal data to comply with our legal or regulatory obligations, as well as to manage our rights 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.- 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 make 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. However, the transmission of information over the Internet is not completely secure and 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. These sites have their own privacy policies and are beyond our control, so we cannot be held responsible for them. You should always review their policies before submitting personal data.

We may also offer you the opportunity to use your social media login to register. If you do so, you share your social profile information with us. The personal data shared depends on your social media platform settings.

11.- SOCIAL MEDIA AND USER-GENERATED CONTENT

Some of our websites and applications 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.

These platforms are beyond our control, so we cannot be held responsible for how they process your personal data. Always read their policies before sharing your personal data.

12.- YOUR RIGHTS AND OPTIONS

VMV Cosmetic Group has established a strict policy for privacy and the processing of your Personal Data. It is very important that you always have control over your personal data. Below you will find a summary 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 or by contacting us at protecciondatos@grupovmv.com.

(ii) Right of access

You have the right to access all personal data we hold about you. Manifestly unfounded, excessive or repetitive requests may not be honoured.

(iii) Right to rectification

You have the right to have your personal data rectified when it is inaccurate or incomplete.

(iv) Right to erasure / right to be forgotten

You have the right to have your personal data deleted or removed, except where it is necessary to retain it for legal and/or legitimate reasons.

(v) Right to object to direct marketing

You may unsubscribe from our marketing communications at any time by using the “Unsubscribe” link or by contacting us.

(vi) Right to withdraw consent

You may withdraw your consent to the processing of your personal data at any time. Withdrawal will not affect the lawfulness of processing carried out previously.

(vii) Right to object to processing based on legitimate interests

You may object at any time to processing of your data when the processing is based on legitimate interests.

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

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

(ix) Right to data portability

You have the right to move, copy or transfer data from our database to another, in the cases provided for by law.

(x) Right to restriction of processing

You have the right to request restriction of the processing of your data in the cases provided for in the GDPR, in which case we may only store your data.

(xi) Right to disable cookies

You have the right to disable cookies through your browser settings, although this may affect the functionality of the websites. For more information, please refer to our Cookies Policy.

(xii) 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 data, including profiling, except in the cases permitted by law.

13.- CONTACT

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 contact us:

• By email at protecciondatos@grupovmv.com.
• By writing to Plaza Víctor Martínez s/n, P.I. Cantallops, Lliçà de Vall (Barcelona – 08185).

14.- VMV COSMETIC GROUP WHISTLEBLOWING CHANNEL

The Whistleblowing Channel is an essential part of VMV Cosmetic Group’s compliance system and is one of the processes established to ensure the effective application of regulations and of the guidelines set out in 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 they detect of the Code of Conduct and/or applicable legislation.

The Compliance Department will process the reports received diligently and promptly, promoting their verification and implementing measures for their resolution. All information will be analysed objectively, impartially and confidentially.

The information will be shared only with those areas whose cooperation is necessary for the verification activities, avoiding any detriment to the outcome of the investigation or to the good name of the persons concerned.

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

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: canaldedenuncias@vmvcg.com.