Sencyr — Privacy Policy

Date of Last Update: 7th December 2022

1. Who Are We

S-Biomedic, a company registered in Belgium with company number BE 0668.407.105 and having its registered office at Beerse.

Our Mission:

Our Company is active in skin health.

We respect your concerns about privacy and value the relationship we have with you. This Privacy Policy describes the types of personal data we collect about our customers, how we use this information, with whom we share it, and the rights of our customers regarding our use of this information. We also describe the measures we take to protect the security of the information, how long we retain it and how our customers can contact us about our privacy practices and how to exercise their rights.

For the purposes of applicable data protection laws, the data controller is S-Biomedic, a company registered in Belgium with company number BE 0668.407.105 and its registered office at Beerse.

Contact

Contact tel number: +32 477 269940

Contact email: privacy@sbiomedic.com

2.  Collection And Processing Of Personal Data When Visiting Our Website

WHAT DATA DO WE COLLECT AND PROCESS

Type of Personal Data that we process

If we process your Data, then it concerns the following Data:

Information We Collect

We may obtain personal data about you from various sources. We collect this information when you provide it on our website, via our social media pages, when you download one of our mobile applications (either via Apple iOS or Android) onto your mobile device, or at one of our events. Our products are available for sale at certain third-party retailers. Unless otherwise indicated at the time that you provide your personal data, any personal data collected by these retailers is not provided to us. This Privacy Policy does not address any data collection by our retail partners. When you visit this site, our social media pages, or use services or features of one of our mobile applications, we also collect certain information about your device or usage by automated means, including using technologies such as cookies, web server logs, and web beacons.

Information You Provide

You may provide personal data to us in a number of ways, such as when you participate in an offer or promotion, when you make a purchase on our site or in our stores, via our social media pages, or through one of our mobile applications. The types of personal data you provide to us may include:

- Contact information (such as name, postal address, email address and mobile or other phone number)

- Age or date of birth

- Gender

- Username and password, nickname/screen name

- Payment information (such as your payment card number, expiration date, and card security code)

- Shipping and billing information (such as delivery address, and billing address)

- Purchase history

- Product preferences

- Your skin type / skin condition

- Your hair type

- Your physical characteristics and your skincare concerns

- Contact information for friends, family or other people you would like us to send a message to on your behalf (please ensure that you only submit contact information of individuals with whom you have a personal or family relationship and who have consented to receive messages from you or us)

- Information or content you provide (such as photographs, videos, reviews, articles, questions, survey responses and comments)

- Information provided to us through social media networks or one of our mobile applications when you visit our social media pages or use one of our mobile applications (such as your name, profile picture, likes)

- Captcha

We process the Captcha request to verify that it is a real request and not a "login robot" or automated spam requests. Your entry there will only be used for this check and will not be stored.

- location, friend list, and other information described on the social media network or application sign-up page, or your geo-location details when using one of our mobile applications)

If your inquiry relates to an existing contractual relationship with you or if you are interested in concluding a contract, e.g. with regard to an activity, the data processing is carried out on the legal basis of Art. 6 para. 1 sentence 1 b) GDPR (contract fulfillment and initiation).

Otherwise, the data will be processed on the legal basis of Art. 6 para. 1 sentence 1 f) GDPR (balancing of interests). It is in our interest to be able to answer your inquiry with the information relevant to you in our internal department. The data processing of the captcha query is in our interest in order to prevent automated logins via login robots or spam requests. We store the data collected via the contact form for processing and answering the respective inquiry.

How We Use the Information

We will use the information you provide to:

- Send you promotional materials or other communications if you so elect

- Provide the products or services you (or your company) have requested and operate features on our site

- Process your payment card transactions and/or gift card transactions

- Create and manage your online account, including access to your online and in-store purchase history

- Create a profile about you based on the information you provided to us in order to tailor our advertisements to your interests, find your appropriate skin or hair care routine and manage the effectiveness of our marketing efforts

- Assist with product selection and replenishment

- Chat with you or respond to your inquiries

- Post your product reviews

- Tailor ads displayed to you on our site and elsewhere to your interests and history with us

- Communicate with you about, and administer your participation in, special events, contests, sweepstakes, loyalty programs, surveys and other offers

- Operate and communicate with you about our social network pages or mobile applications

- Operate, evaluate and improve our business (including developing new products and services; enhancing and improving our services; managing our communications; analyzing our products; performing data analytics and performing accounting, auditing and other internal functions)

- Comply with applicable legal requirements, relevant industry standards and our policies

We also may use the information in other ways for which we provide specific notice at the time of collection. The information collected is necessary for the purposes set forth above. Without this information, you may not be able to take advantage of some of our products or services.

Legal Basis for Our Use of the Information

We will use the information you provide for the above purposes if:

- it is necessary to perform a contract to which you are a party (e.g., to process your payment and deliver the products you have ordered); or

- we have obtained your consent; or if

- we have a legitimate interest in doing so (including a legitimate interest in performing marketing activities, research activities, data analytics, internal administration functions, processing and enforcing legal claims and conducting our business in compliance with all applicable laws, relevant industry standards and our policies).

If your inquiry relates to an existing contractual relationship with you or if you are interested in concluding a contract, e.g. with regard to an activity, the data processing is carried out on the legal basis of Art. 6 para. 1 sentence 1 b) GDPR (contract fulfillment and initiation).

Otherwise, the data will be processed on the legal basis of Art. 6 para. 1 sentence 1 f) GDPR (balancing of  interests). It is in our interest to be able to answer your inquiry with the information relevant to you in our internal department. The data processing of the captcha query is in our interest in order to prevent automated logins via logon robots or spam requests. We store the data collected via the contact form for processing and answering the respective inquiry.

Information We Collect by Automated Means

When you visit this site, view or click on our online advertisements (including our advertisements on third-party websites), visit our social media pages or download and use one of our mobile applications (if applicable), we also collect certain information about your usage or device by automated means or by using technologies such as cookies,

Please see and visit our Cookies Policy link.

3. Contacting/ Communication/ Collaboration

Purpose/Information:

When communicating and/or collaboration with us, e.g. by email or via the contact form on our website, data exchange platform, be it e.g. as a consumer, test person, business partner or customer, the data you provide (your email address, if applicable your name and your telephone number, or personal data submitted during the conversation) will be stored and processed by us in order to e.g. answer your questions, requests or for the purpose of business-related correspondence.

With regard to the cooperation with our suppliers, we have implemented an internal evaluation process which, in our legitimate interest, is intended to improve the business relationship by developing an “action plan”. As a rule, we only process information about the company, but conclusions can be drawn about you as the contact person if the communication with suppliers is examined with regard to response times, reliability, and transparency.

We may ask you when you contact us by telephone as a consumer whether the telephone call may be recorded for quality assurance and training measures. If you agree to the recording, we will process all information that you share with us during the call (communication content, possibly also sensitive (health) data, as well as your phone number and other personal data).

When processing data arising in the course of communication, we have a legitimate interest in processing the data in accordance with legal requirements, for internal verification or in accordance with the respective communication request. 

The provision of your personal data is required for the performance of the contract or a situation similar to a contract. You are not obliged to provide your personal data. If your personal data is not provided, you cannot use the described service.

Controller:

If you purchase products in the eShop Sencyr, then Sencyr is responsible for the data processing described in this clause. This applies also to any questions about your order that you might ask through the contact form provided in the eShop.

Additionally, we transfer the data to the following recipients:

- Customer/Consumer service providers

- Platform/hosting provider

Deletion/Objection:

We delete the data arising in this context once storage is no longer necessary unless statutory retention obligations exist or periods of limitation must be observed.

In case of consumer inquiries through our internal consumer management tool, the personal data will be usually deleted after one year if no other legal retention periods apply. As an exception, the data will be kept longer if the data is necessary for the establishment, exercise or defense of legal claims.

Call recordings are stored for a maximum of 90 days.

Legal basis:

Art. 6 (1) a GDPR in conjunction with Art. 9 (2) a GDPR (consent: telephone recording)

Art. 6 (1) b GDPR (when processing in the context of a contract or a situation similar to a contract)

Art. 6 (1) c GDPR (when processing is necessary for compliance with a legal obligation)

Art. 6 (1) f GDPR (when processing according to the legitimate interest described above)

4.   Your Rights

Your Rights and Choices

You have certain rights and choices in connection with the personal data we collect from you. To update your preferences, ask us to remove your information from our mailing lists or submit a request, please contact us as specified below.

Your rights

You have the right to request confirmation from us whether personal data relating to you is processed; if this is the case, you have a right to access to this personal data and the information specified in Art. 15 GDPR.

You have the right to request us to correct any incorrect personal data concerning you and, if necessary, to complete incomplete personal data without delay (Art. 16 GDPR).

You have the right to request us to delete personal data relating to you immediately if one of the reasons listed in Art. 17 GDPR applies in detail, e.g. if the data is no longer required for the purposes pursued (right of deletion).

You have the right to request us to restrict the processing if one of the conditions listed in Art. 18 GDPR is met, e.g. if you have filed an objection to the processing, for the duration of our examination.

You have the right to object at any time for reasons arising from your particular situation to the processing of personal data concerning you, which is carried out on the basis of Art. 6 para. 1 sentence 1 e) or f) GDPR. We will then no longer process the personal data unless we can prove compelling reasons worthy of protection for the processing that outweighs your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims (Art. 21 GDPR).

You have the right to revoke your consent to us at any time with effect for the future (right of revocation).

You have the right to receive from us the data concerning you that you have provided to us in a structured, common and machine-readable format. You can also transfer this data to other locations or have it transferred by us (right to data transferability).

Please contact us to exercise your rights: privacy@sbiomedic.com.

Without prejudice to any other administrative or judicial remedy, you have the right to appeal to a supervisory authority if you believe that the processing of your personal data is contrary to the GDPR (Art. 77 GDPR). In Belgium, the competent supervisory authority is DPA Data Protection Authority, www.dataprotectionauthority.be.

Email Opt-Out

You can at any time tell us not to send you marketing communications by email by clicking on the unsubscribe link within the marketing emails you receive from us or by contacting us as indicated below. You also may opt-out of receiving marketing emails from us by submitting a request through our email address: privacy@sbiomedic.com.

5.  Retention / Storage Period of your Data

We keep the information you provide for the duration of our relationships, plus a reasonable period in order to be able to run regular deletion routines or to take into account the applicable statute of limitation period or if required under mandatory applicable law. If you wish to receive marketing communications, we will keep the information necessary to send you these communications following the end of our customer relationship or following their collection, if you are a prospective customer.

6. Deletion/Objection:

We delete the data arising in this context once storage is no longer necessary unless statutory retention obligations exist or periods of limitation must be observed.

In case of consumer inquiries through our internal consumer management tool, the personal data will be usually deleted after one year if no other legal retention periods apply. As an exception, the data will be kept longer if the data is necessary for the establishment, exercise or defense of legal claims.

Call recordings are stored for a maximum of 90 days.

7. How We Protect Personal Data Security measures

We maintain appropriate technical and organizational safeguards to ensure an appropriate level of security of your personal data, in particular, to protect your personal data against accidental unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Our security measures are continuously improved in line with technological developments. When using our website, your personal data is encrypted using SSL/TLS technology to prevent access by unauthorized third parties. However, no security system is perfect and we cannot promise that information about you will remain secure in all circumstances, including the security of your data during transmission to us or the security of data on your mobile device.

8. Links To Other Websites

Our website may provide links to other websites for your convenience and information. These websites may operate independently from us. Linked sites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are not owned or controlled by us, we are not responsible for the sites’ content, any use of the sites, or the privacy practices of the sites. Please see and visit also our Cookies Policy.

9. Involvement of service providers and transfer of data to third parties

Your data will be passed on to technical service providers supporting us (e.g. website hosting and support) for the provision of this website and for the aforementioned purposes, which we have of course carefully selected and commissioned in writing.

These service providers are bound by our instructions and are regularly checked by us.

Otherwise, your data will only be passed on to other third parties if expressly stated in this data protection declaration or if we are legally obliged to do so.

Transfers to third countries are possible. As an appropriate safeguard standard contractual clauses pursuant to Art. 46 GDPR were concluded. For third countries/companies which fall under an adequacy decision, the adequacy decision also applies. Additionally, binding corporate rules were approved by a platform/hosting provider. More information on this topic is published here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu_en.

10. Campaigns (e.g. Sweepstakes, Product Tests)

Purpose/Information:

When you participate in sweepstakes or similar campaigns, we use the personal information you provide to conduct the campaign. Further information on the purposes can be found in the respective terms and conditions of the campaign.

The provision of your personal data is required for the performance of the contract or a situation similar to a contract. You are not obliged to provide your personal data. If your personal data is not provided, you cannot use the described service.

Recipients:

-Platform/hosting provider

-Consumer service provider

-Shipping service provider (e.g. for sending samples, prises)

-External agencies for support in campaigns

Transfers to third countries are possible. As an appropriate safeguard standard contractual clauses pursuant to Art. 46 GDPR were concluded. For third countries/companies which fall under an adequacy decision, the adequacy decision also applies. Additionally, binding corporate rules were approved by a platform/hosting provider. More information on this topic is published here: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.

Further recipients can be found in the general recipients section 1.4.

Deletion:

Your data will be deleted after the final processing of the campaign (see terms and conditions of participation) unless this conflicts with statutory retention obligations or statutes of limitations.

Legal basis:

Art. 6 (1) b GDPR (situation similar to a contract)

Purpose/Information:

When you participate in surveys or similar campaigns, we process the personal information for the purpose described in the consent. The collected data covers questions about the intended purpose of the survey or similar campaign, as well as additional socio-demographic information about you. You may participate without identifying yourself unless this has been part of the consent.

For some surveys, it is necessary to ensure technically that no double participation or resumption of the survey is possible. This can be done, for example, through the use of individualized links or cookies.

Cookies used: Type A. More information can be found in the “Cookies/Tool” section.

Recipients:

-Platform/hosting providers

-Consumer management service provider

-External agencies for survey support

Transfers to third countries are possible. As an appropriate safeguard standard contractual clauses pursuant to Art. 46 GDPR were concluded. For third countries/companies which fall under an adequacy decision, the adequacy decision also applies. Additionally binding corporate rules were approved at a platform/hosting provider. More information on this topic is published here: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.

Further recipients can be found in the general recipients section 1.4.

Deletion:

Your data will be deleted after the final processing of the survey or similar campaign (see terms and conditions of participation), unless this conflicts with statutory retention obligations or statutes of limitations. Usually, data will be deleted after two years.

Cookie lifetime: up to 180 days (this applies only to cookies that have been set by this website).

Legal basis:

Art. 6 (1) a GDPR (consent)

 

Need some help      

How To Contact us?

Contact details: privacy@sbiomedic.com