What is personal data?
Personal data is any information about an identified physical person or a physical person that may be directly or indirectly identified via an identification number or one or more elements particular to them, such as their last name, first name, date of birth, customer number, order number, photo, etc. It could also include unique numerical identifiers like your computer’s IP address or your mobile device’s MAC address, as well as cookies.
Who collects the information?
Pharma More BV pays particular attention to the processing, confidentiality and safety of your personal data. When we say “Pharma More BV”, “us”, “our” or “we”, this is who we are referring to.
The aim of this privacy charter is to provide you with clear, simple and complete information about how we process the personal data you give us or the data we may collect while you are browsing our website, how it may be transferred to third parties and your rights and options to control your personal information and protect your privacy.
Pharma More BV, located at Bommelsrede 45 – 9070 Heusden – Belgium, BTW BE 0831.762.330, is the data controller of personal data collected on the website www.lescouleursdenoir.com in the sense of regulations applying to personal data, in particular Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and the free movement of such data (hereinafter the “GDPR”).
We use your personal information only for providing and improving the website. By using the website, you agree to the collection and use of information in accordance with this policy.
What personal data might we collect?
(i) As part of the services we provide, we may need to collect certain data directly from you using electronic forms on our website or in pharmacies, or in paper form, for a range of purposes.
Information we might collect includes:
- Your identity;
- Your contact details (e.g. email address);
- Your personal preferences in relation to the products we market or to our website (language);
- Information relating to your orders, their tracking and your purchase invoices;
- Information you may provide for our customer service;
- Specific health data if you notify us of any undesirable side-effects concerning any of our products;
- Your bank details if you place an order via our website.
Personal data essential to Pharma More BV is mostly marked with an asterisk on all personal data collection forms on our website, in electronic form at some of the pharmacies, as well as off-line in paper form. If you do not fill in these compulsory fields, Pharma More BV will probably be unable to respond to your request and/or provide you with the requested services. Other information is optional and enables us to get to know you better and improve our communications and services with respect to you.
(ii) We may also collect certain data generated by your purchases of products or services, online or in pharamcies, particularly information regarding the amount and type of your purchases.
(iii) Lastly, we may collect information regarding the use of our website, especially with respect to your browsing (pages visited, links clicked, etc.). Some of this information may be collected using cookies placed in your web browser when you browse our website.
How is the date collection done?
While using our website, www.lescouleursdenoir.com, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. We obtain this data via Google Analytics, cookies and the registration procedure. Personally identifiable information is not limited to your name (“personal information”).
We can collect your personal data when you:
- Make purchases in our online shop or pharmacies;
- Join our loyalty program;
- Agree to receive marketing communications from us by email, telephone, SMS or post, depending on your selection;
- Answer surveys or satisfaction questionnaires based on your customer experience;
- Interact with our company via its official page on social networks or when we suggest re-use of content that you have published on a social network;
- Contact our customer service;
- Send requests for information to our company;
- Take part in an event we organize;
- Browse on the internet using cookies or similar technology or when you click on advertisements for our products;
- Create a customer account on our website, in the pharmacies.
For what purpose do we use your personal data?
Pharma More BV processes your data to:
- Enable you to create a customer account on our website and in pharmacies;
- Manage your access to your customer account on the Internet;
- Process and manage your online orders and their delivery;
- Record purchases made at our online store or in pharmacies;
- Secure online transactions, prevent fraud, payment incidents and manage debt collection;
- Manage customer relations with respect to any requests for information or complaints you may send us via our website, customer service or social network pages;
- Manage our loyalty program;
- Trace and manage any alerts you may send us as part of our cosmetic vigilance obligations;
- Manage and optimize your customer experience by improving our knowledge of our customers;
- Propose appropriate, tailored services, particularly when we enhance our products and services;
- Conduct statistical analyses to develop management, measuring and reporting tools in order to adjust and improve our sales, marketing and product manufacturing;
- Subject to your consent, send you information on our offers, news and events on your chosen communication media;
- Manage your participation in any events to which you have signed up.
What legal grounds legitimize the processing of your data?
Pharma More BV processes your personal information:
- To perform the contract agreed between yourself and Pharma More BV, to manage your access to your customer account and to process and track your orders;
- Within the framework of its legitimate interest for the purposes of marketing management, securing its digital media (websites, applications, etc.) and combating fraud;
- When you have given your consent for the processing of your data, especially for the purposes of managing our sales prospection, and of your browsing data via cookies, etc.;
- Within the framework of compliance with our legal obligations, particularly fiscal obligations (conserving purchase invoices) and cosmetic vigilance with regard to Regulation (EU) 1223/2009 of 30 November 2009 on cosmetic products.
Who are the recipients of your personal data?
Your personal data is processed by the personnel of Pharma More BV. We ensure that only authorized persons within Pharma More BV have access to your personal data when this is necessary for the purpose of managing our commercial relations or meeting our legal obligations.
We may also share your personal data with subcontractors, such as:
- Site hosting and maintenance service providers and the providers of our electronic personal data collection solutions in pharmacies;
- Marketing solution service providers, such as social listening, store locator, loyalty programs, identity management, ratings and reviews, CRM, web analytics and search engine, user generated content curation tools;
- Payment service providers;
- Sales prospection and social network communication service providers;
- Customer service providers;
- Service providers for managing cosmetic vigilance alerts;
- Event organization service providers;
- Consulting services in the field of market research and analytics, collect feedback and conduct market surveys on our products, services and otherwise for customer relationship management purposes;
- Services that deliver a product to you e.g. postal/delivery services.
Pharma More BV may need to share your personal data with third parties to meet its legal, regulatory or treaty obligations, or to respond to requests from authorized legal authorities.
We rely on trusted third parties to perform a range of business operations on our behalf. We only provide them with the 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 we work with will keep your personal data secure.
Some recipients of your personal data may be located abroad, including outside of the European Economic Area. All data transfers outside of the European Economic Area are subject to appropriate guarantees, especially contractual, technical and organizational guarantees, that comply with applicable regulations relating to the protection of personal data.
How is the data protected?
We are committed to keeping your personal data secure, and taking all reasonable precautions to do so. We contractually require that trusted third parties who handle your personal data for us do the same.
The security of your personal information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
How long do we keep your personal data?
We will keep your personal data for as long as we need it to provide you with your requested service(s) or to meet our commercial or legal obligations.
To determine the retention period of your personal data, we consider several criteria to make sure that we do not keep your personal data for longer than is necessary or appropriate. These criteria include:
- The purpose for which we hold your personal data;
- Our legal and regulatory obligations in relation to that personal data, for example any financial reporting obligations;
- Whether our relationship with you is ongoing, for example, you have an active account with one or more of our brands, you continue to receive marketing communications, or you regularly browse or purchase off our websites or in pharmacies;
- Whether you are no longer actively participating or engaging with our brands, for example, you do not open our emails, visit our websites, or share user generated content;
- Any specific requests from you in relation to the deletion of your personal data;
- Our legitimate business interests in relation to managing our own rights, for example the defense of any claims, or for statistical purposes.
In particular, we retain certain personal data for the following periods:
- Where you purchase products and services, we keep your personal data for the duration of our contractual relationship;
- Where you participate in a promotional offer, we keep your personal data for the duration of the promotional offer;
- Where you have consented to receive marketing, we keep your personal data until you: (i) request we delete your personal data; or (ii) after a period of inactivity (i.e. where you have not interacted with us for a period of time). This period is defined in accordance with local regulations and guidance;
- Where cookies are placed on your computer, they are stored for as long as necessary to achieve their purposes (e.g. for the duration of a session for shopping cart cookies or session ID cookies) and otherwise for a period defined in accordance with local regulations and guidance.
When we no longer need to use your personal data, it is removed from our systems and records, or anonymized so that you can no longer be identified from it.
What are the rights of the users?
Pharma More BV respects your right to privacy. It is important that you are able to control your personal data. You have the following rights:
- A right of access and information: you have the right to be informed in a concise, transparent, intelligible and easily accessible form of the way in which your data is processed. You also have the right to obtain (i) confirmation as to whether or not data concerning you are being processed, and, where that is the case (ii) to access such data and obtain a copy thereof;
- A right to rectification: you have the right to obtain the rectification of your data. You also have the right to have incomplete data completed;
- A right to be forgotten: in some cases, you have the right to have your personal data erased or deleted. Note that this is not an absolute right, as we may have legal or legitimate grounds for retaining your personal data;
- A right to restriction of processing: in some cases, you have the right to obtain restriction of the processing of your data, including profiling;
- A right to revoke the consent given: at any time, you have the right to revoke your given consent to us for using your personal data;
- A right of objection: at all times you have the right to object to certain forms of processing, such as processing for direct marketing purposes or for automatic profiling;
- A right to data portability: you have the right to receive your data which you have provided to Pharma More BV, in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller without hindrance from Pharma More BV. This right only applies when the processing of your data is based on your consent or on a contract and such processing is carried out by automated means;
- A right to object to processing : you have the right to object to processing of your data when such processing is based on the legitimate interest of Pharma More BV. Pharma More BV may, however, invoke compelling legitimate grounds for continued processing. You also have the right to object at any time to the processing of your Data for marketing purposes.
To unsubscribe from our newsletter you may also use the above channels or simply by clicking on the “unsubscribe” link at the bottom of each newsletter.
You have the right to submit a complaint to the Data Protection Authority:
Drukpersstraat 35, 1000 Brussel
Tel. +32 (0)2 274 48 00
Automated Decision Making
Automated decision making means the ability to make decisions using technology, without human involvement.
We may use automated decision making techniques for the purposes of securing transactions placed through our websites and/or devices against fraud. In addition, we may use a third party provider’s solution to protect our systems, assets etc. against fraud.
The method of fraud detection is based on a number of different data prediction and data intelligence techniques that may change over time, to keep up with technological advancement. These may include, for example, simple comparisons, or association, clustering, prediction and outlier detections using intelligent agents, data fusion and data mining techniques. This fraud detection process may be completely automated or may involve some human intervention where the final decision is taken by a person. In all cases, we take all reasonable precautions and safeguards to limit access to your data.
As a result of automatic fraud detection, you may: (i) experience a delay in the processing of your order/request whilst we review your transaction; and/or (ii) be limited or excluded from using a service if a risk of fraud is identified.
When we send or display personalized communications or content, we may use a technique known as “profiling”. This means any form of automated processing of personal data to evaluate certain personal aspects about an individual, in particular to analyze or predict aspects concerning their personal preferences, interests, economic situation, reliability, behavior, location, or movements.
This means that we may collect personal data about you in the different scenarios, and use this data to analyze, evaluate, or predict your personal preferences, interests, behavior and/or location. Based on our analysis, we may send or display communications and/or content specifically tailored to your interests and/or needs.
We ensure that we have an appropriate legal basis to process your personal data when conducting profiling activities (e.g., consent). You may have the right to object at any time to the use of your personal data for “profiling”.
Information on cookie management
This section is dedicated to our policy for managing cookies on the website www.lescouleursdenoir.com
It has been designed to provide you with information on the origin and use of browsing data processed when you use our website, together with your rights.
What is a cookie?
When you use our website, we may, depending on your choice, place a text file on your terminal (computer, smart phone or tablet) via the web browser. This text file is a cookie. Throughout the period of validity or registration, it will enable Pharma More BV to identify your terminal during subsequent visits. Only the entity issuing the cookies is able to read or modify the information they contain.
What is the purpose of the cookies issued on www.lescouleursdenoir.com ?
There are several types of cookies, some of which are issued directly by Pharma More BV and its service providers, whilst others may be issued by third parties.
I. COOKIES ISSUED BY PHARMA MORE BV AND ITS SERVICE PROVIDERS
Different types of cookies may be placed on your terminal whilst you are browsing on our website:
(i) “Essential” cookies
These cookies are essential for browsing on our website, especially for the functioning of the order process. Deletion of these cookies may cause problems with browsing on our website and make it impossible for you to place an order. These cookies are also necessary for tracking the activity of Pharma More BV. They may be installed on your terminal by Pharma More BV or by its service providers.
(ii) “Analysis and Customization” cookies
These cookies are not essential to browsing on our website, but may help you, for example, to search more effectively and optimize your purchasing experience and help us better target your requirements, improve our offer and optimize the functioning of our website.
(iii) “Advertising” cookies
Cookies may also be used for advertising purposes. These cookies ensure that the adverts you see are the most relevant to you.
What is the benefit of seeing special offers and advertising tailored to your browsing preferences?
The aim is to show you the most relevant offers and advertising. As such, cookie technology enables us to display content, in real-time, that is best suited to your fields of interest, as deduced from your browsing history on our website.
The interest you show in content displayed on your terminal when you consult a website often determines the advertising resources of this site, enabling it to provide its services, which are often supplied free of charge to users. You doubtless prefer to see offers and advertising that are relevant to you, rather than content that is of no interest to you at all. Similarly, both Pharma More BV and advertisers want their offers and advertising to be shown to Internet users that are likely to be interested in them.
Important information if you share your terminal with other users
If your terminal is used by several people or when a single terminal has more than one type of browser software, we cannot be sure that the services and advertising sent to your terminal will match your use of the terminal, rather than that of another user.
In this case, sharing use of your terminal with others and deciding your browser cookie settings are your free choice and your responsibility.
II. COOKIES ISSUED BY THIRD-PARTY COMPANIES
On our website, we may include computer applications from third parties that enable you to share our website content with others, inform others that you have been consulting our website or notify them of your opinion concerning content on our site. This particularly concerns use of the “Share” and “Like” buttons featured on social networks such as Facebook, Twitter, Instagram, Pinterest, etc. The social network providing these application buttons is likely to identify you via this button, even if you have not used it when browsing our website.
Indeed, this type of application button can enable the social network concerned to track your browsing on our website, simply because your account on the social network in question is enabled on your terminal (a session is open) whilst you are browsing our website. We have no control over how social networks collect information regarding your browsing on our website and associated with the personal data they hold.
We encourage you to read the privacy policies of the social networks to learn about the purpose, especially advertising, of any browsing information they may collect via these application buttons. These privacy policies should enable you to exercise your choices with respect to these social networks, in particular by changing your account settings. Visit the websites of the aforementioned social networks for more information about their privacy policies.
III. MANAGING THE COOKIES PLACED IN YOUR WEB BROWSER
You can decide whether to allow cookies to be installed on your terminal.
The choices offered to you by your browser software (Internet Explorer, Firefox, Google Chrome, etc.).
You can adjust your browser settings as you wish, so that cookies are either (i) accepted and registered on your terminal or (ii) refused.
(i) Agreeing to Cookies
If your browser software is set to accept the registration of cookies on your terminal, the cookies embedded in the pages and content you have consulted will automatically be registered on your terminal.
(ii) Refusing Cookies
You can set your browser software so that:
- you systematically refuse the registration of cookies on your terminal.
Important: Any adjustments you may make to the settings in your browser software concerning the acceptance or refusal of cookies may modify your browsing on the Internet and your terms of access to certain services requiring use of these cookies.
For example, by refusing certain essential cookies, you may no longer be able to place orders on our website.
If you choose to refuse the registration of cookies on your terminal or if you delete cookies that are already registered, we decline all responsibility for any consequences relating to the degraded performance of our services resulting from the fact we are unable to register or consult the cookies required for their performance and which you have refused or deleted.
How to exercise your choice, depending on your browser?
Settings vary from one type of browser software to another. Details can generally be found in your browser software help menu. We therefore encourage you to look at your settings to find out how you can make choices regarding cookies.
For Internet Explorer™: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies