PRIVACY AND PERSONAL DATA PROTECTION POLICY
1. PERSONAL DATA CONTROLLER
LABORATORIOS SUAVINEX, SAU and the other companies belonging to its Business Group (hereinafter, Suavinex) are the Personal Data Controller, for the purposes of the provisions of General Regulation 2016/679 of the European Parliament and of the Council on Data Protection, (hereinafter, the GDPR) as well as by virtue of Organic Law 3/2018, of 5 December, on Personal Data Protection and Guarantee of Digital Rights and/or any other regulations that may be applicable to this matter.
LABORATORIOS SUAVINEX, SAU with tax identification (CIF) No. A-03.123.122 is registered in the Companies Registry of Alicante in Volume 1450, Folio 32, Sheet No. A-13866. Its corporate purpose is the marketing of childcare and child hygiene products.
The company has a registered office whose contact details are as follows:
LABORATORIOS SUAVINEX, SAU
C/ del Marco, parcela R88, Polígono Industrial de Las Atalayas, 03114 Alicante - Spain
Telephone: (+34) 96 528 74 11
Email for data protection purposes: email@example.com
2. LEGAL NOTICE ON THE PROTECTION OF PERSONAL DATA
LABORATORIOS SUAVINEX, SAU, as well as the rest of the companies that belong to its Business Group (hereinafter, jointly referred to as Suavinex) agree to comply at all times with the legislation in force concerning the protection of personal data and, in particular, with General Regulation 2016/679 of the European Parliament and of the Council, on Data Protection (hereinafter, GDPR), Organic Law 3/2018, 5 December, on Personal Data Protection and Guarantee of Digital Rights, as well as any other applicable legislation on the processing of personal data, including the Law on Services of the Information Society and Electronic Commerce (LSSICE), among others.
The provisions contained in this document constitute the commitment of LABORATORIOS SUAVINEX, SAU and the rest of the companies in its Business Group regarding the collection and processing of your personal data, while serving to inform you accordingly regarding such aspects. If we make any substantial changes to this policy, we will notify you of its application with sufficient advance notice, and request any relevant consent from you for its application, thus allowing you to object if you deem appropriate.
We also inform you that you have the right to print a copy of it for your consultation at any time, as well as request us to send it electronically using the addresses that we have previously made available to you. Suavinex will duly resolve any type of communication, incident or query in this matter upon request to any of the above-indicated addresses.
2.1. What kind of personal data do we collect about you?
At Suavinex, we comply with the minimisation principle in the collection of personal data, being our objective to store the least amount of personal information possible needed for us to provide the services that you are requesting and fulfil the purposes of the collection in each specific case.
Unless otherwise indicated, the individual can always decide what data to communicate or not to Suavinex. In any case, you may complete the corresponding form at your discretion.
The type of data we process depends on the type of processing to be performed in each case. By way of example, and in a non-exhaustive and general manner, we will process identification data relating to your first name and surname, email account, social network user name and other address or contact data. In addition, and without limitation, in addition to identification data that we have about you, we will also sometimes process commercial information and/or information related to the purchase process in our online shop, commercial data and subscription to the Newsletter, as well as information on tastes and preferences. Also, when applicable, we may collect information related to the connection between your Suavinex Smart devices and the Link Application, as well as data or information related to your use of the above.
In the particular case that you are a User of the Suavinex Link Application, we inform you that we will treat both your personal and clinical data based on the information that you voluntarily provide us, which may relate to the parents or the profiles (children or pregnancies). However, the only mandatory information that we request via the Application is your first name, email and password, all of which are necessary for the configuration of your account. We may also process data relating to the connection and characteristics of your Suavinex Smart devices and their interconnection with the Application.
In the particular case of the Link Application, the data may include:
|Personal Data||Clinical Data||Connection Data|
|User data: Email, password, first name, surname, gender, date of birth and photographs.||Pregnancy:Height, pre-pregnancy weight, current weight, blood type, history of diseases, illnesses or symptoms that appeared during pregnancy, previous pregnancies, medication during pregnancy, consumption of toxic substances, clinical studies carried out during pregnancy, vaccinations received during pregnancy, serology, delivery data (gender, rupturing of the amniotic sac, fever and other data).||Connection data obtained after establishing any connection or link between Suavinex Smart Products and the User’s account in the Suavinex Link Application.|
|Children:First name, surname, date of birth, photographs.||Child profiles::Weight, height, head circumference, family history, pregnancy data, delivery data, breastfeeding, pathological history, allergies and intolerances, vaccines.|
For its part, in the case of the Link Application, the data collected will vary depending on the updates and revisions of the Application. The provision of data to Suavinex is neither required nor obligatory unless it is necessary to create and identify the User.
2.2. How do we collect your data? Sources
The personal data we process at Suavinex may come from:
- Access and navigation through the www.suavinex.com website as well as any other site or domain owned by Suavinex.
- Creation of a User account on any of our websites.
- Creation of a User account in the Suavinex Link Application, as well as the access, navigation, interaction and use of its different functionalities.
- Execution and management of the purchase process and related services.
- Contact forms hosted on any of our websites and/or any associated subdomains.
- Sending of emails, telephone conversations and other forms of communication established with our customer support services for the resolution of incidents, complaints and/or inquiries.
- Newsletter subscription forms.
- Electronic and/or offline (physical) forms for the collection of personal data that we collect through different means.
- Establishment of any kind of connection between a Suavinex Smart Product and an account in the Suavinex Link Application. All data provided in the context of such a connection is transferred to our systems.
- Commercial communications for all products and services.
2.3. What is the purpose of your personal data? Purposes
When you provide your personal data to Suavinex through the different types of collection and processing methods above, the information and/or data that you provide us as the owner of this data may be incorporated into a personal data file for which Suavinex is responsible, where the data will be treated according to the specific purposes that you authorised at the time of data collection, and of which we will have promptly informed you.
In this sense, the personal data you provide us may be used for the following purposes, always according to each specific case for which you expressly authorised us and always according to the basic information that we have provided in the collection form in each case:
- Creation and configuration of a User account on our Website, as well as navigation and subsequent use of the same.
- Creation of your User profile in the Suavinex Link Application so that you may store the data provided to us in it for the customisation of the different fields and enabled functions.
Activation and use of functionalities in the Suavinex Link Application, and navigation through it.
- In this regard, we inform you that the data collected in the Suavinex Link Application may also be used to provide you with information about the profiles you created, as well as offer you personalised content, messages and tips.
- We may also use your data stored in the Suavinex Link Application to perform studies to find and analyse patterns and statistics such as growth statistics, statistics by area, age or gender, etc. In these cases, we undertake to extract and process the data for the above purposes in an aggregated and anonymous manner, eliminating any type of personal information corresponding to the Users.
- Enable the connection between your Suavinex Smart Products and your account in our Suavinex Link Application.
- Enable the connection between your Suavinex Smart Products and third-party managed external voice assistants. In these cases, we also inform you that such assistants receive any personal data of the interested User at any time for which Suavinex is responsible unless you have expressly granted your consent to this effect.
- Management of the purchase process and related services in cases where you have provided us with your data to make a purchase or use the Suavinex Online Shop.
- Attention to your requests and queries, whatever the means of communication you have established (web contact forms, emails, live chats and phone calls, among others).
- Sending of promotional and commercial communications relating to our products and services, as well as the sending of our corporate Newsletter, only when you subscribe for this purpose. In this sense, we want to inform you that our Newsletter will contain diverse content such as commercial information with news related to product and collection launches, invitations to participate in studies, contests, raffles and other activities, information about discounts, offers and promotions, as well as relevant corporate information concerning Suavinex or the rest of the companies of its Business Group. The Newsletter may also contain information and relevant news related to the products or sector in which Suavinex and the other companies of its Group operate, presently the childcare, small electrical appliance, cosmetics, dermatological care, perfumery, pharmaceutical and hygiene sectors.
- Moderation of participation in the Suavinex blog, as well as manage and monitor the User’s intervention in it.
- Participation in contests, dynamics and research.
- Conduct of studies, statistics and profile analysis.
- Any other purpose notified during a Registration process and provision of your data to Suavinex.
- All of the purposes listed above.
As the owner of your data, you have the right to withdraw your consent at any time, as well as request clarification of any purpose you deem appropriate.
If at any time we decide to expand or modify any of the above purposes, we will send you a notification requesting your express consent to this end, assuming the commitment not to perform any processing not included in the purposes in each case accepted by the owner of the data.
Similarly, and under the provisions of the GDPR, Suavinex may obtain data from other subjects through duly authorised third parties within the framework of a legitimate assignment, as well as through sources accessible to the public, and undertakes to inform no later than one month after its collection from the owner regarding the origin of the same and the rights recognised by the Regulation with respect to it, and in any case, regarding how to exercise the rights of access, information, transparency, rectification, deletion, opposition, limitation of the processing and portability of the data in any case. In this sense, the promotional census, telephone directories and lists of members of professional groups are considered sources accessible to the public, among others.
In compliance with the provisions of the Law on the Services of the Information Society and Electronic Commerce, in the forms provided for the collection of personal data or participation in any promotion, the owner of the data must expressly consent to the subsequent use of his/her data for the sending of commercial communications by any means (ordinary post, electronic mail, telephone and, in general, any data in the specific communication provided.).
We also expressly inform you that when you provide your data for subscription to the Newsletter, you are authorising us to send you commercial communications to any of the means of contact that you provide us.
2.4. Who will access your personal information? Our recipients
The personal data you provide may be accessed by employees of LABORATORIOS SUAVINEX SA and other companies belonging to its Business Group, which shall process this data in accordance with the authorised purposes, at all times, respecting its safety concerning its inherent risk, and confidential or secret nature.
At Suavinex, we will not transfer your personal data to third parties not related or expressly authorised by us or which are not part of our Business Group, unless such transfer of data is covered by a legal obligation or when the provision of a service implies the need to enter into a contractual relationship with service providers who maintain a contractual relationship that guarantees confidentiality and compliance with the requirements established in current regulations on the protection of personal data. In this way, we may share your personal information with certain suppliers who provide us with services or carry out activities on our behalf or in our interest after signing the contract.
In this sense, we want to inform you that on certain occasions it may be necessary for Suavinex to communicate the data you provided us to other companies that are part of our Business Group for internal purposes, and to ensure compliance with the indicated purposes. Personal data will be stored and processed within the European Union. However, in the case of any processing of personal data outside the European Union, this processing will be subject to the adoption of adequate guarantees in accordance with the provisions of current regulations. By submitting your personal information, you agree to these types of transfers or processing. If the applicable regulations require us to obtain your prior consent to carry out the above activities, we guarantee to request it promptly for this purpose.
The personal data that we collect will only be accessible to the Suavinex employees who need to know it for the provision of the purposes indicated in point 2.3 of this privacy notice and as authorised in each case. Our employees will treat the accessed data with the confidentiality that it deserves and only for the provision of authorised services. All access to the data by unauthorised subjects is prohibited, except legal obligation.
We also inform you that some of the tools we use to process your data are contracted by third parties, with whom we undertake to sign the relevant Data Processor contracts for the correct processing of your personal data.
2.5. What rights do you have as a data subject? Rights and their exercise
In compliance with the provisions of the GDPR, we inform you that you have the right to exercise your rights of transparency, information, access, rectification, deletion, limitation of processing, data portability, and opposition recognised by the regulations.
Suavinex is at your disposal to provide you with any information regarding the content of the right, as well as the enforcement of any of the above rights. Therefore, we will answer any questions you ask us in this regard depending on your need.
To exercise the above, you can contact Suavinex at any time using any of the following contact formats, indicating the right you wish to exert in your communication:
Ordinary post: LABORATORIOS SUAVINEX, S.A to the attention of the Legal Department, Calle del Marco, Polígono Industrial Atalayas, Parcela R88, 03114 Alicante, Spain
You also have the right to withdraw your consent at any time, without affecting the lawfulness of any previous data processing based on a prior consent, taking into account the legal requirements for data retention. Similarly, you have the right to file a claim with the Spanish Data Protection Agency or any other competent control authority. To exercise your rights, you must be able to prove the ownership of the data, by showing your national identity document or similar identification document.
2.6. What is our legitimate interest in processing your data? How long do we retain your data?
At Suavinex, we undertake to properly inform you about the purposes and legitimate interest on which we rely for the processing of your data before each collection, as well as the period during which we retain your data, which are listed below:
|Purpose||Legitimate interest||Retention period|
Creation of a User Account on any of our Websites.
Configure and give access to the functionalities derived from the registration, and enable navigation through the different sites of the Group.
|Validly expressed consent of the owner of the data in the Registration process.||We will keep your data for as long as you maintain your status as a registered User and as long as you do not validly withdraw your consent.|
|Creation of a User account in the Suavinex Link Application, and access, navigation and use of its functionalities.||Duly expressed consent of the owner through the relevant contact form before registering for the Application, after marking the corresponding confirmation box.||We will retain the personal data obtained from your access and navigation in the Link Application for as long as you continue to be interested in the purposes for which you provided it to us, that is, as long as your account remains active and you do not deactivate or delete it, and thus stored for the sole purposes of navigation and use of the Application.|
|Connection between your Suavinex Smart Products and your User account in the Suavinex Link Application.||We will treat the data provided based on your consent, which we will request during the connection and/or linking procedure between your account in the Application and your Suavinex Smart Product, which you perform in each case for this purpose.||We will retain your data as long as you do not validly withdraw the consent provided in each connection or linking procedure.|
|Management of the purchasing process and related services.||Execution of the contract of sale or provision of services and compliance with legal obligations. If within the framework of this processing, you decide to activate authorisations for additional processing, these authorisations will be processed based on your consent.||
We will treat your data for the time required for the execution of the sales contract and subsequent additional services (inquiries, returns, claims, after-sales service, etc.).
In addition, we will retain a posteriori the information and data related to the commercial relationship for the legally determined period.
Attention to requests and queries.
This processing is applicable regardless of the route chosen by the owner to establish contact with the Data Controller company, be it access via email, post, social networks, web form, telephone consultations or LiveChat.
If the query is not related to the prior sale of a product or service, we will process the data based on your previously requested informed consent. However, we believe that we have a legitimate interest in processing this data to improve the quality of our products and services.
If you have a query upon the purchase of a Suavinex product or service, we will also be legitimised by the execution of the signed purchase agreement.
Finally, if the consultation is based on the exercise of a legally recognised right or claims about our products, we will be legitimised by the fulfilment of our legal obligations.
In the case of queries not related to a product purchase, we will retain your data as long as you do not specifically withdraw the consent provided for this purpose.
In the case of queries based on incidents derived from a product purchase and the exercise of rights, we will retain the data for the time necessary to manage the request, keeping it a posteriori for the retention period required by law.
In all cases, we may also keep your data a posteriori to carry out studies and statistics, based on your consent provided under the terms of this document and additionally on the legitimate interest that assists us for this purpose. In these cases, please note that the information that we process for study or analysis will always be aggregated and anonymous, provided that you have specifically authorised us to do so, and committing ourselves in such circumstances to anonymise the data, therefore, treating its content on an aggregate basis.
|Participation in our Blog, Living Suavinex.||Informed consent of the data subject, previously requested and validly expressed through your agreement by checking the corresponding acceptance box.||We will continue to treat your data as long as the authorised purposes remain unaltered over time, or as long as you do not take any action to the contrary to inform us that you are no longer interested in these purposes.|
|Studies, statistics and analysis of profiles and/or the market.||Duly expressed consent of the data subject.||We will treat your data until we anonymise it. Afterwards, we will only retain the resulting information in an aggregated way to study it for analysis.|
|Participation in contests, dynamics and research.||We will treat the data based on the validly expressed consent of the participating interested parties, according to the specifications in each individual form.||
The data retention period will be adjusted in these cases to the specifications in each individual form for collection.
The data retention period will be adjusted in these cases to the specifications in each individual form for collection. In general, but without prejudice to what is expressly indicated in each form, we will store the information for the time necessary to fulfil the purposes of the activity to be carried out, provided that we have not notified you regarding a different purpose in the form, without prejudice to other legal obligations.
|External data collection forms for various purposes.||The data subject’s previously expressed consent, unless otherwise indicated in the form||The period indicated in the individual form, always keeping in mind the purpose of the collection .|
Finally, and with regard to the retention time of the information provided, we inform you that the retention times are as described above, without prejudice to those cases in which we must keep your data for a more extended period to comply with legal or contractual obligations of any kind.
2.7. How long do we retain your personal information?
At Suavinex, we consider the needs of each data processing, and we undertake to eliminate the personal information of individuals once the purpose of collection has been fulfilled, and according to point 2.6 of this Policy, as long as no other retention obligations exist.
Notwithstanding those mentioned above, in case of contradiction, the information retention periods shall be those that are expressly indicated in the corresponding data form.
Regardless of the periods described above and without prejudice to the legal retention obligations that may exist, you will have the right at any time to unsubscribe from the corresponding processing list, requesting the elimination of any personal information that concerns you.
2.8. Can I unsubscribe from the Newsletter and delete the personal data connected to my User account?
Concerning the sending of our Newsletter and, in general, any type of commercial communication, if at any time you cease to be interested in its content, you can contact Suavinex by any of the above-indicated means to request the elimination of your personal information and stop receiving communications for this purpose, and without prejudice to other possibilities of withdrawal according to the specific purpose of data collection, in the following cases:
- In cases where your personal data has been obtained through the creation of an account, we will keep it as long as you do not deactivate or delete the account.
In cases where your data has been obtained through a subscription to the Newsletter, we will continue to treat your data and send you commercial communications as long as the purposes of our Newsletter do not change or you do not expressly disable this option, which you can do as follows:
- If your subscription to the Newsletter was made directly from the form enabled for this purpose on the web, to unsubscribe you must click on the corresponding link provided in all our communications or send us an email to firstname.lastname@example.org where we will attend to your request.
3. CONFIDENTIALITY AND SECURITY IN THE PROCESSING OF DATA
Suavinex adopts both the technical and organisational security levels required by current legislation to ensure the security of your personal data, avoiding its alteration, loss, processing and/or unauthorised access. Suavinex also undertakes to review the personal data received and analyse the risk related to it for the Application of any necessary protection measures.
However, technical security in a medium such as the Internet is not impregnable and there may be leaks due to malicious actions of third parties, which we undertake to combat promptly, and which we will notify you of, if necessary.
4. COOKIES POLICY
When you access any of Suavinex’s websites, certain information may be stored on the User’s computer in the form of cookies. Cookies use an automated procedure to collect information regarding the preferences determined by a User during a visit to a particular website. This information is recorded in small files that are imperceptibly stored in the computer equipment of the corresponding User. Thus, each time the User accesses the website, these files are automatically activated to configure the site with the preferences indicated during previous visits. In any case, the User may configure their Internet browser to prevent the creation of cookie files or to be warned when this happens.
5. PERSONAL DATA OF MINORS
Any data of minors that may be provided by Users in the context of use of the Suavinex website and/or Application must be communicated solely by the legal custodian of the minors according to the terms of article 3 of Organic Law 1/1982 of 5 May on Civil Protection of the Right to Honour, Personal and Family Privacy and One’s Own Image.
The above statement is an essential requirement for the correct use of the website, the Application and, in general, any product/service provided by Suavinex that involves the processing of the personal data of minors.
6. INTELLECTUAL PROPERTY
To consult Suavinex’s Intellectual Property Policy, the User must access the corresponding clause of the applicable Legal Notice
7. APPLICABLE LAW
Your visit to our Website implies your acceptance of Spain’s legislation and applicable laws.