Personal Data Management Policy

FRESH FORMULA S.A. considers it obligation to protect the personal data of its web site visitors, and believes that it is very important for its reputation to use the personal data in a responsible manner. Therefore, it has adopted and is implementing the present Personal Data Management Policy, aiming at informing the company site visitors about the kind of personal data that might be collected, as well as the purposes for which this data may be used. The Personal Data Management Policy may be amended at anytime. Therefore, we advise you to frequently visit the relevant web page.

2. Type and use of the data collected

2.1. If you are under 18 years of age, you may browse our Site. However, you may not provide personal information to us. For example, you cannot register or make a purchase. This Site is not designed for minors and we do not knowingly collect personally identifiable information from any person under 18 years of age. If you are under 18 years of age and have any questions or concerns about this Site, please seek guidance from a parent or responsible adult.

2.2. The extent and type of the information we receive from you on our website depends on your actions during your visit at the website in question: 
a) If you visit our website in order to read or download information, the data we collect - such as the Internet domain you are connected to, the time and date of accessing the website, and the Internet link through which you were redirected to our website - is being used exclusively for statistical purposes and in order to help us make the website easier for you to use. However, this data is unreadable at personal level. That is, they are not connected to any name, address or other readable personal data. Your personal data is being used in order for us to provide you with personal services and only under the condition that you have provided us with this information. For example, if you send us an e-mail asking for information, we will use this e-mail address in order to respond to your request. The information we collect will be maintained only for the period of time necessary for us to satisfy your request or for as long as the law requires. Personal data shall not be disclosed to a third party without your prior explicit consent. 
b) As long as the e-shop is concerned, if you decide to complete a user registration form, complete an online survey or make a purchase, you may be asked to provide certain information such as your contact information (name, email address, mailing address and telephone number), birthday, gender and product and/or cosmetic concerns, and the brands and products you use. If you decide to place an order, we will also need to know your delivery and billing address, and maybe credit card number and expiry date. Please note you may be transferred to a third party service provider's website in order to submit this information. Sensitive information is not generally sought through this Fresh Line Site. Sensitive information includes data relating to: race or ethnic origin; political opinions; religious or other similar beliefs; physical or mental health. If you do provide sensitive information, by providing that information you explicitly consent to us using it in accordance with the Privacy Policy. If you would prefer that we not collect any personally identifiable information from you, please do not provide us with any such information. Please note that if you do not wish to provide any personal information, you will not be able to make purchases through the e-shop. To protect your personal information, users registering at this Site must also enter a user name and password. Prior to your submission of your personally identifiable information to this Fresh Line Site, you will be asked whether you consent to the processing and transfer of your personal information. If you consent, in addition to the essential service related announcements that we will send you, the information you provide may be used to create and deliver to you our newsletters, surveys or other communications containing product and event information, cosmetics tips or promotions. For example, we may look at what you have previously ordered in an attempt to tell you about promotions that will be of particular interest to you. We will also assume that you have indicated your consent to opt-in if you have given us your details when placing an order without opting-out by un-ticking the consent boxes. If you prefer not to receive such Communications, please do not opt-in to receive these communications or, if you are giving us your details when placing an order, please opt-out when given the opportunity to do so. If you do opt-in (or if you do not opt-out when placing an order) and later decide that you would no longer like to receive these communications, you may opt out of receiving future communications when you register at this Site or otherwise provide your contact information to us. You may change your preferences at any time by clicking the "unsubscribe" link at the bottom of each Communication e-mail you receive. Please note that this opt-out only applies to Fresh Line Site Opt-in Communications and does not apply to communications to serve you.

2.3 We may share your personally identifiable information with our affiliates and other divisions of our company that distribute and market Fresh Line products (the "Group Companies"). Group Companies may use this information in accordance with this Privacy Policy. We will not provide your personally identifiable information to third parties for their use in marketing their products or services to you without your consent. We may disclose any information, including personally identifiable information, we deem necessary, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request. We may also exchange information, including personally identifiable information, with other companies and organisations for credit fraud protection and risk reduction.

2.4. If you elect to participate in any promotions, surveys, questionnaires or other events during your visit to our Fresh Line Site, the rules or terms and conditions for those events may indicate that your personally identifiable information will be shared with third parties. By choosing to participate and submitting your personally identifiable information with respect to such events, you consent to disclosure of your personally identifiable information to such third parties. This Site is not responsible for, and disclaims all liability for, any use of the information you choose to provide to such third parties.

2.5 We may use the information you provide in aggregate (non-personally identifiable) form for internal business purposes, such as generating statistics and developing products and marketing plans. We may collect, store or accumulate certain non-personally identifiable information concerning your use of the Site, such as information regarding which of our pages are most popular. We may share or transfer non-personally identifiable information with or to our affiliates, licensees and partners. We will take reasonable steps to create an accurate record of any personal information you have submitted through this Site. However, we do not assume responsibility for confirming the ongoing accuracy of your personal information. You are responsible for keeping your information on file with us up to date. You may review and change the personally identifiable information you provide to us at any time by calling us to +30 210 6022242-3.

3. Cookies (small text files) The visitors of the website should be aware of the fact that, upon reading the pages of the website, information of nonpersonal nature may automatically be collected in the form of small text files (cookies), which are being used to identify the visitors of the website and facilitate its use. Most Internet browsers identify when a cookie (small text file) is being provided and offer you the possibility of disabling it, although disabling the cookie will not allow you to enjoy the website to its full extent. These cookies will expire when you place an order. In addition, there are advertising banners that might be placed on the website. These ads have been created and provided by third parties and may install cookies on your computer gathering information about you and how you use the Internet. 
FRESH FORMULA S.A. shall not be held responsible for the personal data collected through the above-mentioned ads, since the present Personal Data management policy does not apply in them. 
We may also use IP addresses to analyze trends, administer the Fresh Line Site, track traffic patterns, and gather demographic information for aggregate use, as well as in combination with your personally identifiable information for credit fraud protection and risk reduction. 
When you visit this Fresh Line Site or view one of our emails, we may use pixel tags (also called "clear" gifs), tracking links and/or similar technology to note some of the pages you visit on our Fresh Line Site and personalise your experience. We may also use pixel tags to determine what types of email your browser supports. We may use the information collected through pixel tags, tracking links and similar technology in combination with your personally identifiable information. Some of our other business partners and service providers may also use cookies on their sites. For example, you may have clicked through to our Site from one of their sites. We have no access to, or control over, these cookies and do not accept any responsibility for such third party cookies. Please refer to the privacy policies posted on the applicable third party website to understand the third party's use of cookies and your options relating to those cookies.

4. Links 
Our site contains links to other sites. FRESH FORMULA S.A. shall not be held responsible for the content and the Personal Data Management Policy applied by them nor for the potential use of your personal data by those sites. For this reason, we advise you to carefully read the Personal Data Management Policy they implement before using them in any way. Links appearing on the Site are for convenience only and are not an endorsement by us, our affiliates or our partners of the referenced content, product, service, or supplier. Your linking to or from any off-Site pages or other Sites is at your own risk. We are in no way responsible for examining or evaluating, and we do not warrant the offerings of, off-Site pages or any other Sites linked to or from the Site, nor do we assume any responsibility or liability for the actions, content, products, or services of such pages and Sites, including, without limitation, their privacy statements and terms and conditions. You should carefully review the terms and conditions and privacy policies of all off-Site pages and other Sites that you visit.

5. Security 
FRESH FORMULA S.A. has safety clauses for the protection of your personal data against inappropriate use, loss, alteration or unintentional distraction. The members of our staff having access to this data have been properly trained to uphold the confidentiality of such information. Nevertheless, given the fact that Internet transmissions cannot be absolutely secure, FRESH FORMULA S.A. cannot guarantee the integrity and security of this information during transmission and the data is being transferred at the sender's own risk. After the reception of the personal data, FRESH FORMULA S.A. shall take any and all appropriate measures for their integrity and security.