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SCHOLL'S WELLNESS COMPANY – INTERNATIONAL PRIVACY POLICY

Welcome to the Scholl Global Privacy Policy (“Privacy Policy”).

We are committed to protecting your privacy. This Privacy Policy applies to all of our brands internationally and explains how we collect, use, disclose and protect your personal information and respect any rights you may have under the law in your country.

In this privacy policy, “we”, “us” and “our” refer to all companies within the Scholl Group. Because this Privacy Policy applies globally, the methods of collection, use and disclosure of your personal information may vary from country to country, in which case we will notify you of any specific processing activity taking place in your country.

Your personal information is controlled by Scholl's Wellness Company Limited (whose registered office is at 2, Arlington Square, Downshire Way, Bracknell, RG12 1WA, United Kingdom, Europe ). or by our Scholl company located in your country . With regard to this website, the company that collects, processes and shares your personal data is: Scholl's Wellness Company SARL located at 3-5 Rue Saints Georges 75009 Paris, France .

For more information about us, our local companies, our brands and our presence in your jurisdiction, please visit www.scholl.com.

Definitions

By “personal data” (in some countries referred to as “personal information” or “personally identifiable information”), we mean any information relating to an identified or identifiable natural person. This goes beyond information of a personal or private nature, and also includes information such as your name, date of birth, and email address.

By “sensitive personal information” (in some countries called “sensitive personal data” or “special categories of data”), we mean any personal information relating to a person's racial or ethnic origin, political opinions, beliefs religious or philosophical beliefs, trade union membership, genetic or biometric data processed for the purposes of uniquely identifying that person, data concerning their health or data concerning a person's sex life or sexual orientation. This also includes information about a person's criminal offenses or convictions, as well as any other information deemed sensitive under applicable data protection laws.

1. Scope of our privacy notice

Our Privacy Policy applies to all personal data that we collect, use, share or process through our business activities, both online and offline, that display, link or refer to this Privacy Policy, including Understood :

  • our websites;
  • our official social media pages;
  • our emails;
  • our applications;
  • your online and offline campaigns;

And

  • your conversations or correspondence with our representatives.

Throughout this document, we will refer to our online activities as “Sites” and our offline activities as “Services”.

You should be aware that our Sites may contain hyperlinks to third party sites, applications, etc., which are not controlled by us and are not covered by this Privacy Policy. We are in no way responsible for the contents and activities of these sites, third-party applications, etc. Since these third parties may collect your personal data, we suggest that you review their privacy policies to learn more about their use of your personal data.

Our websites use cookies. For more information on this topic, also see our Cookie Policy .

In addition, when you use our Sites or Services, please also read our applicable Terms of Use.

2. Fair and legitimate treatment

In some cases, where local law requires us to do so, we may ask for your explicit consent to process your personal information for specific purposes.

We only collect, use, disclose or process your personal data where it is fair and legitimate to do so.

If you do not wish to provide us with your personal data, we may not be able to provide you with the products and services you request.

3. How do we obtain your personal data?

Personal data obtained directly from you

Initially, we may obtain your personal data directly from you, for example, when you subscribe to our newsletters, register on our sites, purchase a product, complete a survey, make a comment or request, post a information on our social media pages, subscribe to direct marketing communications, etc.

Personal data collected in this way may include:

  • name ;
  • address ;
  • e-mail address ;
  • username ;
  • telephone number (and records when you contact our dedicated consumer line);
  •  credit card or other payment information;
  •  age ;
  • date of birth ;
  • gender;
  • household data;
  • information, comments or content you provide regarding your marketing preferences;
  • user-generated content, messages and other content you submit to our sites;
  • in rare cases, information you have provided to us about your family or other people. In such cases, we assume that you have the authority to share any personal information provided about them;
  • sensitive personal information such as information related to your image, health (including information related to product use and medical history), sex life (and related behaviors), and biometric data collected during research studies with voluntary consumers (such as facial expression recognition, heart rate and skin condition);
  • demographic information; Or
  • any other personal data that you provide to us directly and voluntarily.
  • We will advise you whether you are required to provide any personal information when sending a survey to you.

Personal data collected automatically

Second, certain personal data may be collected automatically when you visit or use our sites (and from our third party service providers acting on our behalf), including information collected by cookies and other technologies (such as analytics tools). web and pixel tags) on our websites. Also see our Cookie Policy for more information on how we use cookies and other automated means of data collection.

Personal data collected in this way may include:

  •  Information relating to your (mobile) device or browser;
  •  Information about how you use our websites, such as details of the web pages viewed, banners and hyperlinks clicked, etc. ;
  •  the opening by you of emails that we have sent to you;
  • websites visited before arriving at one of our websites;
  • your IP address;
  • the hyperlinks you clicked on;
  • your username, profile picture, gender, network and any other information you choose to share when using third-party sites (such as the “Like” feature on Facebook or the +1 feature on Google+);
  • your MAC address;
  • information you choose to share using the social media tools integrated into our websites or your social media login credentials to access certain sites and applications for RB products; And
  • information you tell us about your location. Where local law requires us to do so, we will only use this information when you have consented to it.

Personal data obtained from other sources

Finally, we may also collect personal data about you from other sources. These sources may include:

  • our trusted business partners;
  • social media sites;
  • consumer research organizations;
  • credit reference agencies;
  • intermediaries facilitating data portability; and
  • other members of our group.

The personal data thus collected may include, your interests such as hobbies and pets, consumer and market research data, purchasing behavior, public data or activities such as blogs, videos, internet posts and user-generated information.

4. For what purpose can we use your personal data?

We may use your personal data for commercial purposes such as:

  • based on your contract with us, to process and manage your purchases, for example, to provide you with information regarding your purchases, to process your payments, to deliver the products and services purchased, and to provide you with customer service necessary ;
  • allow you to participate in promotions, competitions, surveys and polls;
  • allow you to share information and ideas on our pages on social networks, forums, blogs and other communication channels, participate in social sharing and send messages to a friend through our sites or on the sites of our commercial partners trust ;
  • better understand your needs in order to provide you with more relevant information, analyze and evaluate our business activities, carry out tests, develop and evaluate new products and improve our existing products and services, carry out market studies and audits, identify market trends use and examine the degree of effectiveness of our marketing campaigns and the degree of satisfaction of our customers;
  • inform you about our products and services, and send you promotional materials (such as new product announcements, promotions, savings programs, joint promotions and other programs) related to our brands and those of our business partners carefully selected trusted sites, subject to your consent to marketing communications where required by local law;
  • manage our sites, and match the experience and content of our sites to your previous activities on our sites, in order to personalize your experience;
  • respond to your requests or questions;
  • process any adverse event you report to us in relation to a product;
  • carry out the general administration of our files; And
  • meet legal and regulatory requirements.

Your local law may require us to set out in this privacy notice the legal bases we rely on to process your personal information. In such cases, our use of your personal information is permitted by law because:

  • it is necessary for our legitimate interests in efficiently providing information, services and products to you and in running our business efficiently and lawfully (in each case, to the extent that such interests are not overridden by your rights);
  • it is necessary to take steps to enter into a contract with you for the products you purchase, or to fulfill our obligations under such a contract.
  • it is required to satisfy any legal or regulatory obligation to which we are subject; And
  • in limited circumstances and where required by local law, you have agreed to us processing your personal data, for example where you have agreed to receive marketing communications, or to us processing it with your explicit consent in the case of sensitive personal information, such as information about your health.

We may create anonymous data records from personal data by excluding information (such as your name) that identifies you. We use this anonymous data to analyze our products and services. We reserve the right to use this Anonymous Data to disclose Anonymous Data to third parties, including, without limitation, our research partners, in our sole discretion.

5. Who may we disclose your personal data to?

Intra-group sharing

Your personal data may be shared between the different companies and brands within our group, for the purposes set out in this privacy notice. As noted above, this privacy notice applies to the use of your personal data by all of these companies and brands.

Third-party service providers

We may share your personal data with trusted third-party service providers who work on our behalf, such as marketing agencies, market research firms, e-commerce agencies, software, providers of data hosting and other IT services, merchants who sell RB products, call centers, payment systems, etc. These third party service providers are required to use your personal data only to provide the services we have requested and in accordance with our instructions.

Other trusted third parties

We may also share your personal data with other trusted third parties, such as our business partners, advertising agencies (where we are authorized to do so) and data exchange providers, in order to be able to offer you personalized content, including more relevant advertisements for products and services that may be of interest to you. These third parties may set and access their own cookies, web beacons and similar tracking technologies on your device in order to provide you with personalized content and advertisements when you visit Scholl websites.

Our websites and/or applications may also allow you to log in using a social media or other third party account. “Log in on Facebook” is an example of a third party login.

Connecting to one of our sites with your social network or other third party account may allow us to collect information that you authorize us to view on that social network or from that third party. The login function may also transfer information to the social network or third party, such as your username and password, in order to identify you. The social network or third party may also collect information automatically, such as your IP address, information about your browser and device, and the address of the web page you visit on our site. The login function may also install and read cookies from this third party which may contain a unique identifier assigned to you by the social network or another third party. The Login Feature and your use thereof are governed by the privacy policy and terms of the party providing the Login Feature rather than this Privacy Notice.

Acquisitions

If another company acquires (part of) our company, business or assets, that company may acquire some or all of the personal data collected and will assume the rights and obligations relating to your personal data as described in this notice of acquisition. confidentiality. In the unlikely event of insolvency, bankruptcy or receivership, your personal data may also be transferred as a business asset, subject to applicable law.

Necessary Disclosures

We may disclose your personal data if we believe in good faith that such disclosure is necessary or prudent given our obligations under applicable law:

  • as part of a judicial investigation;
  • to comply with applicable laws or respond to court orders, subpoenas and warrants served on us;
  • to protect or defend our rights;
  • to investigate or help prevent any potential violation of the law, this Privacy Notice, or any applicable terms of use.

6. How do we protect your personal data?

We appreciate the trust you place in us. We have put in place appropriate technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access and against any other form of unlawful processing.

When collecting and transferring sensitive personal information, we use many additional security technologies and procedures to help protect your information.

The personal data you provide to us is stored on computer systems located in controlled facilities which can only be accessed by a limited number of people who need it to carry out their tasks and any requested services.

When we handle highly confidential information (such as credit card numbers) over the Internet, we protect it using encryption techniques.

7. Your direct marketing choices

We may periodically send you newsletters, surveys, offers, and other free promotional materials related to our products and services that you may find useful, if you have opted to receive these messages by email or other electronic means. (where such consents are required by local law).

If you no longer wish to receive these communications, you will always have the opportunity to unsubscribe by following the unsubscribe instructions in each of our direct marketing emails or by contacting us directly (see our contact details in the “How to contact us” section). below).

Where permitted by applicable law, we may send you service messages identifying any updates to our privacy notice (even when you have opted out of receiving marketing messages from us).

8. Your rights

Depending on your location, you have various rights in relation to your personal data. In particular, you may have the right to:

  • ask whether or not we process personal data about you, where this right is granted to you under local law;
  • request information about our processing of your personal data, where this right is granted to you under local law;
  • request a copy of the personal data we hold about you;
  • ask us to update the personal data we hold about you, or to correct any personal data which you believe to be incorrect or incomplete;
  • request that we delete the personal data we hold about you or restrict our use of your personal data (the “right to be forgotten”), provided that where your local law requires it, we will delete this personal data as soon as possible if it was collected when you were under 18 years of age;
  • to define guidelines relating to the conservation, erasure and communication of your post-mortem personal data
  • withdraw your consent to our processing of your personal data at any future time (to the extent that such processing falls within your consent);
  • object to the processing of your personal data (including for direct marketing purposes); Or
  • request the transfer of your personal data to you or another data controller (the “data portability” right).

Additionally, in certain cases we may process your personal data through automated decision-making processes, including profiling. This may include segmentation and personalization of data to enable us to match our communications and products to your perceived needs. Depending on your geographic location, you may request not to be subject to automated decision-making, including profiling.
Depending on your geographic location, you may also have the right to provide instructions regarding the storage, deletion or disclosure of your personal data upon your death.

If you would like to exercise these rights or understand whether they apply to you, please click here to complete and submit an online request form. You can also contact us using the contact details provided in the “how to contact us” section below.

9. Complaints

If you are unhappy with how we have processed your personal data or a privacy-related question or request you have raised with us, you have the right to lodge a complaint with your local privacy regulator. data protection, the National Commission for Information Technology and Liberties (CNIL).

10. How long do we keep your personal data?

We will only keep your data for as long as reasonably required for the purposes set out in this privacy notice or to comply with any legal or regulatory requirements to which we are subject.

When your personal data is processed:

  • for the performance of your contract with us, we retain your personal data for 7 years from the date of execution of a contractual order;
  • to comply with legal and regulatory requirements, we retain your personal data as stipulated by applicable law; And
  • In all other cases, we process your personal data according to their type, up to 2 years from the date of our last interaction with you. .

11. Children

Most of our sites are not intended for children, and we require that children under the age of 18 not provide personal information through our sites.

If you are the parent or legal guardian of a child under 15 years of age registered on one of our sites, or if you believe that they have otherwise provided us with personal data, please contact us using the contact details stipulated in the “how to contact us” section below to have them deleted. Information provided voluntarily by children through emails, forums, chats, etc. may be used by other parties to generate unsolicited emails. We encourage parents and legal guardians to teach children how to use the Internet in a safe and responsible manner.

Depending on your geographic location and permissions granted by local law, we may collect information about your children in order to provide you with relevant information about our products and services.

12. Transfers to other countries

Your personal data may be transferred to and processed in other countries where the laws governing the processing of personal data may be less stringent than those in your country (including jurisdictions outside the European Economic Area).

In such cases, where required by local law, we will ensure that adequate safeguards are in place to ensure the protection of your personal data. Depending on the location of the RB entity exporting the relevant personal data, this adequate protection may take the form of a data transfer agreement with the recipient, based on standard contractual clauses approved by the European Commission. Where we are legally required to do so, further information about such transfers and copies of such agreements are available on request from us.

By using our sites and services, to the extent required and valid under your local law, you explicitly consent to your personal data being transferred and processed in this way.

13. How to contact us?

We appreciate your comments. If you have any comments, questions or complaints about this privacy notice or our processing of your personal information, or if you wish to exercise any of the rights set out in “Your rights” above if they apply to your location, you can contact us by emailing fr_care@scholl.com.

You can also write to us at:

Scholl Global Privacy Office,
2, Arlington Square,
Downshire Way,
Bracknell,
RG12 1WA
United Kingdom

14. Changes to this Privacy Notice

This privacy notice was modified on April 1, 2022. This document is a notice to you and not a contract between us. We may modify or amend it from time to time. When we make changes to this Privacy Notice, we will update the revision date at the top of this Privacy Notice.

If these changes are material, we will take steps to notify you. The new modified or amended Privacy Notice will be effective as of such revision date. Always make sure you have reviewed the latest version of the Privacy Notice.

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