Introduction

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Cosmetigroup International Corp. (“Cosmetigroup”) is committed to maintaining the privacy and security of your personal data. This Privacy Policy explains how we collect, use, share and protect your personal data.

 

It is important that you read this Privacy Policy so that you are aware of how and why we are using your personal data.

 

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below:

 

1. Who we are

2. What is Personal Data?

3. Data Protection Principles

4. The Personal Data We Collect from You

5. How We Use Your Personal Data

6. When and How We Share Your Personal Data with Others

7. Transfer of Your Personal Data to Other Countries

8. The Security of Your Personal Data

9. Our Storage and Retention of Your Personal Data

10. Your Rights as a Data Subject

11. Change to this Privacy Policy

12. Data Protection Officer

 

1.Who We Are

 

Cosmetigroup is a “Data Controller”.

 

This means that we are responsible for deciding how we hold and use personal information about you. Where we act as a data controller, we are required under Republic Act No. 10173 (otherwise known as the “Data Privacy Act of 2012”) to notify anyone who provides personal data to us, either directly or through a third party.

 

Cosmetigroup is the trade name of Cosmetigroup International Corporation, a corporation organized and existing under and by virtue of Philippine laws with principal office address at 2/F Libran House Bldg. 144, Legaspi St., San Lorenzo, Makati City, Philippines.

 

Within this Privacy Policy when we mention Cosmetigroup (which can also be referred to as “we”, “us” or “our” in this Privacy Policy), we are referring to Cosmetigroup International Corporation.

 

2.What is Personal Data

 

Personal Data is any information about an individual from which that individual can be identified. Your name, address, phone number and bank account number are examples of Personal Data. It does not include data where the identity has been removed (anonymous data).

 

3.Data Protection Principles

 

We will comply with all data protection principles as laid down in the Data Privacy Act of 2012. In accordance therewith, the personal information we hold about you shall be:

 

1. used lawfully, fairly and in a transparent way;

 

1. collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;

2. relevant to the purposes we have relayed to you and limited only to those purposes.

3. accurate and kept up to date;

4. kept only as long as necessary for the purposes we have told you about; and

5. kept securely.

 

4.The Personal Data We Collect from You Inquiries

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When you request information or make inquiries about any of our services, we may use the Personal Data you provide in order to fulfil your request or respond to your inquiry.

 

We may email you or contact you regarding our services by telephone utilizing automated technology at the telephone number(s) you provided or via our live chat platform. It is in our legitimate interests to use your Personal Data in this way so that you receive the information you have requested.

 

You may give us information about you by completing a form, or by corresponding with us by phone, email, live chat or otherwise. This includes information you provide when you register to use our site, participate in social media functions on our site, enter a competition, promotion, or survey, and when you report a problem with our site.

 

Registration

 

When you register for any of the services we provide, we may collect the following categories of personal data about you:

 

1. Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses

2. Date of birth

3. Gender

4. Nationality and country of residence

5. Government-issued Identification Card (e.g. your passport, driver’s license, or TIN)

6. Bank account details

7. Billing address

8. Credit card or other payment information in order to process your payments

9. Name of nearest kin or authorized representative/s

 

It is in our legitimate interests to collect and use the above information in order to consider and process your registration and perform the contract we have entered with you.

 

Marketing

 

Where you have explicitly consented to do so through a consent form, we may use your personal data to inform you of special offers and new or existing services we offer that are similar to those that you have already purchased or inquired about. This may also include surveys or questionnaires so that we can learn more about your needs and interests.

 

From time to time, we may use your personal data to offer you the opportunity to participate in other promotions. When you enter you should carefully review any rules, as they may contain additional information about our use of your personal data.

 

If you would prefer that we do not send such communications to you, please follow the opt- out links on any marketing message or contact us using the contact details in this Privacy Policy. If you prefer that all your details provided are removed from our database, please contact us using the contact details in this Privacy Policy.

 

Automated Technologies or Interactions

 

As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.

 

Our Website

 

With regard to each of your visits to our website, we may automatically collect the following information:

 

1. technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

 

1. information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time);

 

1. pages you viewed or searched for; and

 

1. page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

 

We will use this information:

 

1. to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

 

1. to improve our site to ensure that content is presented in the most effective manner for you and for your computer;

 

1. to allow you and assist you in participating in interactive features of our services and track your progress in the use of our website;

 

1. as part of our efforts to keep our site safe and secure;

 

1. to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and

 

1. to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

 

Internal Business Purposes

 

We also may use your personal data for our internal business purposes. This is in our legitimate interests in order to operate as a business and monitor and improve the services we provide. Where possible we will anonymize this information. Please contact us using the

 

contact details in this Privacy Policy if you would like more information. Attached to this Policy is our Data Privacy Consent Form.

 

If You Fail To Provide Personal Data

 

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

Parents and Guardians

 

We collect personal data as described above. However, if you are under eighteen (18) years of age and want to request information, register, or procure any of our services, you must ask your parent or guardian for permission.

 

5.How We Use Your Personal Data

 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

 

1. where we need to perform a contract we have entered into with you;

 

1. where we need to comply with a legal obligation; or

 

1. where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

 

We may also use your personal data in the following situations, which are likely to be less common:

 

1. where we need to protect your vital interests (or someone else’s interests)

 

1. Where it is needed in the public interest or for official purposes

 

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.

 

6.When and How We Share Your Personal Data with Others

 

We may share your personal data with third parties where required by law, where it is necessary to perform our contract with you, or where we have a legitimate interest in doing so. Such third parties may include the following:

 

1. Our Service Providers. We may share your personal data with other companies that perform certain services on our behalf. These services may include processing payments, providing customer service and marketing assistance, performing business and sales analysis, advertising, analytics, search information services, credit reference services and supporting our website and IT functionality. These service providers may be supplied with or have access to your personal data solely for the purpose of providing these services to us or on our behalf. Cosmetigroup is the data controller and will remain accountable for your personal data.

 

1. Our Business Partners. We may share your personal data with our business partners with whom we have a contract relating to the services we provide to you.

 

1. Agent. If you use an agent or authorized representative to arrange the fulfillment of the services that you have availed with you, we may share your personal data with them.

 

1. Other Entities in Cosmetigroup. We may share your personal data with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganization or group restructuring exercise or for system maintenance support and hosting of data.

 

1. Regulators. We may need to share your personal data if required by the National

Privacy Commission (“NPC”) or to otherwise comply with law.

 

1. Others. We may share your personal information with other third parties in order to permit us to pursue available remedies or limit damages we may sustain.

 

7.Transfer of Your Personal Data to Other Countries

 

Considering the scale of our business and the location of our shareholders, other business partners, clients, and other service providers, we may need to transfer the personal data you provide to us to other countries.

 

The data protection laws in such countries may not be as comprehensive and provide the same level of protection for your personal data as those provided for under the Data Privacy Act of 2012. In these circumstances, we will take appropriate steps to ensure that your personal data is handled as described in this Privacy Policy. These steps include putting in place appropriate contractual mechanisms. Please contact us using the contact details in this Privacy Notice if you would like more information.

 

8.The Security of Your Personal Data

 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, service providers, business partners, agents and other third parties who have a legitimate need to know. They will only process your personal information on our instructions or as otherwise agreed and they are subject to a duty of confidentiality.

 

We have put in place procedures to deal with any suspected data security breach and will notify you and the NPC of a suspected breach where we are legally required to do so.

 

9.Our Storage and Retention of Your Personal Data

 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. All information gathered shall not be retained for a period longer than one (1) year. After one (1) year, all hard and soft copies of personal information shall be disposed and destroyed, through secured means. Please contact us using the contact details in this Privacy Policy if you would like more information.

 

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

 

In some circumstances we may anonymize your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

 

10.Your Rights as a Data Subject

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Under certain circumstances and pursuant to the Data Privacy Act of 2012, you have the right to:

 

1. Request access to your personal data (commonly known as a “Data Subject Access Request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

 

1. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

 

1. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).

 

1. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

 

1. Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example, if you want us to establish its accuracy or the reason for processing it.

 

1. Request the transfer of your personal data to another party.

 

If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us in writing using the contact details in this Privacy Policy.

 

No Fee Usually Require

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

 

What We May Need From You

 

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

 

Your Right To Withdraw Consent

 

In circumstances where you may have provided your consent to the collection, processing, and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us using the contact details in this Privacy Policy. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

 

11.Change to this Privacy Policy

 

We reserve the right to update this Privacy Policy at any time, and we will provide you with a new Privacy Policy when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

 

12.Data Protection Officer

 

Cosmetigroup has appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the following details:

 

DPO Contact Details

 

Email address: dpo@cosmetigroup.com.ph

Address: 2/F Libran House Bldg. 144, Legaspi St., San Lorenzo, Makati City 1223

 

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