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cosmetic company-privacy policy

Privacy Policy

Your privacy is important to us

1. General

1.1 This Privacy Policy describes how Mirrabel Inc (the “Company”, “we”, or “us”) collects, uses, stores, shares and protects your personal information in connection with your use of both the platform accessible through the tejo.ca domain name (the “Site”) and the services we may offer through the Site and other services (indistinctly referred to as the “Services”).

California Residents: If you reside in the State of California in the United States, refer to the ‘CCPA Notice’ section for additional California-specific privacy disclosures that address the collection, use, disclosure and other processing of personal information that supplement this Privacy Policy and may fall outside its scope.

2. Scope of this policy

Respondents

2.1 If you are a respondent, please note that only process your data to help improve our recommendations. Your data is processed in an anomous way and shared with the person/company that sent you the Tejo Survey. We primarily forcus on providing services to the person or company that sent you the Tejo survey to fill out. You can e-mail customerservice@tejo.ca to remove your data with us.

2.2 We suggest you carefully read the terms and conditions and privacy policy of the company or person that sent you the Tejo survey, as those are the ones governing the processing of your personal data. If you have any doubts, please contact that person or company. Also, depending on how the person or company that sent you a Tejo survey configure that survey, your data may be shared or made public. To find out more, please contact the entity or person sending you the survey.

If you use our Services or Site

2.2. If you use our Services or Site, this Privacy Policy sets forth how we are processing your personal data, and how are we processing personal data on your behalf. You are not required to provide any personal information when using the Site, unless you choose to access features that require such information (as, by way of example, subscribing to any newsletter). The use of the Services, however, require that you agree to the conditions in more detail in the Service Terms and Conditions.

2.3. Personal information you provide us when using the Site and/or the Services is subject to this Privacy Policy, and you will be prompted to read and accept it.


How is your data being processed?

3.1. Who processes personal information? (who is the ‘Data controller’)

Personal information is processed by us, Mirrabel Inc.

3.2. What are we processing your data for and why are we processing it?

We process your data for purposes of providing you with both the Services, as well as to perform our obligations under the Services Terms and Conditions.

We may also process your data for the following purposes:

a) To send you electronic commercial communications (if you subscribe to a newsletter) or to answer the requests you may address us when contacting us;

b) To process information obtained through cookies, as described in more detail in the Cookie Policy, and subject to the terms set forth therein;

c) If you opt to sign in by means of a third party social media platform, we may obtain ID confirmation and other information from that third party, as mentioned in each case;

d) For profiling purposes based on your behavior, image analysis and how you or your customers browse the Site and use the Services, which pages you have visited, and to build audiences. Please note that we may profile users by means of cookies. In those cases, your acceptance of the installation and use of cookies results in a data processing for profiling purposes.

e) We may enrich the data we have about you by obtaining information from a select third party for data enrichment purposes, provided that you have given us prior permission. Enriching data allows us to analyze a deeper subset of data from which we may present personalized content.

f) We may use your user’s data to optimize their recomondations and experince.

Finally, we may also process your data to protect our legitimate interests, as long as said data is strictly necessary to fulfil the goals set forth below, namely:

a) To review, monitor, investigate, and analyze how to improve the Services and/or the Site, as well as to keep our Services and the Site secure and operational and prevent abusive activity (e.g. fraud, spam, phishing activities, etc.).

b) Besides any commercial communication sent when we have obtained your consent as mentioned above, we may also send you those kind of communications when you are our client.

c) Upon dissociating the data we have so as to be impossible to be associated to you or any other person, to perform statistical and other analysis on information we collect (technical and metadata) to analyze and measure user behavior and trends, to understand how people use our services, in order to improve and optimize our performance of such services.

3.3. To which extent do we require to have access to your personal data?

We need to process your personal data to perform the legal and contractual obligations mentioned in section 3.2 above. Otherwise, we are not able to provide you with the Services and/or access to the Site. On the other hand, for data processing which depends on your consent or on our legitimate interests, the data processing is not legally required.

3.4. Which companies will have access to your personal information?

We share your information with our service providers who help us to provide the Services to you, in which case those third parties are required to comply with our internal standards, policies, and technical and organizational measures that ensure that your data is protected and kept confidential at all times, and only in accordance with and to the extent authorized by this Privacy Policy.

When you authorize us to do so, we may also share your data with other companies so that they can process the data for other purposes, as explained more in detail when we request your prior consent. In addition, if you provide consent for the installation of cookies, your data may be processed by third companies for the purposes and in the territories mentioned in the Cookie Policy.

We may also share your information with competent courts and authorities, when we are legally required to do so (for instance, to allow such bodies to investigate, prevent, or take action against illegal activities), or we have to take action to protect our rights or any third party rights.

3.5. In which territories may your personal information be processed?

Your information (not third parties’ information collected through surveys, which is subject to section 4.10 below) may be transferred, processed, and stored in countries that do not have data protection laws as protective as those in your jurisdiction. Your agreement to the terms of this Privacy Policy, followed by your submission of information in connection with the Service, represents your agreement to this international transfer of personal data.

3.6. Your rights

You have the right to withdraw your consent at any time. You also have the right to request access to, and rectification of, or erasure of your personal data, or restriction of processing, or to object to processing, as well as the right to data portability. Please note that if you choose to cancel your data, your account will be deleted and all data in your account will be permanently deleted from our systems.

3.7. Updating your information. Emails and commercial communications.

You can update any information we may have from you by means of the account settings area. Please remember that it is your duty to keep information updated so we can correctly provide you with the Services, and you undertake to verify the information you have handed us from time to time to make sure that it is accurate.

As explained in section 3.6 above, you are entitled to ask us, now or at any moment, not to send you any kind of emails or commercial communications. To that extent, you can either change the communication preferences in your account settings page or contact us as described in section 3.6 above. Note that this will not prevent the sending of emails or other communications related to the Services, as those communications are necessary to perform the relationship we have with you.

4. How is the data we collect on your behalf being processed?

4.1. In order to provide you with the Services, we may need to process on your behalf third parties’ personal data. This is the case, for instance, when a person files out a survey(the survey we made available to you in the Services), in which case the data is collected, stored, and processed on your behalf.

4.2. We will only process any personal data we may have access to as a result of the provision of the Services in accordance with the instructions included in the Service Terms and Conditions. Please, note that you shall bear any consequences arising out of behaviour contrary to law, and you shall defend, indemnify, and hold us harmless of any and all costs (including attorney’s fees), fines, or sanctions, or any damages deriving from our performance of the challenged instruction.

4.3. We will ensure that all employees authorized to process personal data have committed to confidentiality or are under an appropriate statutory obligation of confidentiality.

4.4. To provide you with the Services, we may need to use some service providers we already rely on, as well as hire new ones in the future. Those companies will only process the data to the extent necessary to render the Services, and we will enter into written agreements with them to make sure that said companies comply with the obligations included in this section 4 and implement all necessary security measures to ensure adequate protection of the data.

In the event that we want to change any of those service providers by another, or that we need to hire new companies, you will have the right to reasonably oppose to such changes or new appointments in the non-extendable term of 15 calendar days. ‘Reasonably oppose’ shall be interpreted as any challenge based on the failure to meet the legal requirements set forth by the European data protection laws by the new entity to be hired. In any event, we reserve the right to terminate the relationship with you should we cannot hire a subprocessor which is essential or needed for providing the service.

The Company shall enter into written agreements with any subprocessors engaged in the provision of the Services including the safeguards and guarantees required by the General Data Protection Regulation (EU Regulation no. 679\2016, the “GDPR”), particularly in respect of implementing the security measures required in the GDPR. For those subprocessors located in a country not considered by European authorities as having the same level of protection than European data protection laws, you agree to comply with the requirements set forth in 4.10 below.

4.5. At your request and expense, we shall assist you by appropriate technical and organizational measures, insofar as this is possible, for the fulfilment of your obligation to respond to requests for exercising the data subject's rights laid down in Chapter III of the GDPR, if applicable. For avoidance of doubt, we shall convey you any request data subjects may address directly to us together with all relevant information, if any, so that you can contact and answer to data subjects, but we shall not take care of responding data subjects.

4.6. We shall reasonably assist you in compliance with the security obligations set forth by Article 32 of the GDPR.

4.7. We will also provide, at your request and expense and subject to the nature of processing and information available to us, assistance in complying with obligations set forth in Articles 33 to 36 of the GDPR, if applicable.

With respect to data breaches, we will notify you without undue delay upon we confirm that a data breach affecting personal data has taken place. We will provide you with sufficient information to allow you to meet any obligations to report or inform competent authorities or data subjects. We will reasonably cooperate with you and take such reasonable commercial steps as are directed by you to assist in the investigation, mitigation, and remediation of each such data breach. For avoidance of doubt, you shall be responsible for both filing any reports required under applicable law and notifying data subjects, and you shall defend, indemnify and hold us harmless of any and all costs (including attorney’s fees), fines, or sanctions, or any damages that lack of action on your side may cause.

4.8. Upon termination of the Service Terms and Conditions, we shall delete personal data, unless otherwise required by law.

4.9. We will make available to you all information necessary to demonstrate compliance with the obligations laid down in this Section 4 and allow for and contribute to audits, including inspections, conducted by you or another auditor mandated by you who is not any of our competitors. You accept that you may only conduct up to one (1) audit per year, except if there are reasonable grounds to believe that we are not performing the obligations included in this section 4. Audits shall only be carried out during normal business hours, and you shall bear all costs except that we are found to be in a material breach of this section 4.

4.10. For the provision of the Services or because you want to process data from a given location or hand it to another company, data may be transferred outside the European Economic Area to a country which has not been declared to offer a level of protection equal to the one provided by European data protection regulations.

In those cases, you shall ensure that said transfer is possible in accordance with European data protection regulations or any other requirements set forth by law without having to sign Standard Contractual Clauses. Should this not be possible—and only to this extent—and with respect to any subprocessors hired by us, you (as ‘data exporter’) and we (as ‘data importer’) hereby agree to enter into the Standard Contractual Clauses in respect of any such transfers of data. You fully agree with the contents of the Standard Contractual Clauses and—given that the contractual relationship set forth in the Service Terms and Conditions cannot exist without international transfers of data—you further warrant and represent that you will not question the execution of Standard Contractual Clauses in the future, being their signature a mere act evidencing their agreement to the same as set forth herein.

6. Changes to the privacy policy

6.1. We may amend this Privacy Policy from time to time. You may be required to accept the amended Privacy Policy upon logging in to your Account in order to keep using the Service. Alternatively, we may post any non-material changes to this Privacy Policy on the Site with a notice advising of the changes in advance of the effective date of the changes. We may also notify you of material changes to this Privacy Policy, before the effective date of the changes, by sending an email or otherwise. If you do not agree to any non-substantial change to this Privacy Policy, you may terminate the Service Terms and Conditions.