At Sinelco, we attach great importance to the protection of your personal data. In this privacy policy you will find all relevant information applicable to our use of the personal data of our customers, suppliers and visitors of our websites, regardless of the channel (online or in person) or means that you use to interact with us.
If you provide us with personal data of other persons, such as your collaborators, we kindly request that you inform these persons of our privacy policy before entrusting us with their personal data. Likewise, we will use all opportunity to inform and reassure you and these persons that personal data are safe with us.
We are transparent about which personal data we may process and for what purposes. We inform you on the rights you are entitled to in relation to your data. You will also find further information on each processing operation of your data as you interact with us through our websites or otherwise (e.g., via e-mail).
We permanently make available to you all the information included in this privacy policy. We reserve the right, however, to amend our privacy policy from time to time, if legislation or our internal practices so require. At all times you can find the current version of our privacy policy on our website.
If you would like information about how we use cookies on a specific website, we recommend you to consult the Cookie Policy published on that website.
OVERVIEW
1. THE CONTROLLER OF THE PROCESSING OF YOUR DATA
- THE PERSONAL DATA WE MAY PROCESS
- PURPOSES AND LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA
- DURATION OF THE PROCESSING AND RETENTION OF DATA
- CATEGORIES OF RECIPIENTS AND TRANSFER OF PERSONAL DATA
- YOUR RIGHTS IN RELATION TO THE PROCESSING OF YOUR PERSONAL DATA
- CHANGES TO THE PRIVACY POLICY
- CONTACT SINELCO IN RELATION TO DATA PROCESSING
- THE CONTROLLER OF THE PROCESSING OF YOUR DATA
The legal entity controlling the processing of your personal data is Sinelco International bv.
Sinelco International bv is a Belgian company with limited liability. The company is registered with the Register for Legal Entities in Belgium under number 0400.208.340:
Sinelco International bv
Klein Frankrijkstraat 37
B-9600 Ronse
VAT-nr. BE0400.208.340
RPR/RPM Gent
Sinelco International bv has determined the purposes and means of the processing. Sinelco is therefore the controller of the processing of your personal data. The processing, however, may be performed for the benefit of Sinelco International bv or any of the following affiliated companies: Sinelco Italiana s.r.l. and Sinelco Group bv.
With regard to the processing operations performed for legal reasons (e.g., after-sales warranty), compliance (e.g., post-marketing surveillance of cosmetic products) or tax and accounting reasons, Sinelco International bv and its affiliated companies are to be considered joint-controllers. In this case, we have regulated and are jointly responsible for the processing and protecting of your personal data.
Sinelco International bv and its affiliated companies are hereafter referred to as “Sinelco”, “we”, “us” and “our”.
2. THE PERSONAL DATA WE MAY PROCESS
Depending on the purpose for which we process your data from time to time (see below), Sinelco may process the following personal data:
For customers
(1) Identity data (e.g., name(1)(2); address(1)(2); e-mail address(1)(2); telephone and/or mobile number(1)(2); date of birth when applicable (2); function or title when applicable(1)(2); language and country from which you interact with us(1)(2));
(2) economic and transaction data (e.g., VAT number when applicable(1); payment or card data(1); customer account number (1)(2); information on purchases, orders, returns (1)(2); ticket information (1)(2));
(3) commercial data (e.g., whishes in relation to direct marketing (2); customer participation in trainings or promotions (2));
(4) connection, geolocation and/or browsing data (e.g., location data (1); advertising ID (2); information on tastes and preferences (2));
(5) (customer) experience data (e.g., complaints and details of complaints (1), recordings of telephone calls to customers services (1), queries submitted through our contact pages (1), responses to requests (1));
The personal data “(1)” have to be provided if you want to register as a customer and are processed for the purpose of sales and legally required purposes linked to that purpose. The personal data “(2)” can be processed for direct marketing purposes, depending on the type of direct marketing the customer wants to receive. Some of these data can also be used for analytic and statistic purposes.
Sinelco may reserve specific promotions to segmented customers, e.g., based on history of purchases, kind of customer, date of birth or customer wishes.
For suppliers
(1) Identity data (e.g., name; address; telephone and/or mobile number; e-mail address; type of supplier; function or title; language and country from which you interact with us);
(2) economic and transaction data (e.g., VAT number when applicable, payment or card data, contract related information;)
The provision of all aforementioned personal data is mandatory for suppliers. The data are processed for the purpose of purchasing and legally required purposes linked to that purpose.
For visitors to the websites
(1) Identity data (e.g., name, e-mail address, language and country from which you interact with us);
(2) connection, geolocation and/or browsing data (e.g., location data, advertising ID);
(3) (customer) experience data (e.g., queries submitted through our contact pages, responses to requests)
The provision of these data is entirely on a voluntary basis. However, if you decide to submit a request, you have to fill in a name and electronic contact details. The data are only processed to properly deal with your request and for analytic and statistic purposes.
Additionally, we point out that when you visit or use our social media channels, we may also receive data from these social media providers or their partners about your profile such as: your name, gender, approximate age, profile image and/or online activities. We receive this data in accordance with the terms of use of the social media provider, which we recommend you read carefully.
3. PURPOSES AND LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA
Sinelco processes personal data of its customers and suppliers, as well as of collaborators of its customers and suppliers, and of its visitors to its websites, for the following purposes:
| The purpose of sales | Processing of personal data of customers, contact persons of customers and potential customers for the purpose of conveying offers, invoicing, after sales, management of the customer or sales relationship (including in the context of e-commerce) as well as legally required purposes that are linked to that purpose. |
| The purpose of direct marketing | Processing of personal data of customers, contact persons of customers and potential customers for direct marketing. |
| The purpose of purchasing | Processing of personal data of suppliers, contact persons of suppliers and potential suppliers for the purpose of purchasing, after sales, management of the supplier relationship as well as legally required purposes that are linked to that purpose. |
| Analytic and statistic purposes | Processing of personal data of (potential) customers, contact persons of customers and visitors to the websites for analytic and statistic purpose, i.e. to analyze the usability of our websites and improve the quality of our goods and services. |
| The purpose of responding to requests by visitors of our websites | Processing of personal data of visitors of our websites that fill out the contact page, for the sole purpose of responding to the visitor’s queries sent to us via the contact page. |
| Legally required purposes | Processing of personal data if required for legal reasons (such as after sales warranty), compliance (such as post-marketing surveillance of cosmetic products) or tax and accounting reasons. |
| The purpose of the establishment, exercise or defense of legal claims | Processing of personal data in the event of conflicts or potential conflicts (e.g. communication with law firms, insurance company and insurance broker) |
The legal basis for these processing operations is respectively:
| For the purpose of sales | To the extent that you are a natural person customer of whom the personal data are processed for the performance of the contract, our legal basis for the processing of your data is the necessity for the purpose to conclude and/or perform our purchase or services contract with you. To the extent that you are a collaborator of our customer or potential customer and your contact details have been provided by the customer or the potential customer for the performance of the contract with the customer or for communicating with or giving follow up to an offer to the customer, our legal basis for the processing of your data is the necessity for the purpose of the legitimate interests pursued by Sinelco and the customer to organize, and interact in relation to, the conclusion or performance of our purchase or services contract. In our view, given the limited use made of your contact details, such interests are not overridden by your interests or fundamental rights and freedoms. Should you consider otherwise, please revert to Title 6 below on your legal rights in relation to privacy. |
| For the purpose of direct marketing | For the processing of personal data for direct marketing our legal basis is either: To promote sales, reinforce the relationship with the customers, enhance customer loyalty, etc., Sinelco relies upon its legitimate interests. For processing activities which are in general considered little intrusive (e.g. promotion sent by regular mail), such interests are in our view not overridden by your interests or fundamental rights and freedoms. Should you consider otherwise, please revert to title VI below on Your legal rights in relation to privacy. We may also invoke the same legal basis of our legitimate interest, for newsletters sent by e-mail to our own customers if your e-mail contact details were received directly from you in the context of sales and are only used for the promotion of Sinelco’s own similar products. Every newsletter however carries a link allowing you to unsubscribe from the newsletter. For marketing initiatives such as calling you or sending you text messages, we will always first ask your consent. The same is true for e-mail newsletters that do not comply with the aforementioned conditions. Your consent will be asked at the moment that we receive your personal data. You will be asked, for example via a tick box, whether you would like to receive e-mail newsletters, promotional text messages, calls to inform you on promotions for products or other marketing messages. You may revoke your consent at any moment in accordance with Title 6 below. |
| For the purpose of purchasing | To the extent that you are a natural person supplier of whom the personal data are processed, our legal basis for the processing of your data is the necessity for the purpose to conclude and/or perform our purchase or services contract with you. To the extent that you are a collaborator of the supplier and your contact details have been supplied by the supplier or the potential supplier for the purpose of the performance of the contract or for communicating with or giving follow up to an offer of or sale from the supplier, our legal basis for the processing of your data is the necessity for the purpose of the legitimate interests pursued by Sinelco and the customer to organize, and interact in relation to, the conclusion or performance of our purchase or services contract. In our view, given the limited use made of your contact details, such interests are not overridden by your interests or fundamental rights and freedoms. Should you consider otherwise, please revert to title 6 below on your legal rights in relation to privacy. |
| For analytic and statistic purposes | For the processing of personal data of (potential) customers, contact persons of customers and visitors to the websites for the purpose of analyzing the usability of our websites and improving the customer and visitor’s satisfaction degree in relation to our goods and services, our legal basis is the necessity for the purpose of the legitimate interests pursued by Sinelco to improve the experience of customers and visitors to our websites and provide a higher quality service. |
| For the purpose of responding to queries by visitors of our websites | For the processing of personal data of visitors of our websites that fill out the contact page, for the sole purpose of responding to the visitor’s queries, our legal basis is the necessity for the purpose of the legitimate interests pursued by Sinelco to treat and give follow up to your query. Given your initiative to send your query via our contact page (which we assume you want us to reply to) and the limited use made by us of your contact details to reply, such interests are in our view, not overridden by your interests or fundamental rights and freedoms. Should you consider otherwise, please revert to title 6 below on your legal rights in relation to privacy. |
| For legally required purposes | The legal basis of this processing is to be found in European or national law. |
| A specific case of a processing for legally required purposes, is the processing of personal data (including health related data) for compliance with legislation on post-marketing surveillance of cosmetic products. | Following a customer complaint, we may specifically process the customer’s health information. This data will only be processed to handle this complaint and comply with our regulatory obligations pursuant to EU Regulation (EC) N° 1223/2009 on cosmetic products, and not for any other purpose. We take appropriate safeguards, e.g. by limiting the persons having access to these data and using pseudonymization where possible. Pursuant to the aforementioned legislation we may be required to share the complaint with the person responsible for the cosmetic product in question (such as the manufacturer) and/or the national competent authority. In order to handle your complaint we may also communicate the personal data to our insurance company and insurance broker: Your consent is not required for our reporting (including your name and contact details) to the person responsible for the cosmetic product in question and to our insurance company and insurance broker. To include your name and contact details in reporting to the national competent authorities, we will ask your consent. If you do not consent, we will indicate in our report that the name and contact details of the consumer are withheld at the request of the customer. |
| For the purpose of the establishment, exercise or defense of legal claims | The legal basis of this processing is to be found in the legitimate interest of Sinelco to Internally organize in the event of conflicts or potential conflicts; Seek legal advice and representation; Communicate with insurance company and insurance broker, and Organize for litigation or settlement of disputes. |
4. DURATION OF THE PROCESSING AND RETENTION OF DATA
For customers
We process your personal data for the purpose of sales, as long as your customer status is active. This means that you regularly purchase our products, visit our e-shops and/or participate in promotions. Personal data of inactive customers are retained for as long as necessary for legal, compliance or tax and accounting reasons or for as long as your purchases could give rise to legal claims.
We process your personal data for direct marketing purposes until you oppose to the processing of your personal data for that purpose, or if the processing was based on your consent, until you withdraw your consent.
For suppliers
We process your personal data as long as necessary in the context of the contracts entered into with you. After termination of our active collaboration with you, your personal data are retained for as long as necessary for legal, compliance or tax and accounting reasons.
For visitors of our websites that fill our contact page
We process your personal data as long as necessary to deal with and give follow up to your request. The data are not retained afterwards (unless the case being, in the context of another processing for another purpose as detailed in this privacy policy).
5. CATEGORIES OF RECIPIENTS AND TRANSFER OF PERSONAL DATA
Sinelco forms part of a larger group of companies affiliated to Sally Beauty Holdings Inc. To achieve the purposes mentioned in this privacy policy, we may share personal data within Sally Group:
- As indicated under title 1, Sinelco International bv is the controller of the processing of personal data for itself and a number of affiliated companies based in continental Europe. To the extent that these affiliates participate in some of the processing operations, they do so under Sinelco International bv’s control (unless the affiliates qualify as joint controllers for legally required processing).
- Sinelco may communicate some personal data to other European Sally Beauty companies as the organizations in continental Europe and the UK collaborate closely on a management level. This communication is limited to what is necessary for the purposes.
To the extent that this communication of personal data entails a transfer to the UK, Sinelco relies on the European Commission’s adequacy decision of 28 June 2021.
Apart from the communication of personal data within Sally Group, we may work with the following categories of third party processors: suppliers of IT services and platforms, suppliers of hosting services; consultants and providers of (direct) marketing services; suppliers for logistic services; partners for product maintenance, external law firms, insurance companies and insurance brokers.
Sinelco will make sure that all of its processors have entered into appropriate processor contracts.
6. YOUR RIGHTS IN RELATION TO THE PROCESSING OF YOUR PERSONAL DATA
In relation to the personal data that are processed by Sinelco, you have a number of legal rights:
- You have a right to get access to your personal data and to have these data corrected.
- You may ask Sinelco to erase your personal data, or to restrict the processing thereof.
- To the extent that the processing is based on the legal basis of a legitimate interest, or the processing is done for direct marketing purposes, you have the right to oppose to that processing.
- To the extent that the processing is based on your consent, you have the right to revoke your consent at any time.
- You may ask to receive the personal data which you have provided to us, in a structured, commonly used and machine-readable format and transmit these to another controller.
Within a duration of maximum 1 month after receipt of your request, we will act upon your request and reply. If for some reason we cannot accommodate your request, we will inform you of the reasons thereof. If we are not in a position to identify you properly, we may ask you to provide a proof of your identity as a prerequisite to accommodating your request.
If your sole aim is to unsubscribe from a newsletter or live calls, you can also click the unsubscribe link in the newsletter or ask the live caller not to call you again. Alternatively, if you are a customer and your sole aim is to give or revoke your consent in relation to direct marketing or modify your direct marketing preferences, you can surf to the e-shop and adjust your privacy settings via your e-shop account.
Additionally, should you not wish us to send information to third parties to show you ads, you can do it through several means such as changing your preferences on your device, browser and/or cookies settings or reviewing the privacy policies and settings of the social media sites on which you have profiles.
If on the other hand you have any questions, remarks or complaints in relation to our privacy policy or how we process your data, do not hesitate to contact us, either by telephone or e-mail. You can find our contact details under title 8.
If you have any complaints in relation to how Sinelco processes your personal data, you may file a complaint with our supervisory authority: www.gegevensbeschermingsautoriteit.be or the authority of the country in which you have your habitual residence: https://edpb.europa.eu/about-edpb/about-edpb/members_en.
7. CHANGES TO THE PRIVACY POLICY
We may amend the information contained in this Privacy Policy when we consider this appropriate or if legislation so requires. Should we do so, we will notify you via our website (for example, through a banner or a pop-up), or via your e-mail address when the change in question is relevant to your privacy. That way you can review the changes, assess them and, as the case may be, object or unsubscribe from a service or functionality.
In any case, we recommend you review this privacy policy from time to time in case minor changes are made or we make any interactive improvement. You will always find this privacy policy on our websites.
8. CONTACT SINELCO IN RELATION TO DATA PROCESSING
If you have any questions or comments regarding our privacy policy or your rights under title 6, please contact us:
- Via our dedicated privacy e-mail address: privacy@sinelco.com;
- Or send us a letter at:
Sinelco International bv
Privacy
Klein Frankrijkstraat 37
B-9600 Ronse
BTW-nr. BE0400.208.340
RPR/RPM Gent
Last update: 15 March 2023
