Privacy Policy

Employee Training and Awareness

• PHYTOLAB takes a holistic approach to ensure privacy-aware employees throughout the employment lifecycle including new-hire instructions, annual awareness briefings, targeted training for high-risk populations, and periodic awareness messaging through newsletters and PDPO bulletins.
• The ECO Mission: Promote throughout the global PHYTOLAB Technology community a culture of performance with integrity that encourages ethical conduct, reinforces the CLEAR Values, and drives compliance with the Code of Business Conduct, internal policies, and the law.

Strong Risk Management Programs

• In light of the inherent exposures to PHYTOLAB’s operational and strategic goals, PHYTOLAB is committed to ensuring that risk, issue, and opportunity management is a core competency, and an integral part of PHYTOLAB’s business operations that supports and informs reliable, quality decision making
• The resources in both the Ethics and Compliance Office and its Privacy and Data Protection Office are integral parts of PHYTOLAB’s overall risk assessment program and posture, which includes internal and external audit and monitoring functions.
• With regular privacy risk assessments, the PDPO monitors emerging exposures and remediates weaknesses in an effort to constantly mature PHYTOLAB’s compliance capabilities.

A consistent Privacy Impact Assessment program is carried out on new and changed services, systems, and processes, aiming to disclose potential issues before they become a problem. Formal data breach handling procedures and a robust 24/7 operated incident response center supplement regulatory and contractual notification requirements, enabling constant vigilance and readiness in case of a crisis.

Collection of Personal Information

Personal information is any information that personally identifies an individual or from which an individual could be identified. This may include a name, address, telephone number, email address and other private personal attributes.

PHYTOLAB collects, uses, stores and transfers (collectively “processes”) personal information to manage its relationship with its customers, employees, business partners and other third parties (“covered individuals”) and better serve covered individuals by personalizing their experience and interaction with PHYTOLAB. Such processing is done in compliance with applicable laws, including appropriate notice and consent, along with required filings with data protection authorities, where required.

PHYTOLAB may collect and process personal information through a variety of means, including, as examples, access to PHYTOLAB sites or services, or other ordering channels, employment processes, during conversations or correspondence with PHYTOLAB representatives, through purchase of goods or services or in the course of an online application.

Use of Personal Information

Fulfilling your Transaction Request

If we receive any requests related to, for example, a product or service, a callback, or specific marketing materials, we will use your personal information to fulfill your request. In this context, we may share information with others, for instance, PHYTOLAB’s group companies and business partners, involved in fulfillment. In connection with a transaction, we may also contact you as part of our customer satisfaction surveys or for market research purposes subject to applicable laws and regulations.

Recruitment

In connection with a job application or inquiry, whether advertised on a PHYTOLAB Web site or otherwise, you may provide us with information about yourself, such as a resume. We may use this information throughout PHYTOLAB and its group companies in order to address your inquiry or consider you for employment purposes.

Monitoring or Recording of Calls, Chats and Other Interactions

Certain online transactions may involve you calling us or us calling you. They may also involve online chats. Please be aware that it is PHYTOLAB’s general practice to monitor and in some cases record such interactions for staff training or quality assurance purposes or to retain evidence of a particular transaction or interaction.

Mobile Applications and Use of Information in the Social Computing Environment

PHYTOLAB makes available mobile applications for download from various mobile application marketplaces. PHYTOLAB also provides social computing tools on some of its websites to enable collaboration among members who have registered to use them. These include forums, wikis, blogs and other social media platforms.

When downloading and using these applications or registering to use these social computing tools, you may be asked to provide certain personal information. These applications and tools may also include supplemental privacy statements with specific information about collection and handling practices. We encourage you to read those supplemental statements to understand how the tools and applications may process your data.

Any other content you post, such as pictures, information, opinions, or any other type of personal information that you make available to other participants on these social platforms or applications, is not subject to this Privacy Statement. Rather, such content is subject to the terms of use of those applications or platforms, and any additional guidelines and privacy information provided in relation to their use, as well as the process by which you can remove your content from such tools. You should be aware that the content you post on any such social computing platforms may be made broadly available to others inside and outside PHYTOLAB

Choices and Privacy Preferences

Registration is not required to gain access to PHYTOLAB websites. However, if you choose to receive certain services, specific material and information your subscription is required on certain PHYTOLAB websites.

In this regard, PHYTOLAB may collect personal information from you including your name, phone number, email address, or other information you choose to provide at various times, for example, when you complete an online form or request or participate in an online community.

You can make or change your choices about receiving either subscription or general communications at the data collection point, within your account preference settings or by using other methods, which are listed in this Privacy Statement. You may opt-out at any time using the links at the bottom of any email.

Please note, this option does not apply to communications primarily for the purpose of administering business relationships, including contracts, support, or other administrative and transactional notices where the primary purpose of these communications is not promotional in nature.

International Data Transfers

PHYTOLAB recognizes and respects the varying national laws and obligations and their impact on cross-border data transfers. When transferring personal information outside of the country of collection for the purposes identified above, PHYTOLAB will do so in compliance with applicable law.

In the development of PHYTOLAB’s privacy policies and standards, we respect and take into account the major privacy and data protection principles and frameworks around the world and any amendments applied thereto from time-to-time, including the OECD Guidelines on the Protection of Privacy and Transborder Flows of Personal Data, the EU General Data Protection Regulation(GDPR), the UK Data Protection Act 2018, the APEC Privacy Framework, Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), and the Australian Privacy Principles under the Privacy Act 1988.

EU Personal Data Transfers

For personal data originating from a European Union (EU) member state, PHYTOLAB uses a variety of lawful data transfer mechanisms for this purpose, including EU Standard Contractual Clauses

PHYTOLAB has an intragroup agreement on the transfer and processing of personal data within the PHYTOLAB group worldwide which has the EU Standard Contractual Clauses incorporated. This agreement allows PHYTOLAB to ensure that personal data, including data originating from the EU, which is transferred cross-border and processed by other PHYTOLAB group companies, including those located outside the EU, is adequately protected in accordance with applicable data protection law.

PHYTOLAB’s Response

At PHYTOLAB, our commitment to privacy goes beyond the minimum legal and regulatory requirements. We strive for “best in class” data protection and privacy management, which requires a sound data privacy governance structure and an effective data privacy compliance and best practices program to ensure PHYTOLAB meets ever-changing and increasingly-complex regulatory standards and all contractually agreed privacy obligations

PHYTOLAB’s Global Privacy and Data Protection Office has strategic and operational responsibility for this program, which is appropriately organized to ensure the policies and compliance processes, technology and physical controls and security we rely upon to govern the collection, use, and transfer of personal data all over the world meets statutory and regulatory requirements. Therefore, PHYTOLAB’s approach is to coordinate the contribution of several corporate disciplines ─ including ethics and compliance, legal, human resources, and information security ─ to achieve our “best in class” data protection and privacy management objectives.

Highlights of this approach include:

• SO 27001 certified, tier IV classified data centers and delivery centers around the world to host and manage customer data;
• First class services including built-in privacy and data protection;
• A strong and robust global service delivery model that is flexible enough to meet privacy requirements even of highly sensitive, regulated and classified data environments;
• Comprehensive and cohesive compliance standards and procedures ensuring consistent privacy and data protection across all businesses and within all geographies and jurisdictions where PHYTOLAB does business;
• A strong and robust global service delivery model that is flexible enough to meet privacy requirements even of highly sensitive, regulated and classified data environments;
• A one-stop point of contact for our customers for any privacy related matters regardless of the geography, business or service including an independent external provider to resolve any privacy related disputes.

Disclosure of Personal Data

Detailed information about the type or identity of third parties to which PHYTOLAB discloses personal information, and the purposes for which it does so, can be found in the Sections “Use of Personal Information” and “Sharing of Personal Data” as outlined further above in this Enterprise Online Privacy Statement. Please note that PHYTOLAB may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Transfer of Personal Data from the United Kingdom to the U.S. post ‘Brexit’

The European Council and the United Kingdom (UK) have agreed to extend the period for withdrawal of the UK from the European Union (EU) beyond March 29, 2019. During the extension period, the UK will remain a Member State of the EU; as a Member State, EU law will remain applicable to and in the UK, therefore transfers of personal data from the UK to the U.S. made under the Privacy Shield will remain legal until the date the UK and the EU implement the withdrawal (“Applicable Withdrawal Date”).

After the Applicable Withdrawal Date, an organization that has publicly committed to comply with Privacy Shield with regard to personal data received from the UK and that has committed to cooperate and comply with the EU Data Protection Authority panel under the Framework will be understood to have committed to cooperate and comply with the UK Information Commissioner’s Office (ICO) with regard to personal data received from the UK in reliance on Privacy Shield.

In order for PHYTOLAB (US) to receive personal data from the UK post Applicable Withdrawal Date in reliance on the EU-U.S. Privacy Shield Framework, the following Privacy Shield commitments shall apply and be adopted by PHYTOLAB as of the Applicable Withdrawal Date.

In order for PHYTOLAB (US) to receive personal data from the UK post Applicable Withdrawal Date in reliance on the EU-U.S. Privacy Shield Framework, the following Privacy Shield commitments shall apply and be adopted by PHYTOLAB as of the Applicable Withdrawal Date.

California Consumer Privacy Act – CCPA

PHYTOLAB is committed to the lawful treatment and confidential handling of sensitive information, including personal information about California residents, and has adopted a set of global information management policies including privacy and data protection, security, system access, information classification, and other relevant policies governing the collection, use, disclosure, transfer, retention, and deletion of information.

PHYTOLAB as a “Service Provider” (as defined in the CCPA) confirms that it will process personal information which it retains, uses, or discloses in connection with its performance under any contract: (1) only on behalf of and for the benefit of the “Business” (as defined in the CCPA) from which it has received the personal information; (2) only in accordance with the contract and Business’s prior written instructions, if any; unless (3) as otherwise required by the CCPA. PHYTOLAB confirms that it will not process personal information for any purpose other than for the specific purpose of performing the services specified in the contract.

Information Security, Accuracy, and Retention

Security is a high priority for PHYTOLAB and to protect the personal data and other confidential information and maintain its accuracy and integrity we have implemented appropriate administrative, technical and physical safeguards to prevent unauthorized access, use or disclosure. We require the same high standard of information security and information management of any third parties we share your data with.We will retain personal information only for as long as legally required or permitted and in accordance with PHYTOLAB records and information management policies. We respect your right to privacy and upon your request PHYTOLAB will no longer use your personal information unless required to provide you services or as necessary to comply with PHYTOLAB’s legal obligations, resolve complaints and disputes, and enforce our agreements.

Access to Your Personal Information

PHYTOLAB has implemented technology, management processes and policies aimed to maintain data accuracy. According to applicable laws, PHYTOLAB provides individuals with reasonable access to personal information that they provided to PHYTOLAB and the reasonable ability to review and correct the data or ask for anonymization, blockage, or deletion, as applicable. To protect your privacy and security when submitting an access request, we will take reasonable steps to verify your identity, such as requiring a password and user ID, passport number and/or other unique personal identifiers before granting access to your data. To submit your access request, please contact the PHYTOLAB Global Privacy and Data Protection Office at admin@phytolabcosmetics.com.

Online Advertising

PHYTOLAB makes use of third party advertising systems to promote content on this website. These services will often make use of cookies and pixel tags to provide targeted advertisements based on your activities and interests. PHYTOLAB does not permit third parties to advertise on this site but we do use external sites to advertise our products and services. Please visit these third party sites for additional details regarding their privacy policies and practices.

External Links

PHYTOLAB sites or services may provide links to third-party applications, products, services, or websites for your convenience and information. PHYTOLAB does not control those third party sites or their privacy practices, which may differ from PHYTOLAB’s practices. We do not endorse or make any representations about third-party sites and privacy practices. The personal data you choose to provide to or that is collected by these third parties is not covered by this PHYTOLAB Privacy Statement. We encourage you to review the privacy policy of any site you interact with before allowing the collection and use of your personal information.

We may also provide social media features that enable you to share information with your social networks and to interact with PHYTOLAB and its group companies on various social media sites. Your use of these features may result in the collection or sharing of information about you, depending on the feature. We encourage you to review the privacy policies and settings on the social media sites with which you interact to make sure you understand the information that may be collected, used, and shared by those sites.