Data Protection Policy

In accordance with the provisions of law n ° 78-17 of January 6, 1978 amended by law n ° 2018-493 of June 20, 2018, we inform you that the processing of personal data collected from the Website accessible at the address www.ingredientsecret.com (hereinafter the ”Website”) are implemented under the conditions of this Data protection policy (hereinafter the ”Data protection policy”).

BRAIN FOR BEAUTY informs you that within the meaning of the regulations:

• “personal data” is any information that identifies, directly or indirectly, an individual.
• “processing of personal data” is any operation or set of operations applied to personal data.

ARTICLE 1 – INFORMATION ON THE PROCESSING THE PERSONAL DATA

BRAIN FOR BEAUTY collects personal data directly from Users and / or Customers, generally through contact forms or subscription to the Website’s newsletter.

When personal data is collected directly from Users and / or Customers, the mandatory information is marked with an asterisk. These are essential for the performance of the contract with BRAIN FOR BEAUTY or for compliance with a legal obligation. Failure to communicate may prevent the registration and / or processing of a contact request, or the sending of the newsletter, if applicable. The processing of personal data carried out by BRAIN FOR BEAUTY is carried out for the following purposes and on the following legal bases:

Purpose	Legal basis
Customer relationship management	Contract with BRAIN FOR BEAUTY
Order processing	Contract with BRAIN FOR BEAUTY
Sending the commercial communications through your subscription to the newsletter	User consent
Organization of contests or promotional offers	Contract with BRAIN FOR BEAUTY
Processing the requests made to BRAIN FOR BEAUTY customer service	User consent
Management of product reviews	User consent
Analysis of the ergonomics of the Website by means of cookies or similar technologies making it possible to collect information on Users’ online browsing, for example the type of browser, the country code corresponding to their location, the pages of the Website consulted, the advertisements on which the User has clicked or even any Products sought on the Website. These data are statistical and anonymized, they do not identify a User.	BRAIN FOR BEAUTY’s legitimate interest in cookies intended to improve and guarantee the proper functioning and security of the Website and the User’s consent for all other cookies (advertising and targeted communications, production of statistics).

ARTICLE 2 – RECIPIENTS OF PERSONAL DATA

The personal data of Users are treated by BRAIN FOR BEAUTY confidentially and with the greatest care. BRAIN FOR BEAUTY shares them only with:

• service providers engaged to process data on behalf of BRAIN FOR BEAUTY, for example for the management of the platform of our Website, the implementation of commercial campaigns, etc. These service providers are only authorized to use personal data as part of the services they perform on behalf of BRAIN FOR BEAUTY and only for the achievement of the purposes provided for herein;
• public bodies or authorities making the request to comply with a legal obligation or protect rights;
• possibly future buyers of BRAIN FOR BEAUTY in the event of a business sale or assets.

ARTICLE 3 – LOCATION AND STORAGE PERIOD OF PERSONAL DATA

BRAIN FOR BEAUTY keeps all the personal data of Users and / or Customers in the territory of the European Union. Some of this data may be transferred and stored outside the European Union by service providers engaged by BRAIN FOR BEAUTY under the conditions of Article 2 – Recipients of personal data.

BRAIN FOR BEAUTY only keeps personal data for the time necessary to achieve the purpose for which it was collected.

Purpose	Legal basis
User account creation	Until the User’s request to delete or three (3) years from the last activity of the account
Order	Duration of the contract with the Client
Participation in a competition or promotional offer	Duration of the competition or promotional offer
Information request	Time needed to process the request
Newsletter Sign-Up	Until the request to unsubscribe or delete data or three (3) years from the last activity of the account
Processing the data carried out with BRAIN FOR BEAUTY customer service	Until the request for deletion of data or three (3) years from the last contact activity
Cookies	Maximum duration of thirteen (13) months based on the User’s consent
Compliance with a legal obligation and / or exercise of BRAIN FOR BEAUTY rights	Duration of the legal obligation or limitation period for legal action

ARTICLE 4 – USER RIGHTS

The person responsible for processing personal data is BRAIN FOR BEAUTY, on its own behalf. Each User proving their identity may require that personal data concerning them be communicated to them or that they be, as the case may be, rectified, supplemented, updated or deleted. Under the same conditions, the User can also withdraw his consent at any time, without affecting the lawfulness of the processing based on the consent made before its withdrawal.

Finally, the User benefits from the right to the portability of his personal data as well as the right to define directives relating to the fate of his personal data after his death. Each User proving his identity can also request the limitation or object to the processing of personal data concerning him for legitimate reasons. The rights of each User recalled herein are exercised by writing to contact@ingredientsecret.com or at 91 rue du Faubourg Saint-Honoré –75008 Paris.

A response is sent within one month of receipt of the request. If necessary, this period may be extended by two months, taking into account the complexity and the number of requests, in which case BRAIN FOR BEAUTY will keep the User informed. The User can lodge a complaint with the CNIL if he considers that the protection of his Personal Data has not been ensured as part of the processing carried out by BRAIN FOR BEAUTY.

ARTICLE 5 – UPDATE

BRAIN FOR BEAUTY is likely to change its Privacy Policy, in particular to comply with the laws and regulations in force. Changes affecting the Privacy Policy and their effective date will be communicated to Users in advance. After the date of entry into force, continued navigation on the Website will constitute acceptance of these changes.