1. Introduction
In this general L.C.S. Laboratory Cosmetic Swiss Sa Privacy and Data Protection Policy (hereinafter, the “Policy”) we describe how we collect your Personal Data and why, what we do with your Personal Data, with whom we share it, how we protect it and what choices you can make regarding your Personal Data.
This policy applies to the processing of your Personal Data within the various services, tools, applications, websites, portals, (online) commercial promotions, commercial actions, sponsored social media platforms, etc. provided or operated by us or on our behalf.
This policy contains general rules and explanations. It is supplemented with specific privacy policies relating to particular services, tools, applications, websites, portals, (online) commercial promotions, commercial actions, sponsored social media platforms, etc. provided or managed by L.C.S. Laboratory Cosmetic Swiss Sa or on its behalf.
This privacy policy will be communicated to you whenever your personal data is requested within the framework of the above-mentioned activities (e.g. via websites, portals, individual communication services, newsletters, reminders, market surveys, offers, events, etc.). This policy applies to all personal data collected by (or on behalf of) L.C.S. Laboratory Cosmetic Swiss Sa, for the purposes of this policy referred to below as “LCS”, “we”, “us” and “our”.
If you agree to the provisions of this Policy, you consent to our processing of your personal data in the manner described in this Policy.
At the bottom of this Policy you will find definitions of certain key concepts used in this Policy and which are indicated with a capital letter (e.g. personal data, processing, data controller…).
2. Who is responsible for the processing of your personal data?
The entity responsible for processing your personal data is:
L.C.S. Laboratory Cosmetic Swiss Sa
Via Camuzio 19 – 6900 Lugano (SVIZZERA)
3. Who can you contact if you have questions or requests? The contact point for data protection
We have set up a data protection contact point which will deal with your questions or requests regarding this Policy, any specific privacy notices and your personal data (and its processing).
If you have any questions, requests or complaints about the application of this Policy or if you wish to exercise your rights as described in this Policy, you may contact us via the Data Protection point of contact: privacy@lcswiss.com
4. Key Principles
We place the highest value on the personal data you give us, and we are committed to handling it fairly, transparently and securely. The key principles that L.C.S. Laboratory Cosmetic Swiss Sa applies are:
- Lawfulness: We will only collect your personal data in a fair, lawful and transparent manner.
- Data minimisation: we will limit the collection of your personal data to that which is directly relevant and necessary for the purposes for which it was collected.
- Purpose limitation: we will only collect your personal data for specific, explicit and lawful purposes, and will not further process your personal data in a manner incompatible with those purposes.
- Accuracy: we will keep your personal data accurate and up-to-date.
- Data security and protection: we will take all technical and organisational measures to ensure an adequate level of data security and protection considering, among other things, the nature of your personal data to be protected. These measures serve to protect against any unauthorised disclosure or access, accidental or unlawful destruction or loss, or alteration and any other form of unlawful processing.
- Access and correction: we will process your personal data in compliance with your legal rights.
- Retention limitations: we will retain your personal data in a manner that complies with applicable laws and regulations, for no longer than is necessary for the purposes for which it was collected.
- Protection for international transfer: we will ensure that any of your personal data transferred outside the EEA is adequately protected.
- Third party safeguards: we will ensure that access to personal data by (and transfer to) third parties is in accordance with applicable law and appropriate contractual safeguards.
- Legality of direct marketing and cookies: when we send you promotional materials or send cookies to your computer, we shall ensure that we do so in accordance with applicable legislation.
5. Processing of your personal data: what personal data we collect and on what legal basis
Whenever we request your personal data, we will clearly inform you about what personal data we collect. This information will be communicated to you by means of a specific privacy policy which, for instance, will be included in specific services (including communication services), e-newsletters, reminders, market surveys, offers, invitations to events, etc.
Please note that, in accordance with applicable data protection legislation, your personal data may be processed if:
- you have given us your consent for the purposes of processing (as described in the privacy policy for that particular type of processing). For the avoidance of doubt, you have the right to revoke your consent at any time; or
- is necessary for the performance of obligations under a contract you have signed; or
- that processing enables us to pursue a legitimate interest that is not overridden by your right to privacy. These legitimate interests will be duly disclosed to you in the privacy policy relating to that particular type of processing.
- is required by law.
6. For what purposes we process your personal data
We will only process your personal data for specific, explicit and lawful purposes, and we will not further process your personal data in a manner incompatible with those purposes.
These purposes may be the execution of an order you have placed with us, improving the navigability by you of one of our websites or portals, improving one of our products and services more generally, offering services or applications, marketing actions and communications, etc. The purpose of each processing of your personal data will be clearly defined in the specific privacy policy relating to that particular processing. This privacy policy will be accessible, for example, on a website or portal, in an application, in an e-mail newsletter, etc.).
7. Keeping your personal data accurate and up-to-date
It is important for us to keep a record of your personal data always accurate and up-to-date. Please inform us of any changes or errors in your personal data as soon as possible by contacting us via our data protection contact point (see Section 3 ‘Who Can You Contact If You Have Questions Or Requests?’). We will take all measures reasonably necessary to ensure that any inaccurate or outdated personal data is deleted or amended as necessary.
8. Access to your personal data
You have the right to access your personal data that we are processing and, if your personal data is inaccurate or incomplete, you have the right to request its correction or deletion. If you would like more information about your privacy rights or would like to exercise any of these rights, please contact us via our data protection contact point (see Section 3 “Who Can You Contact If You Have Questions Or Requests?”).
9. How long we keep your personal data
We will store your personal data in accordance with applicable data protection legislation. We will only retain your personal data for as long as is necessary for the purposes for which we process your personal data or to comply with legal obligations. For information on the expected duration of retention of personal data before deletion from our systems and databases, please contact us via our data protection contact point (see Section 3 ‘Who Can You Contact If You Have Questions Or Requests?’).
10. Protecting your personal data
We have implemented a number of technical and organisational security measures to protect your personal data from any unlawful or unauthorised access or use, as well as from any loss or damage to their integrity. These measures have been designed taking into consideration our IT infrastructure, the potential impact on your privacy and the costs involved, as well as industry standards and practices.
Your personal data will only be processed by an external data processor if this external data processor agrees to comply with these technical and organisational data security measures.
Maintaining data security means protecting the confidentiality, integrity and availability of your personal data:
(a) Confidentiality: we shall protect your personal data from unwanted disclosure to third parties.
(b) Integrity: we will protect your personal data from modification by unauthorised third parties.
(c) Availability: we shall ensure that all authorised parties have access to your personal data when necessary.
Our data security procedures include secure access, backup systems, monitoring, auditing and maintenance, security incident management, continuity, etc.
11. Use of cookies or similar systems
We make use of cookies on our websites. This helps us to improve your experience when you browse one of our websites, and also allows us to improve our sites.
For more information on how we use cookies and how to avoid them, please see our cookie policy, available at
https://www.lcswiss.com/en/cookies-policy/
12. Disclosure of personal data
Depending on the purposes for which we collect your personal data, we may disclose it to the following categories of recipients, who will then only process your personal data within the limits of the respective purposes:
a) Within our organisations and as part of our branding:
– Authorised members of our staff;
– Our affiliated and subsidiary companies;
– Members of our preferred Authorised Dealer network or those who are located near you (based on your postcode or address) or with whom you have come into contact;
b) Third Party Business Partners:
– Advertising, marketing and promotional agencies: to help us achieve and analyse the effectiveness of our advertising and promotional campaigns;
– Marketing partners: for example, trusted companies who may use your personal data to provide you with the services and/or products you have requested and/or who may provide you with marketing materials (provided that you have given your consent to receive those marketing materials) We require these companies to act at all times in accordance with applicable legislation and this Policy, and to take the utmost care to maintain the confidentiality of your personal data;
c) Other third parties:
– When required by law or as legally necessary to protect L.C.S. Laboratory Cosmetic Swiss Sa:
– to comply with laws, requests from authorities, court orders, legal procedures, reporting and filing obligations with authorities, etc;
– to verify or enforce L.C.S. Laboratory Cosmetic Swiss Sa policies or agreements; and
– to protect the rights, property or safety of L.C.S. Laboratory Cosmetic Swiss Sa and/or its customers;
– In connection with corporate transactions: in the context of a transfer or disposal of a business or a business, or in connection with a merger, consolidation, change of control, reorganisation or liquidation of an entire business of L.C.S. Laboratory Cosmetic Swiss Sa or a part thereof.
Please note that the third-party recipients listed under b) and c) above – especially service providers who may offer you products and services through the applications and channels of L.C.S. Laboratory Cosmetic Swiss Sa or through their own channels – may collect your personal data directly and independently from you. In such cases, these third parties are solely responsible for controlling such personal data and your relationship with them will be governed by their terms and conditions.
13. Specific contacts with our authorised dealers
If you purchase a product or service from one of our Authorised Resellers, or if you give them your personal information, you will have a separate relationship with the Authorised Reseller. In this case they become the owner of your personal data, possibly shared with us. If you have any questions or requests about the collection and use of your personal data by an Authorised Reseller, please contact them directly.
14. Use of social media
If on a L.C.S. Laboratory Cosmetic Swiss Sa tool (website, portal, etc.) you use a specific login from a social media outlet (e.g. your Facebook account), L.C.S. Laboratory Cosmetic Swiss Sa will record your personal data available on that social media outlet; your use of that social media outlet means that you have specifically consented to the disclosure of your personal data recorded by L.C.S. Laboratory Cosmetic Swiss Sa via its tool.
Sometimes L.C.S. Laboratory Cosmetic Swiss Sa facilitates the publication of (personal) data via social media, such as Twitter and Facebook. These social media have their own terms of use, which you should take into account when using them. Please note that publishing content on social media can have certain consequences, including for your privacy or that of persons whose personal data you share, such as the inability to delete a publication quickly. You are fully responsible for your publications. L.C.S. Laboratory Cosmetic Swiss Sa shall have no liability in this respect.
15. Transfer outside the EEA
Your personal data may be transferred to recipients located outside the European Economic Area (EEA) and may be processed by us and these recipients outside the EEA. In relation to any transfer of your personal data to countries outside the EEA which do not generally offer the same level of data protection as countries within the EEA, L.C.S. Laboratory Cosmetic Swiss Sa will take appropriate specific measures to ensure an adequate level of protection for your personal data. These measures may consist, for example, of entering into binding contracts with the recipients that guarantee this adequate level of protection.
We will always inform you clearly whenever your personal data may be transferred outside the EEA. This information will be communicated to you by means of a specific privacy policy which, for instance, will be included in specific services (including communication services), e-newsletters, reminders, market surveys, offers, invitations to events, etc.
16. Your choices and rights
We want to be as transparent as possible with you, so that you can make informed choices about how you want us to use your personal data.
– Your choices about how you want to be contacted.
Here you can make a number of choices about how you want to be contacted by us, through which channel (e.g. email, postal mail, social media, telephone, etc.), for what purposes and how often, by changing the privacy settings on the device you use or updating your user profile or account, or by following the unsubscribe instructions that will be included in the communication.
Please note that as a basic rule, if you do not make a choice, you will receive our promotional communications at the normal frequency of the publication concerned.
– Your personal data
You can contact us at any time via the data protection contact point (see section 3, ‘Who can you contact if you have questions or requests?’) to find out which of your personal data we hold and where it comes from. Under certain conditions you have the right to receive your personal data, which you have provided to us, in a commonly used format usable by any electronic device, and to transmit your personal data to any third party of your choice.
– Your corrections
If you notice any errors in your personal data or if you realise that they are incomplete or incorrect, you can ask us to correct or supplement them.
– Your restrictions
You have the right to request a restriction on the processing of your personal data (e.g. while the accuracy of your personal data is being checked).
– Your objections
You can also object to the use of your personal data for direct marketing purposes (if you prefer, you can also tell us through which channels and how often you prefer us to contact you) or to their sharing with third parties for the same purposes.
You may at any time revoke your consent to the further processing of your personal data that you have provided to us by contacting us via our data protection contact point (see Section 3 “Who Can You Contact If You Have Questions Or Requests?”).
In addition, you may request us to delete any data concerning you (except in certain cases, e.g. to prove a transaction or when required by law). Finally, please note that you have the right to lodge a complaint against the Data Controller with the competent Data Protection Authority (DPA). With regard to TME (as Data Controller), the competent DPA is the Data Protection Authority of Switzerland.
17. Legal information
The provisions of this policy supplement, but do not replace, the existing provisions of data protection laws. In the event of a conflict between what is written in this policy and the requirements of the applicable data protection law, the data protection law shall prevail.
L.C.S. Laboratory Cosmetic Swiss Sa may change this policy at any time. Should this happen, we will inform you of all changes and ask you to re-read the most up-to-date version of our policy and confirm your acceptance of it.
18. Definitions
In this Policy, the terms indicated below have the following meanings:
(a) Data controller means the organisation that determines the purposes for which and the manner in which your personal data is processed. Unless otherwise communicated by us, the Data Controller(s) is/are L.C.S. Laboratory Cosmetic Swiss Sa (Via Camuzio 19 – 6900 Lugano SWITZERLAND). Further information may be communicated to you by means of a specific privacy policy which, for example, will be included in individual services (including communication services), electronic newsletters, reminders, market surveys, offers, invitations to events, etc.
(b) Data Processor means the person or organisation that processes your personal data on behalf of the Data Controller.
(c) Data protection point of contact means the contact point (i.e., the person appointed by L.C.S. Laboratory Cosmetic Swiss Sa in the jurisdiction concerned) through which you can forward to the Data Controller your questions or requests relating to this Policy and/or (the processing of) your personal data, and who will handle such questions and requests. Unless we communicate otherwise, the data protection contact point can be reached as described in Section 3 (“Who Can You Contact If You Have Questions Or Requests?”).
(d) EEA means the European Economic Area (= the member states of the European Union + Iceland, Norway and Liechtenstein).
(e) Personal data means all data that relate directly or indirectly to you, or which enable you to be identified, such as your name, telephone number and e-mail address.
Unless otherwise communicated by us, the Data Controller(s) is/are L.C.S. Laboratory Cosmetic Swiss Sa (Via Camuzio 19 – 6900 Lugano SWITZERLAND).
