# PRIVACY POLICY > DATA PROTECTION AND PRIVACY POLICY Welcome to FRESHLY COSMETICS The present Data Protection Policy of FRESHLY COSMETICS will be applied to the browsing of ou Source: https://freshlycosmetics.kustomer.support/en_us/privacy-policy-SyUhOqS6xg Last updated: 2026-05-21T10:44:45.009Z **PRIVACY AND DATA PROTECTION POLICY** Welcome to FRESHLY COSMETICS! This FRESHLY COSMETICS Data Protection Policy applies to browsing our website, [www.freshlycosmetics.com](http://www.freshlycosmetics.com), as well as to the purchase of our products through it. * * * ### **1\. Who is responsible for processing your personal data?** Controller: FRESHLY COSMETICS, S.L. Tax ID: B-55666143 Address: C/Nicaragua, 36, Reus (Tarragona) 43204 Registration details: registered in the Commercial Registry of Tarragona, Volume 2,899, Page 18, Sheet number T-48.80 Contact: hello@freshlycosmetics.com Data Protection Officer: dpo@freshlycosmetics.com UK Contact: ukdp@freshlycosmetics.com * * * ### **2\. What presence does FRESHLY COSMETICS have on social media?** FRESHLY COSMETICS has profiles on the main social media platforms on the Internet (Pinterest, LinkedIn, Snapchat, Facebook, Instagram, YouTube and TikTok). FRESHLY COSMETICS acknowledges itself as the controller of the data of its users, followers, or individuals who make comments through these platforms. FRESHLY COSMETICS disclaims any liability arising from comments made by users and followers on its social media. FRESHLY COSMETICS may use the profiles described above to inform its users about topics it considers to be of interest. In relation to certain platforms such as Facebook, Instagram or TikTok, FRESHLY COSMETICS may act as a joint controller together with those platforms with respect to certain data. For more information, please consult the privacy policies of each social network. * * * ### **3\. What personal data do we collect about you?** The personal data we may collect are as follows: ● **Identification data:** First name and surname, postal and email address, and telephone number. ● **Payment information:** Payments for our products are processed through the platforms of Adyen B.V., PayPal, Checkout and Klarna (secure payment gateways), therefore FRESHLY COSMETICS does not store any personal data of this nature. ● **Personal data to create a product routine:** gender, data related to pregnancy or breastfeeding, age, skin type, etc. ● **Profile data:** username and password, purchases or orders made, preferences, comments and responses to surveys, as well as any profile data that we may add (such as the use of data analytics or profiling). ● **Information about your visits to the website [www.freshlycosmetics.com](http://www.freshlycosmetics.com):** IP address of your device, date and time of access. For more information on this processing, please consult our Cookie Policy. ● **Any data that you voluntarily send to our email address hello@freshlycosmetics.com or transmit to us through chat or other communication channels.** ● **Any information that you voluntarily share publicly on FRESHLY COSMETICS social media.** Such information will be subject to the privacy policy of the social network on which it is shared, so we recommend that you review the privacy settings of your profile. ● **Marketing and communication data:** data about your preferences in receiving direct marketing from us or from third parties, as well as your communication preferences. We also collect, use, and share aggregated data, such as statistical or demographic data, regardless of its purpose. Aggregated data may be derived from your personal data, but legally it is not considered personal data because it does not reveal your identity, either directly or indirectly. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific feature of the website. To improve the service and content we offer, the **FRESHLY COSMETICS** website uses the web analytics service **Google Analytics**. However, if we combine or connect aggregated data with your personal data in a way that allows for direct or indirect identification, we will treat the combined data as personal data in accordance with this Privacy Policy. ### 4\. Do we process data from minors? The sale of our products is not intended for minors. However, minors under the age of **16** who wish to register on our website and/or purchase our products must have the permission of their father/mother/guardian or legal representative. Similarly, if you share images on our social networks in which minors under the age of **16** appear, you must ensure that you have previously obtained the authorization of the minor's father/mother/guardian or legal representative. **FRESHLY COSMETICS** reserves the right to request proof of this authorization at any time. ### 5\. For what purposes do we process your personal data? **FRESHLY COSMETICS** processes your personal data for the following purposes: * To provide you with the information you request regarding our products. * To ensure the proper processing of your order. For example, when you make a purchase with us through our website. * When you register as a user via our website. * To manage subscriptions to our newsletter and the sending of commercial communications, which include calls, SMS, and email. * To manage subscriptions to the loyalty program. * To manage your participation in giveaways, promotions, and/or surveys. * We conduct a personalized test so you can discover the best routine for you; therefore, we must collect certain data considered sensitive. The data we require includes: gender, age, skin type, pregnancy, habits, etc. The processing of this data, due to its nature as special category data relating to health, is carried out based on the explicit consent of the data subject in accordance with **Article 9.2.a)** of the General Data Protection Regulation (GDPR). * We use your identification, technical, contact, tracking, usage, and profile data to create a picture of what we think you may want or need, or what may be of interest to you. This allows us to decide which products, services, and offers may be relevant to you. This process is called "direct marketing." * We also collect personal data from your CV/resume via our website. For example, if there is a job opening at **FRESHLY COSMETICS** that matches your profile, please apply as we would like to get to know you. * When we must comply with a legal or regulatory obligation. For example, maintaining sales records to comply with our tax obligations. We always strive to clearly indicate on our website what we are doing and what communications we will send you, both when you decide to sign up for our newsletter and when you participate in a promotion or survey. Of course, you have the right to change your mind at any time and unsubscribe from these services. The easiest way to cancel your subscription and unilaterally revoke your consent at any time is to send an email to **dpo@freshlycosmetics.com** (or **ukdp@freshlycosmetics.com** for the UK) or click the unsubscribe link found at the bottom of every communication. ### 6\. What is the legal basis for processing your personal data? We use your personal data only when the law allows us to. Please note that, depending on the specific purpose for which we use your personal data, its processing may rely on more than one legal basis. Generally, this will occur under the following circumstances: * **Performance of a contract:** For the management of your purchases via our website. * **Consent:** This legal basis is required for the following purposes: * Managing your newsletter subscription and sending commercial communications (calls, SMS, and email). * Managing loyalty program subscriptions. * Managing participation in giveaways, promotions, and/or surveys. * Acceptance of cookies for direct marketing and/or profiling purposes. * Conducting personalized service/product tests. Since this test includes health-related data, we request your specific and explicit consent for this processing. * Managing your application for a job offer. * Creating commercial profiles based on harmonized personal data. * **Compliance with legal obligations of FRESHLY COSMETICS:** * Fraud investigation. * **Legitimate interest of FRESHLY COSMETICS:** To improve our products and customer service, or to manage your requests. We collaborate with **Microsoft Clarity** and **Microsoft Advertising** to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replays to improve and market our products/services. Website usage data is collected using first-party and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information on how Microsoft collects and uses your data, please see the **Microsoft Privacy Statement**. If you need further information regarding this, please do not hesitate to contact us. ### **7\. Who has access to your personal data?** Your personal data will only be communicated to those persons or entities that need access to it in order to manage orders for our products or services. ● **Hosting provider:** ○ Amazon Web Services. Provider of cloud computing technological infrastructure services, including storage, processing and data hosting. You can consult its privacy policy at: [https://aws.amazon.com/es/privacy/](https://aws.amazon.com/es/privacy/) ● **Payment providers:** ○ Adyen B.V.: online payment processing platform. [www.adyen.com/es\_ES/privacy-policy](http://www.adyen.com/es_ES/privacy-policy) ○ PayPal: digital payment services provider. [www.paypal.com/es/legalhub/paypal/privacy-full](http://www.paypal.com/es/legalhub/paypal/privacy-full) ○ Checkout.com: electronic payment processing platform. [www.checkout.com/legal/privacy-policy](http://www.checkout.com/legal/privacy-policy) ○ Klarna: provider of deferred payment and financing solutions. [https://www.klarna.com/es/privacidad/](https://www.klarna.com/es/privacidad/) These providers enable the secure management of payments made through our website. When a user makes a purchase, certain data necessary to process the transaction (such as identification data, purchase amount and billing data) are communicated to these providers. FRESHLY COSMETICS does not store or have access to the full payment method data. These providers generally act as independent data controllers and will therefore process the data in accordance with their own privacy policies, available on their respective websites. ● **Chat applications:** In our direct interactions with our customers or users we use an application. In this regard, for more information about it and to understand how it processes personal data, please consult the following privacy policies: ○ Kustomer: For more information about this application and to understand how it processes personal data, please consult its privacy policy at: [www.kustomer.com/privacy/policy/](http://www.kustomer.com/privacy/policy/) ● **Software for sending commercial communications:** ○ Klaviyo. For more information about this software and to understand how it processes personal data, please consult its privacy policy at: [www.klaviyo.com/legal](http://www.klaviyo.com/legal) We require all third parties with whom we collaborate to respect the security of your personal data and to process it in accordance with applicable legislation. Likewise, we do not allow external service providers to use your personal data for their own purposes, and we ensure that they only process it for the specified purposes and in accordance with our instructions. * * * ### **7.1. International data transfers** Whenever we transfer your personal data outside the European Economic Area, we will comply with the applicable data protection legislation. These are some of the mechanisms we may use when carrying out an international transfer: ● The transfer of your personal data is carried out to a country that the European Commission officially considers to provide an adequate level of protection for personal data. ● We reserve the right to use specific contracts approved by the European Commission that give personal data the same protection it enjoys in Europe (the so-called EU standard contractual clauses). * * * ### **8\. How long do we retain your data?** Your personal data will be retained for as long as necessary to fulfil the purposes for which they were collected. After this period, FRESHLY COSMETICS will delete them from its systems, without prejudice to the possibility of retaining them, limiting their processing to the exercise and defence of claims, under the terms provided for in the applicable legislation. * * * ### **9\. What security measures do we apply to the processing of your data?** FRESHLY COSMETICS applies security measures to guarantee the confidentiality, availability and resilience of personal data processing systems. Likewise, we carry out verification and evaluation processes of the technical and organisational measures implemented, in order to guarantee the security of personal data at all times. * * * ### **10\. What are your rights?** You may exercise the rights listed below by sending an email to the following address: dpo@freshlycosmetics.com (or ukdp@freshlycosmetics.com in the case of the United Kingdom) ● Request, at any time, that FRESHLY COSMETICS confirm whether or not it is processing your personal data. ● Access your personal data, request the rectification of those that are inaccurate or, where appropriate, request their deletion when, among other reasons, they are no longer necessary for the purposes for which they were collected. ● In certain cases, request the restriction of the processing of your data. In this case, we will only retain your data for the exercise or defence of claims. ● In certain circumstances, object to the processing of your data. ● Request the portability of your data. ● Withdraw the consent that you may have given for the processing of your data by FRESHLY COSMETICS. ● Lodge a complaint with the competent data protection supervisory authority. * * * ### **11\. How to contact us?** We always want to hear from our customers, especially if you believe we can do better. If you: * Have any questions or comments about this notice * Want us to stop using your data * Wish to exercise any of your rights as set out above, or have a complaint Do not hesitate to contact our customer service team, who will be happy to answer any questions you may have. You can contact our privacy team by writing to us at the general email address, or if you prefer you can contact us at: FRESHLY COSMETICS, S.L. * Contact: hello@freshlycosmetics.com * Data Protection Officer: dpo@freshlycosmetics.com **UK visitors** We are committed to complying with the relevant data protection legislation wherever we operate. To this end, our processes comply with both the UK GDPR and the Data Protection Act 2018. Our point of contact for UK website visitors is as follows: FRESHLY COSMETICS UK, LIMITED * Address: WSM, Connect House, 133-137 Alexandra Road, Wimbledon, London SW19 7JY. * Contact: ukdp@freshlycosmetics.com If you have any questions related to your specific rights in the United Kingdom or wish to exercise those rights under the UK GDPR, please contact us at the email address above. * * * **Last update: 27/03/2026**