Last update made the 20 / 07 / 2020.
Preamble:Aware of the importance of ensuring data confidentiality, the SYRES company makes strong commitments to the protection of personal data.
Also, this data protection policy aims to inform you about the commitments and practical measures taken by the company to ensure the respect of your personal data.
The SYRES company offers you to participate in consumer tests allowing you to evaluate one or more cosmetic, beauty or dermatological products, devices or services, marketed and / or under development under real conditions of use and in line with your habits.
The SYRES company is assigned by Promoters whose names can be revealed to you at the end of the tests, as well as those of the tested products.
The purpose of these tests is to assess the effectiveness and sensoriality of cosmetic products, in particular skincare, make-up, hair, sunscreen, hygiene, in real conditions of use, directly at your home, and in certain cases, exceptionally, that you come and test on one of our sites.
The products offered to you have been previously evaluated in terms of safety (toxicological and harmlessness tests) and all measures have been taken upstream to minimize any undesirable effects. They do not involve any serious foreseeable risk for use under normal conditions of use and offer the same guarantees as the products you buy on the market.
The products are delivered directly to your home and then during and / or at the end of their use you answer online questionnaires or questionnaires by post.
For each test performed, you will be given the dates to return the questionnaires as well as the instructions for using the products. It is important that you respect these conditions, otherwise your answers will not be taken into account and you may be removed from our panel. Indeed, if these conditions are not respected, you will receive a warning after which you will be deleted if you do not respect the conditions of the following test.
Likewise, SYRES reserves the right to remove you from its panel in the event of no response to calls and / or emails. You will also receive a warning before deleting your profile.
At the end of the tests, you can keep the products, except for specific tests.
The tests offered are generally not subject to compensation. In case of compensation, you will be informed before the test is carried out.
To participate in these tests, all you have to do is subscribe to the SYRES panel, by completing the Registration Form.
You will only be able to participate in a test if your profile matches that of the Study (age, sex, skin type, etc.) and if you do not have the following characteristics:
- Known skin / hair / scalp problems;
- Heavy medical or dermatological treatments in progress;
- History of allergies to cosmetic products;
- Women who are pregnant or likely to be or are breastfeeding in progress.
Between each test performed, you will have a deficiency of at least 2 months.
Personal data collected
The information concerning you, which is collected on the registration form and during the tests, is recorded in a computerized file by the SYRES Company (4, rue de Gally 78450 Chavenay - 01.30.79.92.50) and is subject to processing in accordance with the directives of the "Informatique et Liberté" law n ° 78-17 of 6 January 1978 as amended and the General Data Protection Regulation of 27 April 2016 (RGPD - n ° 2016/679 / EU).
With your prior consent, the personal data that are collected when you register for our consumer panel are the following: gender, surname and first name, date of birth, postal / telephone / email address, profession, allergies, children, languages spoken, ethnicity, skin / hair types and consumption patterns.
The information collected allows SYRES to determine your physical characteristics, as well as your consumption habits, in order to offer you consumer tests in line with your beauty habits.
Subsequently, the SYRES company may need to collect additional information on your consumption habits, or your physical characteristics, in order to complete your profile and offer you consumer tests in line with your habits.
When certain information is mandatory to participate in a consumer test, this mandatory character is indicated at the time of data entry. If this mandatory information is not disclosed to us, you may not have access to some of the tests offered by the company.
The data collected during the tests are used to determine the efficacy, cosmetics and / or acceptability of the products tested with our clients (Study Sponsors). We may also have to contact you again after the tests in order to ask you additional questions, which happens more particularly in the event of stopping the test or of a reaction of discomfort or intolerance to the products.
The SYRES company makes sure to collect and process only data strictly necessary for the purpose for which they are processed (minimization of data).
Purposes of the personal data collected
Your personal data is collected by the SYRES Company for the following purposes:
- Verification, identification and authentication of transmitted data;
- Recruitment in order to make you participate in various tests, according to the inclusion and exclusion criteria and the directives of the Promoter of the consumer test;
- Carrying out consumer surveys and studies aimed at improving consumer needs and practices and assessing the efficacy and tolerance of the Products;
- Management of requests for the right of access, rectification and opposition;
- With your consent: we use information about you when you have given us your consent for a specific purpose not mentioned above;
- To protect our legitimate business interests and legal rights: where required by law or where we believe it is necessary to protect our legal rights, interests and interests of others, we use information about you in connection with legal claims, compliance, audit functions and information relating to the acquisition, merger or sale of a business.
These purposes have been brought to the attention of our Data Protection Officer through the preliminary formalities made with the latter.
Transmission of personal data
The personal data that we collect, as well as that which is collected subsequently, is intended for us.
We ensure that only authorized persons can have access to this data. The people authorized to access your data are:
- The authorized persons of the SYRES company;
- The Promoter of the Study concerned;
- The partners of the company SYRES;
- The service providers with whom we work, and only to the extent necessary for the accomplishment of the tasks entrusted to them.
Your personal data may be communicated in application of a law, a regulation, a decision of a regulatory or judicial authority and finally, if necessary for the company SYRES, in order to protect its rights and interests.
The data transferred to the Study Sponsors are mainly the data collected during the tests, i.e. your answers given to the test questionnaire (s), and are transmitted in a pseudonymized manner.
We may also send them other data about you, to prove that you meet the inclusion criteria given by the Promoter, such as your age, skin / hair type, gender and ethnicity.
In case you have made a reaction of discomfort or intolerance to a product tested, we can also send them additional information after completing a response sheet with you by phone or email.
The Study Sponsor may also ask to get in touch with you directly, in which case we will first ask for your consent before sending them your personal details.
Outside of consumer surveys and studies, we share the information we collect about you in the following circumstances:
- When carrying out Studies with our partners: We may need to contact you to participate in Studies with our partners and you will only be tested with them with your prior consent. All data collected by our partners during these tests are only used for the Study of the test in question;
- During the audit of the Study Promoter: The Study Promoter may possibly consult our databases as part of an Audit with our company. This consultation can only be done on our premises and under our control. None of this data can leave the SYRES company premises;
- Business transfers: If we are acquired or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we collected from the other company;
- In response to legal process: We may also disclose the information we collect from you to comply with the law, legal process, court order or other legal process, for example in response a court order or subpoena;
Transfer of personal data outside the European Union
Within the framework of the purposes mentioned above, we may be likely to transmit your personal data to companies located in countries which are not members of the European Economic Area (European Union, Iceland, Liechtenstein, Norway), including Personal data protection laws differ from those of the European Union.
In case of transmission of your personal data outside the European Union, you will be informed of this when recruiting for the test.
Transfers made to other countries are governed by the following appropriate guarantee measures:
- The data may be transferred to our service providers established in the United States, as part of the provision of IT services. The latter have adhered to the EU-US Privacy Shield and ensure an adequate level of data protection (Decision (EU) 2016/1250 of 12-7-2016);
- For other countries outside the EU, standard contractual clauses approved by the European Commission.
You can obtain communication of the guarantees taken by contacting our Data Protection Officer: firstname.lastname@example.org.
Retention period of personal data
The retention periods that we apply to your personal data are proportionate to the purposes for which they were collected.
If you wish to have more information on the retention of your data, you can send an email to our Data Protection Officer at the following address email@example.com.
Security and confidentiality of personal data
The SYRES company attaches great importance to the security of your data.
Appropriate technical and organizational measures are implemented to ensure that the data are processed in such a way as to guarantee their protection against loss, destruction or accidental damage which could affect their confidentiality or their integrity.
When developing and designing, or when selecting and using the various tools that allow the processing of personal data, we ensure that they ensure an optimal level of data protection. processed.
This is the reason why we take all appropriate measures to prevent as far as possible any alteration or loss of your data or any unauthorized access to them.
When we use a service provider, we only communicate personal data to him after having obtained from the latter a commitment and guarantees on his ability to meet these security and confidentiality requirements.
We enter into contracts with our subcontractors in compliance with our legal and regulatory obligations that precisely define the conditions and methods of processing personal data by them.
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Implementation of rights concerning personal data
Thus, you have the right to access, rectify, erase your personal data or limit the processing concerning you. You also have the right to define guidelines regarding the fate of your personal data after your death. You can also, for legitimate reasons, oppose the processing of your data and have the right to withdraw your consent at any time.
Visit cnil.fr for more information on your rights.
You can exercise these rights at any time by contacting our Data Protection Officer at the following address firstname.lastname@example.org, or by post to the following address: 4, rue de Gally 78450 Chavenay.
Any request by post or e-mail must be signed and accompanied by a photocopy of an identity document bearing your signature and specify the address to which the reply must be sent. A response will then be sent to you within one month of receipt of the request.
Data subjects have the right to lodge a complaint with the CNIL by writing to: CNIL - 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX.
We have appointed a Personal Data Protection Officer whose contact details are as follows: email@example.com.
This Data Protection Officer is responsible in particular for advising, informing and monitoring compliance with data protection regulations.
We invite you to regularly consult this confidentiality policy available on our site, in order to be aware of any changes.