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Your privacy is important to Pierre Fabre. This privacy notice explains how we handle and treat your personal data when you use the products or services that Pierre Fabre provides (hereafter the "Notice").

 

By personal data, we mean any directly or indirectly identifiable information about you, collected or otherwise received by Pierre Fabre, as defined by the General Data Protection Regulation (EU) 2016/679 ("GDPR") and described in this Notice.

 

This Notice explains our approach to any personal data that we collect from you or that we have obtained about you from a third party and the purposes for which we process your personal data. It also sets out your rights in respect of our processing of your personal data.

 

We may collect personal data from you in the course of our business, including through your use of our B2B websites/platform, when you contact or request information from us, or as a result of your relationship with one or more of our staff or partners.

 

1. Who is responsible for your personal data?

 

2. What personal data do we collect about you?

 

3. How do we use your personal data?

 

4. Who do we disclose your personal data to?

 

5. How long do we retain your personal data?

 

6. What are your rights?

 

7. Contact and complaints

 

8. Changes to this Notice

 

 

 

 

1. Who is responsible for your personal data?

 

Pierre Fabre SA, with registered office as société anonyme à conseil d'administration, registered under SIREN 662006170 is established in PARIS (75008) (“Pierre Fabre” or “we”), is the controller for the processing your personal data in the context of our business relationship.

 

2. What personal data do we collect about you?

 

We collect personal information about you, such as:

 

• Contact information including your email address
• Information that you provide to us as part of us providing services to you, which depends on the nature of your instructions to Pierre Fabre,
• Information you provide to us for the purposes of attending meetings, and
• Other information relevant to provision of services.

 

The personal data that is indispensable for us to fulfill the purposes that are described above, is marked with an asterisk on the form where it is collected. Should you choose not to fill in these mandatory fields, we may not be able to process your requests and/or to provide you the requested products and services. Other personal data is purely optional and allow us to know you better and to improve our communications and services accordingly. Further information on purposes and legal basis for specific processing scenarios can be found below.

 

3. How do we use your personal data?

 

We use your personal data for the purposes listed below. As required by law, whenever we process your personal data, we do so on the basis of a lawful "justification" (or lawful basis) for processing, which we have identified and explained in the table below , in accordance with GDPR standards..

 

	Purpose for processing	Lawful basis
	To carry out administrative operations relating to agreements, orders, receipt of deliveries, invoices, payments, accounting in relation to customer accounts management, etc.	The performance of the contract between you and Pierre Fabre.
	To comply with our legal obligations in terms of client verifications (including any Know Your Client, Anti-Money Laundering or Anti-Bribery regulations), conflicts or similar obligations including, but without limitation, maintaining regulatory insurance.	This processing is necessary to comply with our legal obligations. However, where such legal obligations result from laws other than EU or Member State law, then we consider that we have a legitimate interest in complying with such legal obligations when non-compliance may result in sanctions or other adverse consequences for our organization or the Pierre Fabre group in general.
	To comply with any applicable law, court order, other judicial process, or the requirements of a regulator	This processing is necessary to comply with our legal obligations.
	To enforce our agreements with you.	We consider that we have a legitimate interest in ensuring that our contracts are performed correctly and in defending our rights where necessary.
	To enforce our legal rights and obligations, and for any purposes in connection with any legal claims made by, against or otherwise involving you.	We consider that we have a legitimate interest in protecting our organization from breaches of legal obligations owed to it and to defend itself from litigation.
	To protect the rights of third parties.	This processing is necessary for the compliance with legal obligations to which Pierre Fabre is subject. This processing is also necessary for the purpose of the legitimate interests pursued by Pierre Fabre. We consider that we have a legitimate interest in ensuring our activities do not violate any third parties’ rights.
	In contemplation of and/or in connection with a business transaction such as M&A, or  restructuring, or sale.	We consider that we have a legitimate interest as we need to be able to make decisions relating to the future of our business in order to preserve our business operations or grow our business.

 

If you are an employee of one of Pierre Fabre’s corporate partners, we only use your contact information for the management of the relationship with your employer. We consider that we have a legitimate interest in ensuring we can communicate with you and preserve our business operations with your employer.  

 

4. Who do we disclose your personal data to?

 

We may share your personal data with a variety of the following categories of third parties as necessary:

 

• Other entities of the Pierre Fabre group (the list of Pierre Fabre affiliates is available here:  pierre-fabre.com,
• Third party service providers (maintenance, storage, payment, logistics, marketing services, etc.), for the purposes described in Section 3 above,
• Third party postal or courier providers who assist us in delivering our postal marketing campaigns to you, or delivering documents related to a matter,
• Our professional advisers such as lawyers and accountants, auditors,
• Shareholders,
• Professional insurers or any other relevant insurers, and
• Regulators/tax authorities/corporate registries.

 

Please note this list is non-exhaustive and there may be other examples where we need to share with other parties where justified by our legitimate interest, permitted by applicable law, or necessary for compliance with a legal obligation to which we are subject.

 

In this context, your personal data may be transferred outside the European Economic Area (EEA), to countries not offering a level of protection of personal data equivalent to that offered within the EEA. Given the fact that some of these non EU countries do not ensure an adequate level of protection of Personal Data as in the European Union, Pierre Fabre shall in accordance with applicable regulations, ensure the protection of your Personal Data as follows:

• within the Pierre Fabre Group, through the conclusion of an Intra-Group Data Transfer Agreement including the standard contractual clauses published by the European Commission; and
• when using the services of external service providers, through the implementation of standard contractual clauses published by the European Commission.

You can obtain a copy of the relevant safeguard by contacting our Data Protection Officer dpofr@pierre-fabre.com although some details may be omitted for confidentiality reasons.

 

5. How long do we retain your personal data ?

 

Our general approach is to retain your personal data only for as long as required to fulfil the purposes for which it was collected. We generally retain your personal data for the duration strictly necessary for the management of our relationship with you. However, unless you object, we retain your personal data used for marketing purposes for an additional 3-years period after the end of our relationship with you.

 

However, we may in addition retain personal data for longer periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements, or where such data is necessary to establish the existence of a right or contract. In that case, your personal data will be archived and retained for the duration imposed by applicable law, or for the duration of the applicable statute of limitations.

 

When your personal data will no longer be necessary, the data will be deleted or anonymized.

 

6. What are your rights?

 

You have a number of rights in relation to your personal data. More information about each of these rights is set out below:

 

• Withdrawal of consent. You can withdraw at any time your consent in respect of any processing of personal data based on your consent, without affecting the lawfulness of processing based on your consent before its withdrawal.
• Access. You can ask us to confirm whether we process your personal data and, as the case may be, inform you of the characteristics of such processing, allow you to access such data and give you a copy of it. 
• Rectification. You can ask us to rectify or complete inaccurate or incomplete personal data. 
• Erasure. You can ask us to erase your personal data in the following cases: where it is no longer necessary for the purposes for which it was collected; you withdrew your consent; you objected to the processing of your personal data; your personal data has been processed unlawfully; or to comply with a legal obligation. We are not required to comply with your request notably if the processing of your personal data is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.
• Restriction. You can ask us to restrict the processing of your personal data (i.e., keep but not use your personal data) where: the accuracy of your personal data is contested; the processing is unlawful, but you do not want it erased; it is still necessary to establish, exercise or defend legal claims; to verify the existence overriding grounds following the exercise of your right of objection. We can continue to use your personal data following a request for restriction, where: we have your consent; to establish, exercise or defend legal claims; or to protect the rights of another natural or legal person.
• Portability. You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it 'ported' directly to another data controller, but only where the processing is based on your consent or on the performance of a contract with you, and the processing is carried out by automated means.
• Right to object to processing justified on legitimate interest grounds. Where we are relying upon legitimate interest to process personal data (see Section 3), then you have the right to object to that processing. If you object, we must stop that processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defense of legal claims.
• Right to object to processing for marketing purposes. Where we process personal data for direct marketing purposes, then you have the right to object to that processing at any time.

 

You also have the right to lodge a complaint with a supervisory authority if you consider that the processing of your personal data infringes applicable law. In France, the supervisory authority for the protection of personal data is the CNIL, 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07 .

 

7. Contact and complaints

 

For further information regarding your rights, how to exercise any of your rights, or if you have any complaints or questions regarding the processing of your personal data, please contact our Data Protection Officer : dpofr@pierre-fabre.com

 

 

8. Changes to this Notice

 

We may occasionally change this Privacy Notice, for example, to comply with new requirements imposed by the applicable laws, technical requirements or good commercial practices. We will notify you in case of material changes.

 

 

June 2022