1. Who we are
 

This Privacy & Cookie Policy explains how Professional Derma SA processes personal data in connection with the Jalupro website and related online services covered by this Policy.

Data Controller:

• Professional Derma SA

• Riva A. Caccia 1/d, 6900 Lugano, Switzerland

• Email for privacy matters: privacy@pderma.com

• Website: www.jalupro.com

Professional Derma SA processes personal data in accordance with the Swiss Federal Act on Data Protection (FADP). Where the EU General Data Protection Regulation (GDPR) applies to a particular processing activity, the relevant GDPR requirements are also observed.

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2. Scope of this Policy

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This Policy covers personal data processed through www.jalupro.com, including information submitted through the contact form, technical data generated when the website is used, cookies and similar technologies, and the Jalupro product-authentication service accessible through v.jalupro.com.

The website is intended for an international audience. Information concerning Jalupro products may vary according to the laws and regulatory requirements of each country. Information on this website is not intended to replace advice from a physician or other qualified healthcare professional.

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3. Personal data we process

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3.1 Information you provide to us

When you contact us through the website, we may process the information you provide, such as your first name, last name, email address, telephone number and the content of your message, together with any other information you voluntarily include.

We ask users not to include unnecessary health information or other sensitive personal data in free-text messages.

3.2 Technical and website usage data

When you visit the website, certain technical information may be processed automatically by the website platform and related service providers. Depending on the configuration and your cookie choices, this may include IP address, device and browser information, date and time of access, pages or functions used, security information, cookie identifiers and similar technical data.

3.3 Jalupro Smart Label / product authentication

Jalupro products may include a Smart Label containing a QR code and/or PIN. The authentication service is available through v.jalupro.com and is provided using the CODIKETT technology operated by Securikett. When the service is used, information relating to the product identifier and verification event may be processed, including the QR/UID or PIN, date and time of verification, frequency of scans and technical information associated with the verification. The service may derive an approximate geographic location, such as country or city, from technical network information; Professional Derma does not use this service to obtain precise GPS location.

The Smart Label service is used for product authentication, anti-counterfeiting, detection of anomalous verification patterns and protection of the distribution chain.

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4. Why we process personal data

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We process personal data, as applicable, to:

• respond to enquiries and communicate with website visitors;

• manage requests concerning Jalupro products, Professional Derma or its distribution network;

• operate, maintain, secure and improve the website and its functionality;

• prevent misuse, fraud and security incidents;

• authenticate Jalupro products and detect suspected counterfeit products or anomalous scanning patterns;

• comply with legal and regulatory obligations and establish, exercise or defend legal claims;

• perform analytics or other optional website functions where enabled and permitted by applicable law and the user's cookie preferences.

Where the GDPR applies, processing is carried out on an appropriate legal basis depending on the activity, which may include steps taken at your request, legitimate interests, compliance with legal obligations or consent where consent is required.

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5. Recipients and service providers

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Personal data may be disclosed to service providers only to the extent necessary for the purposes described above. Relevant categories currently include:

• Wix.com and its sub-processors, for website hosting, operation, security and related platform services;

• service providers supporting the development and technical maintenance of the website, where they are authorised to access relevant data;

• Securikett / CODIKETT, for the Smart Label and product-authentication service;

• IT, communications and professional service providers where required for the operation, security or support of the relevant service;

• public authorities, courts or other recipients where disclosure is required by law or necessary to protect legal rights.

Service providers acting on our behalf are required to process personal data in accordance with applicable contractual and data-protection requirements.

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6. International data transfers

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Professional Derma SA is established in Switzerland and uses international technology providers. As a result, personal data may be processed in Switzerland, the European Economic Area, Israel, the United States and other countries in which relevant service providers or their approved sub-processors operate.

Where personal data are transferred to a country that does not provide an adequate level of data protection under the applicable law, Professional Derma and/or the relevant service provider rely on appropriate safeguards, such as recognised standard contractual clauses or other legally permitted transfer mechanisms, unless a statutory exception applies.

Wix states that data of website visitors may be processed by Wix.com Ltd. in Israel and by Wix entities and sub-processors in other jurisdictions.

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7. Data retention

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We retain personal data only for as long as necessary for the purposes for which they were collected, taking into account legal, contractual and operational requirements and the need to establish, exercise or defend legal claims.

As an internal retention rule, enquiries submitted through the website that do not lead to an ongoing business relationship are generally retained for up to two years from the last relevant contact, unless a longer period is required for a specific reason. Where an enquiry develops into a business, contractual or other relationship, the data are retained according to the retention rules applicable to that relationship.

Technical data, cookies and Smart Label verification information may follow different retention periods depending on the service, security requirements and configuration. Data are deleted or anonymised when they are no longer required, subject to applicable legal or technical retention requirements.

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8. Data security

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Professional Derma applies technical and organisational measures appropriate to the nature of the processing and the associated risks. These include access restrictions based on operational roles, use of secure cloud services and appropriate controls over service providers. No internet-based system can, however, be guaranteed to be completely secure.

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9. Your rights

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Depending on the law applicable to you and the circumstances of the processing, you may have rights in relation to your personal data, including the right to:

• ask whether we process personal data concerning you and request access to such data;

• request correction of inaccurate personal data;

• request deletion or destruction of personal data where the applicable requirements are met;

• object to or request restriction of certain processing where provided by applicable law;

• withdraw consent at any time for processing based on consent, without affecting processing carried out before withdrawal;

• exercise any additional rights granted by applicable data-protection law.

Requests can be sent to privacy@pderma.com. We may request information necessary to verify your identity before disclosing or modifying personal data.

You may also contact the competent data-protection supervisory authority. In Switzerland, the supervisory authority is the Federal Data Protection and Information Commissioner (FDPIC).

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10. Cookies and similar technologies

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The website uses cookies and similar technologies. Some are necessary for the website to operate securely and correctly. Other technologies may be used, depending on the website configuration, for preferences, analytics or other optional functions.

Where required by applicable law, non-essential cookies or similar technologies are activated only in accordance with the choices made through the website's cookie banner or preference centre. Visitors can accept or reject non-essential categories and can change their preferences through the cookie settings made available on the website.

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Cookies and similar technologies may fall into the following categories:

• Essential: required for security, basic functionality and operation of the website;

• Functional / preferences: used to remember choices or enable optional website functions;

• Analytics: used, where enabled, to understand website usage and performance;

• Marketing / advertising: used only if such technologies are actually enabled on the website and subject to the consent or other requirements applicable to them.
   

The exact cookies and technologies used may change when the website configuration or third-party integrations change. Where available, the current cookie banner or preference centre provides information about the categories in use and allows visitors to manage their choices.

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11. Third-party links and services

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The website may contain links to third-party websites or services. Professional Derma is not responsible for the privacy practices of independent third parties. Users should review the privacy information provided by the relevant third party when leaving the Jalupro website.

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12. Changes to this Policy

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We may update this Privacy & Cookie Policy to reflect changes in our services, technologies, legal requirements or data-processing practices. The current version will be published on this page together with the date of the latest update.

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13. Contact

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For questions about this Policy or the processing of your personal data, please contact:

Professional Derma SA
Riva A. Caccia 1/d
6900 Lugano, Switzerland
privacy@pderma.com