Privacy policy

Data policy

Smeraldina Corporation fully understands the importance of privacy and the protection of personal data in the digital era and is committed to ensure an adequate level of data protection for all persons with whom Smeraldina Corporation has dealings. This includes, notably:

  • Users of our services, including websites and apps users;
  • representatives of our contractors and business partners;
  • job applicants.

What you will find in this document

This Global Privacy & Data Protection Policy (“Policy”) describes Smeraldina Corporation’s global practices to ensure an adequate protection of personal data, i.e. any information relating to an identified or identifiable natural person, for all data processing carried out in the framework of its business and activities (“Personal Data”).

The objective of this Policy is to help you understand:
INFORMATION WE COLLECT FROM YOU: what information Smeraldina Corporation collects and processes about you.
THE PURPOSES: for what reasons and purposes Smeraldina Corporation processes your Personal Data.
ON WHAT GROUND: on what basis does Smeraldina Corporation process your Personal Data.
WHERE FROM: from what sources does Smeraldina Corporation collect your Personal Data.
WHO: who are the authorized parties that Smeraldina Corporation may disclose your Personal Data to.
WHERE: where Smeraldina Corporation and its authorized parties may process your Personal Data.
HOW SECURE: what Smeraldina Corporation does to protect your Personal Data.
HOW LONG: Smeraldina Corporation’s approach to defining the term of retention of your Personal Data.
YOUR RIGHTS: what your rights are and how you can exercise them.
HOW TO CONTACT US: where and how you can reach us if you wish to exercise your rights or if you have a question.

What processing activities does this Policy cover?

This Policy is intended to apply to all processing activities Smeraldina Corporation conducts towards the persons it deals with in its professional business activities.

Specific privacy and data protection information notices (“Privacy Notice”) and/or consent forms will, if necessary, be communicated to you regarding specific situations where Smeraldina Corporation may process your Personal Data. These Privacy Notices shall describe in more detail how your Personal Data will be processed in relation with the processing in question. If the legislation of your country so requires, this Policy and/or Privacy Notices may be supplemented by local mandatory provisions, as the case may be.

Validity and evolution of this Policy

This Policy may be modified by Smeraldina Corporation, from time to time, in particular to adapt its terms to evolutions or changes of applicable legislations and/or to Smeraldina Corporation’s practices. Changes will be available on this page. We invite you to check this Policy periodically.

Information we collect from you: Information about you or that you provide to us

Smeraldina Corporation collects, or you may provide to us, several types of information from and about users of our Website, including information:

  • by which you may be personally identified, such as name, postal address, e-mail address, telephone number, and other identifying information;
  • that is about you but individually does not directly identify you, such as date of birth;
  • about your internet connection, the equipment you use to access our Website and usage details, such as Internet Protocol (IP) address;
  • about your education, employment history and related information (references) as well as any other information provided during an application (for spontaneous candidacy).

We collect this information:

  • directly from you when you provide it to us (for example through a job application, a trade show or a registration process);
  • automatically as you navigate through the site;
  • from third parties, for example, our business partners.

We also may use online technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking), which may include the use of cookies (data files placed on the hard drive of your computer that may be necessary for you to access our website), web beacons (electronic files that allow Smeraldina Corporation to collect aggregated information on users visiting our Website).

In some regions, countries, or U.S. states (such as California), you may have the right to opt out of such tracking. Please see the sections below, “Your Rights” and “Contact Us,” if you wish to exercise such rights.

The purposes: Smeraldina Corporation will always collect your Personal Data for explicit and legitimate purposes

Smeraldina Corporation collects your Personal Data for the following purposes:

  • to carry out our business operations; carry out marketing and sales; respond to your requests; to keep track of our interactions and meetings, such as when you contact us for information and support;
  • to comply with legal or regulatory obligations that apply to Smeraldina Corporation; monitor safety; manage adverse events; carry out prevention and investigatory activities; carry out administrative formalities, registration, declarations or audits;
  • to provide you access to online services, application and platforms; manage your online accounts;
  • to allow us to identify or authenticate you; provide or verify your credentials including via passwords, password hints, security information and questions;
  • to improve and develop our products and services; identify usage trends and develop new products and services; understand how you and your device interacts with our services; track and respond to safety concerns; determine the effectiveness of our promotional campaigns, conduct surveys;
  • to personalize your experience when using our services; ensure that our services are presented in the way that best suits you; understand your professional and personal interests in our content, products and services or other content and adapt our content to your needs and preferences; present you products and offers tailored to you;
  • to allow us to communicate with you; respond to your requests or inquiries; provide support for products and services; provide you with important information, administrative information, required notices, and promotional materials; send you news and information about our products, our services, our brands, our operations;
  • to respond to legal requests from administrative or judicial authorities, in accordance with applicable laws; comply with a subpoena, required registration, or legal process;
  • to protect our rights and interests; protect the health, safety, and security of Smeraldina Corporation personnel and premises; carry out internal audits, asset management, system and other business controls; manage business administration (finance and accounting, fraud monitoring and prevention); maintain the security of our services and operations; protect our rights, privacy, safety or property, to allow us to pursue available remedies or limit the damages that we may incur as necessary; to protect ourselves against possible fraudulent actions.

On what ground? Smeraldina Corporation will always process your Personal Data lawfully

Depending on the data processing at stake, Smeraldina Corporation will generally process your Personal Data on either one of the following legal basis:

  • your prior consent: where you have clearly expressed your approval of Smeraldina Corporation’s processing of your Personal Data. In practice, this will generally mean that Smeraldina Corporation will ask you to sign a document, or to fill-in an online “opt-in” form or to follow any relevant procedure to allow you to be fully informed and then either clearly accept or refuse the data processing envisaged.
  • a contractual relationship between you and Smeraldina Corporation: in such case, the processing of your Personal Data is generally necessary to the execution or the performance of the contract; this means that if you do not wish Smeraldina Corporation to process your Personal Data in that context, Smeraldina Corporation may or will be obliged to refuse to enter into such contract with you or will not be able to provide the products or services covered in this contract.
  • legal obligations applicable to Smeraldina Corporation’s activities; for instance, Smeraldina Corporation is required to implement pharmacovigilance procedures to monitor adverse effects of marketed products, which generally involves the collection and retention of Personal Data, or when required by law in connection with a court order, a criminal investigation or to protect security, people and other rights or interests.
  • the “legitimate interest” of Smeraldina Corporation in the sense of applicable data protection law. In such a case, Smeraldina Corporation shall consider your fundamental rights and interests in determining whether the processing is legitimate and lawful.
  • Smeraldina Corporation may, on a case-by-case basis, rely on other legal grounds, such as the protection of your vital interests, in accordance with applicable data protection law, as set forth in the applicable Privacy Notice.

Where does the Personal Data come from? Smeraldina Corporation will always collect Personal Data from trusted sources

Smeraldina Corporation may collect your Personal Data from different sources:

  • Data that you communicate to us through various media, through registrations, direct and indirect interactions with Smeraldina Corporation. For example, data you provide submitted an online application, to send us a request for information, etc.
  • Data that we collect automatically, for instance when following your interactions with our websites, platforms, applications and services through certain technologies, such as cookies.
  • Data that we obtain legally from third parties, for example, when we may need to confirm contact or financial information. In such case, we generally receive such Personal Data from third-parties that are authorized to do so in the framework of their own privacy and data protection policies or in accordance with the law. As applicable, we will inform you in the Privacy Notice of the identity of those third-parties and will invite you to refer to their privacy and data protection policies to inquire on the origin of such Personal Data and the condition of their collection.

About children Personal Data

Our Websites is not intended for children under 15 years of age (as per European law). We do not knowingly collect personal information from children under 15 through our Website. If you are under 15, do not use or provide any information on this Website.

If a parent or guardian becomes aware that his or her child has provided us with personal information, he or she should contact us as described in the “How to Contact Us” section below. We will take steps to delete such information from our database in accordance with applicable legal requirements.

Who has access to Personal Data: Smeraldina Corporation will share your Personal Data only with authorized parties

For the purposes described above, Smeraldina Corporation may need to share your Personal Data with the following authorized third-parties:

  • selected suppliers, service providers or vendors acting upon our instructions for website hosting, data analysis, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing, etc.;
  • legal or administrative authorities, as required by applicable laws including laws outside your country of residence;

Smeraldina Corporation may need to share your Personal Data with other third-parties, in which case you will be duly informed through the applicable Privacy Notice.

In any case, Smeraldina Corporation will require that such third-parties:

  • undertake to comply with data protection laws and the principles of this Policy;
  • will only process the Personal Data for the purposes described in this Policy;
  • implement appropriate technical and organizational security measures designed to protect the integrity and confidentiality of your Personal Data.

California Shine the Light

California's "Shine the Light" law, Civil Code section 1798.83, allows California residents to opt-out of disclosures of their personal information to third parties for third parties' direct marketing purposes. We will honor California residents’ opt-out requests and will not disclose their personal information to third parties for the third parties’ direct marketing purposes. California residents can exercise their opt-out rights in this regard at no cost contacting us as described in the “How to Contact Us” section below.

Where Personal Data may be transferred: Smeraldina Corporation will ensure that transfers of your Personal Data outside EU are safeguarded

Smeraldina Corporation is a multinational organization with affiliates, partners and subcontractors located in many countries around the world. For that reason, Smeraldina Corporation may need to transfer (via access, visualization, storage..) your Personal Data in other jurisdictions, including from the European Economic Area to outside the European Economic Area, in countries which may not be regarded as providing the same level of protection as the jurisdiction you are based in.

Safeguards for international transfers of Personal Data: In cases where Smeraldina Corporation needs to transfer Personal Data outside the European Union, it shall ensure that adequate safeguards, as required under applicable data protection legislation, will be implemented (including, notably, the European Commission’s Standard Contractual Clauses, as applicable).

How secure: Smeraldina Corporation will implement security measures to protect your Personal Data

We have implemented a variety of technological and organizational procedures and measures to ensure the integrity and confidentiality of your Personal Data from unauthorized access, use and disclosure. These measures shall take into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons.

For instance, we store your Personal Data on servers that have various types of technical and physical access controls, which may include, for instance, if appropriate, encryption. We may also aggregate, pseudonymize or anonymize Personal Data to ensure that no personally identifiable information is communicated to third parties.

How long: we will retain your Personal Data for no longer than necessary

Smeraldina Corporation will retain your Personal Data only for the period necessary to fulfill the purposes outlined in this Policy.

As an exception, Smeraldina Corporation may be required to retain your Personal Data for longer periods as required or permitted by law, or as necessary to protect its rights and interests. In such a case, you will be informed of the intended retention period in the applicable Privacy Notice.

Your rights: Smeraldina Corporation will ensure that you can exercise your rights pertaining to your Personal Data

You can exercise your rights as provided by data protection laws.

To that end, Smeraldina Corporation informs you that you may, where required by applicable law and subject to limitations which may apply in consideration of exceptions or legal requirements, be entitled:

  • to have access upon simple request to your Personal Data – in which case you may receive a copy of such data (if requested), unless such data is made directly available to you, for instance within your personal account;
  • to obtain a rectification of your Personal Data should your Personal Data be inaccurate, incomplete or obsolete;
  • to obtain the deletion of your Personal Data in the situations set forth by applicable data protection law (‘right to be forgotten’);
  • to withdraw your consent to the data processing without affecting the lawfulness of processing, where your Personal Data has been collected and processed on the basis of your consent;
  • to object to the processing of your Personal Data, where your Personal Data has been collected and processed on the basis of legitimate interests of Smeraldina Corporation, in which case you will need to justify your request by explaining to us your particular situation;
  • to request a limitation of the data processing in the situations set forth by applicable law;
  • if you would like to exercise any of these rights, please contact us as described in the “How to Contact Us” section below and we will take necessary steps to respond as soon as possible.

You may also file a complaint before a competent data protection authority regarding the processing of your Personal Data. While we suggest that you contact us beforehand, if you wish to exercise this right, you should contact directly the competent data protection authority.

Updates to our privacy policy

Without prejudice to your rights under applicable law, Smeraldina Corporation reserves the right to amend this Policy without prior notice to reflect technological advancements, legal and regulatory changes and good business practices. If Smeraldina Corporation changes its privacy practices, an updated version of this Policy will reflect those changes and we will notify you of such changes by updating the effective date at the top of this Policy.

How to contact us

You can send any request pertaining to Smeraldina Corporation’s use of your Personal Data submitting a form from this link: an e-mail to

Last update: 21/04/2023