1. Introduction

Welcome! At Sphyg and our affiliated companies in the EMEA region (referred to as “Sphyg,” “we,” or “us”), we value your privacy and are committed to protecting it. This Privacy Policy explains how we handle your personal data when you purchase our products (“Products”) or engage with us through our websites, apps, or other services (“Services”). Take a moment to read this policy—it’s designed to keep you informed about how we treat your personal data and your rights regarding it.

2. Personal Data We Collect

Your privacy matters to us, and we’re transparent about what personal data we collect and why. “Personal Data” refers to any information that can identify you. Here’s a breakdown:

General Personal Data:

• Your Contact Details: Information like your name, address, email, and phone number, plus any requests, complaints, or feedback you provide.
• Automatically Collected Information: Details like your IP address, browser type, and usage habits, often collected via cookies or similar technologies. (See our Cookie Policy for details.)
• Online Services Usage: Data about the pages you visit, products you like, or items left in your shopping cart.
• Online Purchases: Details such as purchase date, product, payment method, and delivery information.
• Your Reviews: Opinions or feedback shared on our websites or social media platforms.
• Communication Data: Information from email, phone, or social media conversations.
• Other Sources: Data from public databases or third-party aggregators.
• Educational Data: Records of participation in training courses, including certifications and activity logs.
• Traffic Data: Information like IP addresses collected via our guest Wi-Fi.

Sensitive Data:
If you use Sphyg healthcare-related products or services, you might share health data with us. We only process this information with your explicit consent and solely for purposes outlined in this policy. You’re free to withdraw consent anytime.

3. Why We Use Your Personal Data

Here’s why we collect and use your data:

• To Fulfill Our Agreement With You: Managing purchases, handling requests, and delivering services.
• For Legitimate Business Interests: Enhancing our products, analyzing usage, tailoring advertising, and ensuring a great user experience.
• Based on Your Consent: Sending marketing communications or processing sensitive data. You can revoke consent anytime.
• To Comply With Legal Obligations: Maintaining records, meeting regulatory requirements, or supporting investigations.

4. Sharing Your Data

We may share your personal data, but only when necessary:

• Within the Sphyg Group: To provide a seamless experience across our global network.
• With Service Providers: Trusted vendors who help us operate efficiently (e.g., IT support, payment processors).
• With Partners: When co-sponsoring services or events, always with safeguards in place.
• For Legal Reasons: To comply with laws, court orders, or protect our rights.
• In Corporate Transactions: During mergers or asset sales.
• With Your Consent: Only when you’ve authorized us to do so.

5. International Transfers

Your data may be processed outside your country, such as in Japan. When this happens, we ensure your data is protected according to applicable laws through measures like contracts and safeguards.

6. Keeping Your Data Secure

Your trust is our priority. We use technical, physical, and organizational measures to secure your data against unauthorized access, misuse, or loss. Access is limited to those who genuinely need it.

7. How Long We Keep Your Data

We only keep your data for as long as it’s needed to fulfill the purposes outlined here or as required by law. After that, we securely delete or anonymize it.

8. Your Rights

You have control over your data! You can:

• Access, correct, or delete your data.
• Restrict or object to processing.
• Request a copy of your data in a portable format.

To exercise these rights, email us at [email protected]. If you’ve given consent for data use, you can withdraw it anytime without affecting previous processing.

9. Third-Party Websites

Our site might link to other websites. Please review their privacy policies, as we’re not responsible for how they handle your data.

10. Updates to This Policy

We may update this Privacy Policy occasionally. If there’s a significant change, we’ll notify you in advance.

11. Contact Us

Questions? Concerns? Contact us anytime at [email protected]. We’re here to help!

Issue Date: September 2019