Legal Terms for Saigu Cosmetics’ consumer panel

1. ORGANIZER AND MANAGER OF THE PANEL

The consumer panel “Comité de sabías” (hereinafter, the “Panel”) is organized by Saigu Cosmetics, S.L. (hereinafter, “Saigu”), with registered office at Calle Jorge Juan, 9, 46004 Valencia, Tax Identification Code B67263533, registered with the Barcelona Companies Registry.

Any questions, issues, or communication related to the Panel can be sent to info@saigucosmetics.com.

2. PURPOSE AND AIM OF THE PANEL

The purpose of the Panel is to include real Saigu consumers in the evaluation process prior to launching new products, in order to learn about their user experience, perception, preferences, and assessment.

In this first edition, the Panel will focus on launching the new stick shades of Melting Blush and Melting Bronzer.

The information gathered through the Panel will be used, in particular, for the following purposes:

Consumer research.
Product evaluation and improvement.
Identifying consumers’ needs and preferences.
Developing tools to help choose a shade.
Preparing the communication strategy and product launch.

As part of the Panel activities, Saigu may ask participants, when appropriate, to provide graphic materials, photos, videos, or testimonials related to their product experience. These may be used in Saigu marketing content, including social media, website, newsletter, advertising, and other owned or promotional channels, always in accordance with these legal terms and the relevant permissions detailed in clause 6.

Participation in the Panel is not commercial in nature and does not create any employment, commercial, or service-provision relationship between the participant and Saigu. It is a voluntary, unpaid collaboration, without prejudice to the free delivery of the products being tested.

3. PARTICIPATION REQUIREMENTS

Anyone who meets all of the following requirements may take part in the Panel:

Be over 18.
Be resident in Spain.
Be a customer at the Radiant level of Saigu’s Radiant loyalty club.
Be able to receive and try the product on the scheduled dates for the corresponding round.
Commit to using the product throughout the established testing period.
Commit to completing the follow-up and feedback forms linked to the Panel.

You don’t need professional makeup knowledge to take part.
Taking part in the Panel means fully accepting these legal terms, without exceptions or reservations. Signing up via the dedicated form implies the participant’s explicit acceptance.

Saigu reserves the right to verify compliance with the above requirements and to exclude from the Panel, at any time, any people who do not meet them or who have provided inaccurate or incomplete information during the registration process.

4. NUMBER OF PARTICIPANTS

For the first round of the Panel’s first edition, participation by 10 consumers is planned.

Saigu may later run new rounds within this same edition, adding new participants, if the research needs require it. In that case, the new participants will be duly informed of the applicable conditions, which may be these same legal terms or an updated version.

5. HOW THE PANEL WORKS AND ITS PHASES

In this first edition, the Panel will be carried out in the following phases:

Registration via a form provided by Saigu.
Selection of participants according to the criteria defined by Saigu in accordance with clause 3 above.
Free delivery to the selected participants of the products being tested.
A product-use period of approximately two weeks.
Completion by the participant of one or more follow-up and feedback forms.
When requested, the participant’s submission of testimonials, photos, videos, or other materials related to their product-use experience.

The specific start and end dates for each of the previous phases for the first round will be communicated by Saigu to the selected participants. The following schedule is provided as a guideline: registration from August 17, 2026 to August 20, 2026; selection announcement on August 21; product shipment starting August 24; use and testing period from August 24 to September 4; and closing of form and materials collection on September 7.

Follow-up and feedback forms may include questions about application, texture, ease of use, finish, wear time, shades, preferences, frequency of use, benefits, areas for improvement, and purchase intent, among other aspects related to the product-use experience.

Saigu reserves the right to change the schedule, increase or decrease the number of participants, and to suspend or cancel the Panel or any of its rounds at any time, where justified reasons make this necessary, informing the affected participants through the communication channels indicated in clause 7.

6. AUTHORIZATION TO USE CONTENT AND VISUAL MATERIALS

During the Panel, Saigu may ask participants to voluntarily provide testimonials, photos, videos, or other visual materials related to their product-use experience (the “Materials”).

When the Materials may be used publicly by Saigu or could make it possible to identify the participant, Saigu will request a specific authorization from the participant before using them, freely given, explicit, and informed, for use in Saigu’s marketing and communication content.

This authorization will be collected as part of the sign-up or participation process for the Panel itself, and will allow Saigu to use the Materials voluntarily provided by the participant on social media, the website, the newsletter, digital advertising, and other brand-owned or promotional communication channels, for the purpose of showcasing the products included in the Panel and participants’ experiences.

The authorization may specify, among other things, the territorial and time scope of the license, the specific distribution channels, and the possibility for the participant to withdraw that authorization at any time, without affecting the lawfulness of any use carried out before the withdrawal.

Providing Materials by the participant is voluntary and does not in any case mean they must give a positive review of the product, nor does it affect their continued participation in the Panel or their enjoyment of the products received.

If the participant does not grant the relevant authorization, the Materials provided may still be used internally by Saigu for the consumer research purposes described in clause 2, but they will not be used in publicly distributed content.

7. COMMUNICATION CHANNELS WITH PARTICIPANTS

The main communication channel between Saigu and participants will be email.

During this edition of the Panel, Saigu is expected to contact participants mainly for the following purposes:

Notify selection as a Panel participant.
Manage product shipping and provide test instructions.
Carry out follow-up during the usage period.
Send feedback forms.
Handle any potential issues related to participation in the Panel.
Request, when appropriate, materials or additional information related to the research.
The WhatsApp channel will only be used when the participant has given their explicit permission and has selected it as their preferred communication channel.
It is not planned to use phone calls as a regular communication channel with participants.

If you have any questions, queries, or issues related to the Panel, you can contact us at any time at the email address info@saigucosmetics.com.

8. PROCESSING OF PERSONAL DATA

8.1. Data controller

The data controller for participants’ personal data is Saigu Cosmetics, S.L., with registered office at calle Jorge Juan, 9, 46004 Valencia, Tax Identification Code number B67263533, registered with the Barcelona Commercial Registry, and contact email info@saigucosmetics.com.

8.2. Purpose and legal basis for processing

The personal data provided by participants will be processed for the purposes described in clause 2 (consumer research, product evaluation and improvement, identification of needs and preferences, development of tools to help choose a shade, and preparation of the communication and launch strategy), as well as for the Panel’s operational management (registration, selection, product shipment, follow-up, and incident management).

The legal basis for processing is the participant’s consent, given through their voluntary registration in the Panel and acceptance of these legal terms, and, where applicable, the performance of the accepted participation conditions.

8.3. Categories of data processed

The sign-up form and follow-up forms will not, under any circumstances, request health data, dermatological conditions, medical treatments, pregnancy, allergies, or other special categories of medical data.

Questions may be asked about cosmetic skin characteristics needed for the research, such as skin type, tone, or undertone, while avoiding requesting diagnoses or information of a medical nature in all cases.

8.4. Platforms used to collect and manage data

To manage the Panel, the following platforms will mainly be used:
Typeform, for sign-up, follow-up, and feedback forms.

Google Workspace, for internal management, organisation, and analysis of the information associated with the Panel.

Access to the data will be limited to members of the Saigu team who need to process this information to manage the Panel and analyse its results, in line with the principle of minimum access.

8.5. Data retention

Participants’ personal data will be kept for as long as necessary to run the Panel and to fulfil the purposes described and, afterwards, where applicable, for the statutory limitation periods for any legally enforceable liabilities.

8.6. Participants’ rights

Participants may exercise their rights of access, rectification, erasure, objection, restriction of processing, and data portability, as well as withdraw their consent at any time, by writing to Saigu Cosmetics, S.L., calle Jorge Juan, 9, 46004 Valencia, or by email to info@saigucosmetics.com, stating the right they wish to exercise and providing a copy of an identification document.

Participants may also file a complaint with the Spanish Data Protection Agency (www.aepd.es) if they believe the processing of their data does not comply with the applicable regulations.

9. PROVIDERS AND THIRD PARTIES WITH ACCESS TO DATA

Depending on the activity carried out at each stage of the Panel, the following providers or third parties may have access to certain participants’ personal data, in their capacity as data processors or, where applicable, as independent controllers when appropriate:

Typeform, as the provider of the platform used to collect registration information, monitoring, and feedback.
Google Workspace, as the environment used to internally manage and store the Panel’s information.
Saigu’s shipping company, solely with regard to the data needed to deliver the products to selected participants (name, postal address, and contact details).
Each of these providers will have access only to the data strictly necessary to provide the relevant service, and will be subject to the confidentiality and security obligations required by the applicable data protection regulations.
Saigu will not share participants’ personal data with third parties other than those indicated in this clause, unless required by law.

10. ACCEPTANCE AND AMENDMENT OF THE TERMS

Taking part in the Panel means full acceptance of these legal terms. A participant’s registration via the designated form will constitute an express statement of that acceptance.

Saigu reserves the right to modify the Panel’s conditions at any time, including these legal terms, as well as to suspend or cancel it early, provided there are justified reasons to do so. Any substantial change will be communicated to participants through the communication channels indicated in clause 7 before it takes effect.

A participant may withdraw from the Panel at any time by emailing info@saigucosmetics.com, without affecting the validity of any actions carried out prior to that notice.

11. APPLICABLE LAW

These legal terms are governed by Spanish law, in particular by Regulation (EU) 2016/679, the General Data Protection Regulation, Organic Law 3/2018 of 5 December on Personal Data Protection and the guarantee of digital rights, and any other Spanish and European Union regulations that may apply.

For any dispute arising from the interpretation or enforcement of these legal terms, the parties agree to submit to the Spanish Courts and Tribunals with jurisdiction under the applicable regulations, expressly waiving any other jurisdiction that may apply.