PRIVACY POLICY

WHAT PERSONAL DATA DO WE COLLECT FROM YOU AND HOW DO WE USE IT?

How Do We Collect Or Receive Your Personal Data?

We might collect or receive personal data from you via our websites, forms, apps, devices, L’Oréal products or brand pages on social media, through your direct interactions with your account managers or customer care teams, or otherwise. Sometimes you give this to us directly (e.g. when you create an account, when you contact us, when you purchase from our websites/apps or in our stores), sometimes we collect it (e.g. using cookies to understand how you use our websites) or sometimes we receive your personal data from other third parties, including other L’Oréal Group entities.

When we collect personal data, we will indicate which types of personal data are mandatory via asterisks. Some of the personal data we request from you are either necessary for us to:

• Perform our contract with you (e.g. to create your account, or deliver the goods you have purchased on our websites/apps);
• Provide you with a service you have asked for ;
• Comply with legal requirements (e.g. invoicing).

If you do not provide the personal data marked with an asterisk, this may affect the goods and services that we can provide.

In the table below, we explain:

1. During which interactions you may provide and we may collect your data: This column explains what activity or scenario you are involved in when we use or collect your personal data. For example, whether you are making a purchase, signing up to a newsletter, or browsing a website.
2. What personal data we may receive from you directly or resulting from your interactions with us: This column explains what types of personal data we may collect when you take part in a particular activity.
3. How and why we use your personal data: This column explains what we do with your personal data, and the purposes for collecting and using it.
4. What is our legal basis for using your personal data: Whenever we use your personal data, we will have a legal basis to do this. For example, you have asked us to provide a service, you have given us your consent, or we have a legitimate interest in using your personal data.

The legal basis for the processing of your personal data can be:

• Your consent.
• The performance of a contract – This applies where you provide us with your personal data in order for us to provide you with a service (e.g. you ask us to create a customer account for you or you wish to purchase a product and we can manage the associated logistics).
• Our legitimate interest, which can be:
  • Improvement of our products and services: more specifically, our business interests to help us better understand your needs and expectations and therefore improve our services, websites/apps, devices, products and brands for our customers’ benefit.
  • Fraud prevention: to ensure payment is complete and free from fraud and misappropriation.
  • Securing our tools: to keep tools used by you (our websites/apps, devices) safe and secure and to ensure they are working properly and are continually improving.
• Legal grounds – This is where we need to keep your personal data for legal reasons (e.g. when you make a purchase we need to keep your transaction information to comply with our tax and financial reporting obligations).

Information Overview On Your Interactions With Us And Their Consequences On Your Personal Data

The legal basis for the processing of your personal data can be:

Automated Decision Making

For purposes of securing transactions placed through our websites/apps/devices against fraud and misappropriation, we use third party provider’s solution(s).The method of fraud detection is based on, for example, simple comparisons, association, clustering, prediction and outlier detections using intelligent agents, data fusion techniques and various data mining techniques.This fraud detection process may be completely automated or may involve human intervention where a person takes the final decision. In any case, we take all reasonable precautions and safeguards to limit access to your data.

As a result of automatic fraud detection, you may (i) experience delay in the processing of your order/request whilst your transaction is being reviewed by us; and (ii) be limited or excluded from the benefit of a service if a risk of fraud is identified. You have the right to access information on which we base our decision. Please see “Your Rights and Choices” section below.

Profiling

When we send or display personalised communications or content, we may use some techniques qualified as “profiling” (i.e. any form of automated processing of personal data consisting of using those data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s personal preferences, interests, economic situation, behaviour, location, health, reliability, or movements). This means that we may collect personal data about you in the different scenarios mentioned in the table above. We centralize this data and analyse it to evaluate and predict your personal preferences and/or interests.

Based on our analysis, we send or display communications and/or content tailored to your interests/needs.

You have the right to object to the use of your data for “profiling” in certain circumstances. Please see “Your Rights and Choices” section below.

Who May Access Your Personal Data?

We may share your personal data within L’Oréal Group to comply with our legal obligations, to prevent fraud and/or to secure our tools, to improve our products and services, or after having obtained your consent to do so.

Depending on the purposes for which they were collected, and only on a need-to-know basis, some of your personal data may be accessed by L’Oréal Group entities worldwide, where possible in a pseudonimized way (not allowing direct identification), and where necessary to provide you with requested services.

We may also share your personal data in a pseudonimized way (not allowing direct identification) with L’Oréal Research & Innovation scientists, including those located outside of your country, for research and innovation purposes.

Where permitted, we may also share some of your personal data including those collected through cookies between our brands to harmonize and update the information you share with us, to perform statistics based on your characteristics and to tailor our communications.

Please visit the L’Oréal group website, for further details on the L’Oréal Group, its brands and its locations.

We may share your personal data for marketing purposes with third party or entities of the L’Oréal Group.

We only share your personal data with third parties for direct marketing purposes with your consent. In this context, your data is processed by such third party, acting as a data controller, and its own terms and conditions and privacy notice apply. You should carefully check their documentation before consenting to the disclosure of your information to that third party.

Your personal data may also be processed on our behalf by our trusted third party providers.

We rely on trusted third parties to perform a range of business operations on our behalf. We only provide them with the information they need to perform the service, and we require that they do not use your personal data for any other purpose. We always use our best efforts to ensure that all third parties we work with keep your personal data secure. For instance, we may entrust services that require the processing of your personal data to:

• Third parties that assist and help us in providing digital and e-commerce services such as social listening, store locator, loyalty programs, identity management, reviewing social media and public profiles, ratings and reviews, CRM, web analytics and search engine, user generated content curation tools;
• Advertising, marketing, digital and social media agencies to help us to deliver advertising, marketing, and campaigns, to analyse their effectiveness, and to manage your contact and questions and our relationships;
• Third parties required to deliver a product to you e.g. postal/delivery services;
• Third parties that assist and help us in providing IT services, such as platform providers, hosting services, maintenance and support on our databases as well as on our software and applications that may contain data about you (such services could sometimes imply access to your data to perform the required tasks);
• Payment service providers and credit reference agencies for the purpose of assessing your credit score and verifying your details where this is a condition of entering into a contract with you;
• Third parties that assist us for customer care and cosmetovigilance purposes;
• Third parties that assist us in providing training, seminars, and events, such as training providers travel agencies, and event management companies; and/or
• Third parties that provide us with consulting services in the field of market research and analytics, collect feedback and conduct market surveys on our products, services and otherwise for customer relationship management purposes.

The legal basis for this sharing is our legitimate interests – (i) to improve our products and services; (ii) better engage with you; (iii) prevent fraud; (iv) secure our tools and design new features; (v) use appropriate suppliers; and (vi) ensuring your values align with that of L’Oréal’s.

We may also disclose your personal data to third parties:

• In the event that we sell any business or assets, in which case we may disclose your personal data to the prospective buyer of such business or assets. If L’Oréal or a part of its assets is acquired by a third party, personal data held by it about its customers relating to those assets is one of the transferred assets. Where appropriate, in such case, the buyer acting as the new data controller processes your data and its privacy policy governs the processing of your personal data.
• If we are under a duty to disclose or share your personal data in order to comply with a legal obligation, or in order to enforce or apply our terms of use/sales or other terms and conditions you have agreed to; or to protect the rights, property, or safety of L’Oréal, our customers, or employees.
• If we have your consent to do so.
• Or if we are permitted to do so by law.

We may disclose your personal data to our partners:

• In the event the service you subscribe to was co-created by L’Oréal and a partner (for example, a co-branded app). In such case, L’Oréal and the partner process your personal data each for their own purposes and as such your data is processed: u;
  • By L’Oréal in accordance with this Privacy Policy;
  • By the partner acting also as a data controller under its own terms and conditions and in accordance with its own privacy policy.
• In the event you agreed to receive marketing and commercial communications from a L’Oréal partner through a dedicated opt-in (for instance, through an App branded by L’Oréal and made available to its partners). In such case, your data is processed by the partner acting as a data controller under its own terms and conditions, and in accordance with its privacy policy.
• We may publish on our supports content from social networks. In the event you consult content from social networks on our website/apps, a cookie from such social network may be stored on your device. We invite you to read the Cookie Policy of these social networks for more information;
• When we use Google advertising services on our websites/apps, Google will access and use your personal data. If you wish to learn more on how Google uses your personal data in this context, please consult their Google Privacy & Terms, which govern these services and data processing.

Information that Facebook collects and shares with us

All Facebook features and services available on our website/app are governed by the Facebook Data Policy, in which you can get more info about your privacy rights and settings options.

By using this website/app, you may:

• Sign-up with your Facebook login. If you do so, you consent to share some of your public profile information with us;
• Use the Facebook social plug-ins, such as “like” or “share” our content on the Facebook platform;
• Accept cookies from this website/app (also identified as “Facebook Pixel”) that will help us understand your activities, including information about your device, how you use our services, the purchase you make and the ads you see, whether or not you have a Facebook account or are logged into Facebook.

When you are using those Facebook features, we collect data that help us to:

• Show you adds you might be interested in on Facebook (or Instagram, Messenger or any other Facebook services);
• Measure and analyze the effectiveness of our website/app and ads

We may also use the personal data you gave us on this website/app (such as your name and surname, email, address, gender and phone number) to identify you in Facebook (or Instagram, Messenger or any other Facebook services) in order to show you ads that are even more relevant for you. While doing this, Facebook will not share your personal data and will delete the data promptly after the match process is complete.

We do not offer or sell your personal data.

Where Do We Store Your Personal Data

The data that we collect from you may be transferred to, accessed from, and stored at a destination outside the European Economic Area ("EEA"). It may also be processed by staff members operating outside the EEA who work for us or for one of our service providers.

L’Oréal transfers personal data outside of the EEA only in a secure and lawful way. As some countries may not have laws governing the use and transfer of personal data, we take steps to make sure that third parties adhere to the commitments set out in this Policy. These steps may include reviewing third parties’ privacy and security standards and/or entering into appropriate contracts (based on the template adopted by the EU Commission).

For further information, please contact us as per the “Contact” section below.

How Long Do We Keep Your Personal Data

We only keep your personal data for as long as we need it for the purpose for which we hold your personal data, to meet your needs, or to comply with our legal obligations. To determine the data retention period of your data, we use the following criteria:

• Where you purchase products and services, we keep your personal data for the duration of our contractual relationship;
• Where you participate in a promotional offer, we keep your personal data for the duration of the promotional offer;
• Where you contact us for an enquiry, we keep your personal data for the duration needed for the processing of your enquiry;
• Where you create an account, we keep your personal data until you require us to delete it or after a period of inactivity (no active interaction with brands) defined in accordance with local regulations and guidance;
• Where you have consented to direct marketing, we keep your personal data until you unsubscribe or require us to delete it or after a period of inactivity (no active interaction with brands) defined in accordance with local regulations and guidance;
• Where cookies are placed on your computer, we keep them for as long as necessary to achieve their purposes (e.g. for the duration of a session for shopping cart cookies or session ID cookies) and for a period defined in accordance with local regulations and guidance.

We may retain some personal data to comply with our legal or regulatory obligations, as well as to allow us to manage our rights (for example to assert our claims in courts) or for statistical or historical purposes.

When we no longer need to use your personal data, it is removed from our systems and records or anonymised so that you can no longer be identified from it.

Is Your Personal Data Secure?

We are committed to keeping your personal data secure, and taking all reasonable precautions to do so. We contractually require that trusted third parties who handle your personal data for us do the same.

We always do our best to protect your personal data and once we have received your personal data, we use strict procedures and security features to try to prevent unauthorised access. As the transmission of information via the internet is not completely secure, we cannot guarantee the security of your data transmitted to our site. As such, any transmission is at your own risk.

Links to Third Party Sites and Social Login

Our websites/apps may from time to time contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we are not responsible or liable for these policies. Please check these policies before you submit any personal data to these websites/apps.

We may also offer you the opportunity to use your social media login. If you do so, please be aware that you share your profile information with us depending on your social media platform settings. Please visit the relevant social media platform and review its privacy policy to understand how your personal data is shared and used in this context.

Social Media and User Generated Content

Some of our websites/apps allow users to submit their own content. Please remember that any content submitted to one of our social media platforms can be viewed by the public, so you should be cautious about providing certain personal data e.g. financial information or address details. We are not responsible for any actions taken by other individuals if you post personal data on one of our social media platforms and we recommend that you do not share such information.