Schedule 1 (Supplier’s Privacy Notice)

Privacy Policy – Clarins Connect

This Privacy Policy was updated on 22/11/2016

1 - Introduction

Clarins is committed to protecting your privacy and to respect all relevant legal provisions.

This privacy policy allows you to better understand the principles of data protection applied by Clarins. We invite you to read it before submitting your personal data.

Clarins UK Ltd whose registered office is located 10 Cavendish Place, London W1G 9DN, United Kingdom and Clarins SA whose registered office is located 9 rue du Commandant Pilot, 92200 Neuilly-sur-Seine, France are joint data controllers for the website www.clarins.co.uk.

This Privacy Policy may be updated at any time by Clarins. The date of the most recent revision will appear on this page. We suggest that you refer back to it on a regular basis.

Please note that by using the website www.clarins.co.uk, you authorize Clarins to collect, record, organize, store, use and/or transfer your personal data according to this privacy policy.

2 - When does Clarins collect your information? 

We collect personal information from you when: 

• register with Clarins Connect at counter, spa and/or Beauty Bar;
• you are visiting one of our Spas;
• you are visiting one of our Beauty Bars;
• you are attending a Clarins Event including experiential event;
• you subscribe to our newsletters;
• you sign up  for one of our loyalty program;
• you participate in special operations, in particular games, competitions, product tests, customers surveys or market researches;
• you contact us, in particular when you submit a request or a complaint to our Customer Service or when you rate or review our products and/or services;
• you have given your consent to third parties to send us personal information about you.

3 - What information do Clarins collect about you?

We consider that all information that could identify you directly or indirectly are "personal information". We may mainly collect the following personal information:

• information about your identity, in particular your gender, last name, first names, address, telephone number, email addresses, date of birth or age;
• information about your payment method, in particular your credit card number and the expiration date;
• information about our commercial relation, in particular transaction numbers, history of your purchases, your request or your communications with our Customer Service, your preferences and interests or information about one of our loyalty program;
• information about your skin (beauty concern, skin type, skin sensitivity, etc.) subject to your prior approval, in particular when asking for a beauty prescription Clarins or a treatment Clarins in one of our Spa;
• technical information, in particular your IP address or information about how your device navigates through our website.

4 - Why are your personal information collected?

Personal information may be collected mainly for the following purposes:

• To provide the most accurate assessment of your skincare, make-up needs, to provide an informed pre and post sales service. This processing may be necessary for the performance of a contract to which you are party;
• Customer Relationship Management (CRM) (loyalty program, newsletters, promotions, product testing, surveys, etc.). This processing is made subject to your approval;
• Market analysis and timing (profiling on the basis of your purchasing behavior, preferences and interests, analyses while navigating through our website, statistics, reporting, etc.). This processing is made subject to your approval;
• When appropriate, prevention and fraud detection;
• Managing your request (complaints, right to access, rectify, oppose and remove, etc.); This processing is necessary to process your request.
• With customer consent, third party retailer opt-in information will be obtained and relevant information shared with approved third party retailer (email, first and last name).

5 – Does Clarins disclose your personal information?

We never share your personal information with other companies for marketing purposes unless prior consent is provided.

Consent may be given to share your personal information with an agreed third party retailer during your Clarins Connect consultation. If you receive a Clarins Connect Consultation and agree to hear from your home store* third party retailer then your personal information (first/last name, email address) is shared via a secure transfer to that agreed third party retailer. All transfers of customer data use methods that adhere to data protection laws.

Clarins is an international group that operates in many countries. The personal information we are collecting about you are intended to Clarins and are will be likely to be communicated to all the Clarins Group companies and to service providers chosen for their expertise and reliability and acting on our behalf and at our direction (IT providers, customer service, delivery, etc.).

We authorize these service providers to use your personal information only to the extent necessary to perform services on our behalf or to comply with legal requirements and we strive to ensure that your personal information are always protected.

These third parties may be located in or out the European Economic Area (EEA), including in countries that do not provide the same level of data protection as in your country of residence. In such a case, we will ensure either:

• to obtain your unambiguous consent to share your personal information with these third parties,
• to enter into appropriate data transfer agreements conforming to the Standard Model Clauses established by the European Commission,
• to comply with Binding Corporate Rules (BCR) approved by competent authorities.

Finally, we may also transmit your personal information to local authorities if required by law or as part of an investigation and in accordance with local regulations.

6 - How will Clarins protect the information about you?

Clarins takes appropriate technical and organizational measures, in relation to the nature of data and risks, to preserve the security and confidentiality of your personal information and, in particular, to prevent them from being deformed, damaged or transmitted to any unauthorized parties.

This may include practices such as retaining your personal information on a secure server protected by a firewall, the transmission of sensitive information (such as credit card number) using a secure encryption protocol (Protocol SSL), internal reviews of our practices and privacy policies and implementation of physical security measures to protect against unauthorized access.

7 - What is the policy about minors?

This website www.clarins.com is not aimed at minors.

We do not knowingly collect nor process personal information from children under the age of 18. Assuming we would have knowledge of the collect of personal information from minors without prior authorization from the holder of the parental responsibility, we would take appropriate measures to delete this personal data from our servers.

8 – What is the cookies policy of Clarins?

For more information on Clarins’ cookies policy, please see our Cookies policy:

://www.clarins.co.uk/customer-service-privacy-security/cookies_policy.html?iscontentfolder=true

9 - For how long are your personal data kept?

We strive to keep your personal information only for the time necessary for the purposes set out in this privacy policy and in accordance with the provisions in force.

As a general rule:

• Customer / prospect data will be kept for three years from the date of collection or after the last contact or the end of the commercial relationship, unless opposed by you. At the end of this three-year period, we may make contact with you again in order to find out whether or not you wish to continue to receive marketing approaches. If no clear positive answer is given by you, your data will be deleted or archived in accordance with the provisions in force.
• Data to prove a right or a contract, or kept under compliance with a legal obligation can be archived in accordance with the provisions in force.

10 – Your rights regarding personal data and how to contact us?

If you give us your email address, phone number or mailing address, you may receive emails, calls or periodic messages from us about our products, services or upcoming events. You can unsubscribe at any time from our mailing lists by contacting us at the address below or by following the link "unsubscribe" contained in each of our emails. You can also change your preferences at any time in your account.

In accordance with the provisions in force, you have the right to access, rectify, limit, oppose and delete personal information about you. You can also withdraw your consent at any time. To exercise these rights, you must send us a request:

• By E-mail a request to the Customer Service;
• By writing to the following address:

CLARINS U.K. LIMITED
10 Cavendish Place
London W1G 9DN
United Kingdom

You will be informed of the actions to be taken as soon as possible and in any case no later than one month after your request. However we reserve the right not to respond to manifestly unfounded or excessive requests.

In accordance with the provisions in force, you can also file a complaint with the competent authority responsible for data protection or lodge an appeal if your data are misused.

Please contact our data protection officers in UK or in France should you have any questions or comments in connection with this Privacy Policy:

Groupe Clarins
Direction Juridique / Délégué à la Protection des Données
12 avenue de la Porte des Ternes
75017 Paris
France