Professional* account creation and management

Where your personal data are collected as part of the creation or throughout the management of a professional account with L’Oréal (either directly through our account management teams, or on L’Oréal websites/apps).

*professional accounts are created in relation to a business capacity; they are not for personal use.

• First name and surname;
• Organisation name;
• Gender;
• Professional and/or personal email address;
• Professional and/or personal postal address;
• Professional and/or personal phone number;
• Bank details or other financial information;
• Details of individuals employed by your organisation;
• Professional account details and/or membership associations;
• Training courses (online and offline) you have selected and/or attended;
• Photo;
• ID/username, and password;
• Preferences;
• Order details;
• User generated content (such as reviews or images you share);
• Other information you have shared with us about yourself (e.g. via your “My Account” page, by contacting us, a question via the chat function available on some websites, or by participating in a survey etc.).

To:

• Manage your account and orders;
• Send you marketing communications which may be tailored to your professional “profile” (i.e. based on the personal data we know about you and your preferences);
• Assess your eligibility for credit facilities and manage any credit facility throughout our relationship with you, including the recovery of any unpaid monies;
• Manage any direct debits;
• Run audits to manage our compliance obligations;
• Offer you a loyalty program;
• Offer personalised services based on professional interests and characteristics;
• Allow you to manage your preferences;
• Monitor and improve our websites and apps;
• Run analytics or collect statistics;
• Secure our websites and protect you and us against fraud;
• Respond to your questions and otherwise interact with you;
• Contact you for feedback and request you complete surveysetc.; and/or
• Manage any promotions, surveys etc. you enter.

• The performance of a contract – so we can create and manage your professional account, and provide you with the services that you request;
• Our legitimate interests: (i) to send you information about our products and services; (ii) to improve our products and services; (iii) better engage with you; (iv) prevent fraud; (v) exercise our rights e.g. in the event of unpaid monies; and (vi) secure our tools.

Newsletter and marketing subscription

Where your personal data are collected when you receive our marketing communications.

• First name and surname;
• Email address;
• Gender;
• Address;
• Phone number;
• Professional account details and/or membership associations;
• Birthday or age range
• ID/username, and password;
• Personal description or preferences;
• Order details;
• Social media profile (where you use your social media login or share this personal data with us);
• User generated content; and/or
• Other information you have shared with us about yourself (e.g. via your “My Account” page, by contacting us, a question via the chat function available on some websites, or by participating in a contest, game, survey etc.).

To :

• Send you marketing communications (where you have asked us to) which may be tailored to your “profile” based on the personal data we know or learn about you and your preferences;
• Show you marketing communications on other websites, including social media platforms. Note that you may also see our ads on other websites, including on social media sites, but these may or may not be tailored to you;
• Keep an up to date suppression list if you have asked not to be contacted;
• Run analytics or collect statistics; and/or
• Send content on your behalf to your friends, family and/or other contacts.

• Our legitimate interests to: (i) send you information on our products and services; and (ii) improve our products and services; and (iii) better engage with you.

Purchases and order management

Where your personal data are collected during the purchase process made via L’Oréal account team, on L’Oréal website/apps or in store.

• Professional account details, including first name and surname, email address, postal address, phone number, account number;
• Personal description or preferences;
• Social media profile (where you use your social media login or share this personal data with us);
• Transaction information including purchased products;
• Payment and information; and/or
• Purchase history.

To

• Contact you to finalise your order where you have saved your shopping cart or placed products in your cart without completing the checkout process;
• Inform you when a product you wanted to purchase is available;
• Process your order including delivering the product to the address you indicated;
• Manage payment. Please note that if you make a payment on a credit or debit card, your payment information (credit card number/Paypal/bank account details) are not collected by us directly, but by secure payment service providers. If you make payment via your account, we will hold your bank details in order to manage these payments;
• Manage any contact you have with us about your order;
• Secure your transactions against fraud. We may use a third party provider’s solution to detect fraud and make sure that payment is completed;
• If you place a purchase using a registered account, we will add this transaction to your profile so we can understand your interests and preferences and you will see a record of your transactions with us within your account (where applicable);
• Manage any dispute relating to a purchase; and/or
• Run analytics or collect statistics.

• The performance of a contract – so you can make purchases and we can manage the associated logistics.
• Our legitimate interests: (i) to improve our products and services; (ii) better engage with you; (iii) prevent fraud; and (iv) secure our tools.
• To comply with a legal obligation – to keep the information we are legally required to retain.

Online browsing

Where your personal data are collected by cookies or similar technologies (“cookies”*) when you browse L’Oréal website/apps or on third-party website/apps where we have cookies.

For information on the specific cookies placed on a particular website/app, please check the cookies table or tool available on the specific website/app.

*cookies are small text files stored on your device (computer, tablet or mobile) when you are on the Internet, including on L’Oréal Group’s websites.

Data related to your use of our websites, including:

• Where you came from;
• Login details;
• Data related to your use of our apps/websites;
• Videos you watched;
• Pages/adverts you looked at, clicked or tapped on;
• Duration of your visit; and/or
• Products you selected to create your basket.

Technical information:

• Your IP address;
• Browser information;
• Device information; and/or
• Your unique ID which is given to each visitor, and the expiration date of the ID.

We use cookies, together with other personal data you have already shared with us (such as previous purchases, or whether you’re signed up to our email newsletters) for the following purposes:

• To deliver targeted advertising, that is to show you:

   

  • online advertisements for products which may be of interest to you, based on your previous behaviour; and/or
  • ads and content on social media platforms or other websites
• You can opt out of targeted advertising by using the function available on our website (where applicable), or in your browser settings. For opting out of targeted advertising on social media platforms, please visit the relevant social media platform to explore the options they may provide.

   

• To tailor our services for you, that is to:

   

  • show you recommendations, marketing, or content based on your profile and interests; and/or
  • display our websites in a tailored way, for example, show you products we think you might like.
• To allow our websites/apps to function properly, that is to:

   

  • ensure the proper display of content
  • create and remember your shopping cart
  • create and remember your account login details;
  • interface personalisation, such as language, or any user-interface customisation (i.e. parameters attached to your device including your screen resolution or font preference), etc.; and/o
  • improve our websites/apps, for example, by testing new ideas or layouts.
• To ensure our websites/apps are secure and safe, and to protect you against fraud or misuse of our websites/apps or services, for example through performing troubleshooting.

   

• To run statistics, that is to:

   

  • avoid visitors being recorded twice;
  • know users’ reaction to our advertising campaigns.
  • improve our offers; and/o
  • understand how you discovered our websites/apps
• To allow sharing of our content on social media.

   

• Consent – to store cookies on your device.
• Our legitimate interests: (i) to improve our products and services; (ii) better engage with you; and (iii secure our tools.

Promotions

Where your personal data are collected during a competition, game, contest, promotional offer, sample request, survey etc.

• Professional Account details;
• First name and surname;
• Email address;
• Phone number;
• Birthday or age range;
• Gender;
• Address;
• Personal description or preferences;
• Social media profile (where you use your social media login or share this personal data with us); and/or
• User generated content;
• Other information you have shared with us about yourself (e.g. via your “My Account” page, by contacting us, a question via the chat function available on some websites, or by participating in a contest, game, survey etc.).

To:

• Complete tasks that you have asked us to, for example to manage your participation in the promotion, including to take into account your feedback and suggestions;
• Run analytics and statistics;
• Add your participation to your profile so we can understand your interests and preferences.

• The performance of a contract – so you may entered into the promotion/we can deliver the prize).
• Our legitimate interests: (i) to improve our products and services; and (ii) better engage with you.

User Generated Content

Where your personal data are collected when you submit content (for example images or ratings and reviews) on one of our websites/apps/social media platforms, or accept our re-use of any content you posted on social media platforms.

• Professional Account details;
• First name and surname or alias;
• Email address;
• Photo;
• Personal description or preferences;
• Social media profile (where you use your social media login or share this personal data with us); and/or
• Other information you have shared with us about yourself (e.g. via your “My Account” page, by contacting us, or by providing your own content such as photos or a review, or a question via the chat function available on some websites).

To:

• Use the content you have created and/or shared in accordance with the specific terms and conditions accepted by you e.g. to post your review/content and to promote our products;
• Run analytics and statistics; and/or
• Add your content to your profile so we can understand your interests and preferences.

• Consent – to provide you with the service you have requested, for example, so you can upload the content of your choice, or so we can reuse your content for which you have given your consent.
• Our legitimate interests: (i) to improve our products and services; (ii) better engage with you; and (iii) secure our tools and design new features.

Use of websites/apps and devices

Where your personal data are collected as part of your use of our apps and/or devices.

• First name and surname;
• Email address;
• Photo;
• Location;
• Birthday or age range;
• Personal description or preferences, including characteristics such as skin tone, skin/hair type; and/or
• Application or device usage data.

To:

• Provide you with the service(s) you requested (e.g. test our products virtually, enable you to purchase our products, provide you with advice and notifications regarding your sun exposure, hair routine etc.);
• Analyse your personal characteristics and recommend appropriate products (including bespoke products) and routines;
• Provide you with learning materials and information on brands, products, and services;
• Facilitate communication and connection between users (e.g. chat functions);
• Conduct research and innovation by scientists within the L’Oréal Group;
• Monitor and improve our apps and devices; and/or
• Run analytics and statistics.

• Consent – to provide you with the service you have requested, for example, show you recommended products or complete your purchase.
• Our legitimate interests: (i) to improve our products and services; (ii) better engage with you; and (iii) secure our tools.

Enquiries

Where your personal data are collected when you ask questions relating to our brands, our products and their use, or your purchases, account or rights.

• Professional Account details;
• First name and surname;
• Phone number;
• Email address;
• Other information you have shared with us about yourself in relation to your enquiry (which may include welfare and health data).

To:

• Answer and manage your enquiries;
• Conduct studies in relation to the safe use of our products;
• Run analytics and statistics; and/or
• Add your questions or concerns to your profile so we can understand your interests and preferences.

• The performance of a contract – to respond to your enquiries.
• To comply with a legal obligation – to monitor any undesirable effects of our products.
• Our legitimate interests: (i) to improve our products and services; (ii) better engage with you; and (iii) secure our tools.

Social media and public profile

Where your personal data are collected from publicly available information contained in social media and public profiles.

• First name and surname;
• ID/username; and
• User generated content, such as reviews or images you share, and other data manifestly made public by you

• To review your profile to ensure our values are aligned.

• Our legitimate interests to: ensure that when we elect to work with you on a particular project or activity, we have assessed whether the content you have posted on your social media profiles and data that is public about you aligns with our values. The processing of special categories of data is limited to data manifestly made public by you.

Event, seminars and training sessions

Where you are interacting with us in the course of your professional occupation as our customer, client, vendor, service provider, journalist etc.

• Professional account details;
• First name and surname;
• Organisation name;
• Gender;
• Birthday or age range;
• Dietary requirements;
• Professional occupation;
• Professional and/or personal email address;
• Professional and/or personal address;
• Professional and/or personal phone number;
• Professional account details and/or membership associations
• Photo;
• Preferences;
• Spoken language; and/or
• Other information you have shared with us about yourself

To:

• Invite you, organise the relevant event and manage the seminars and events that we organise as part of our business activities;
• Provide you with information and training on our products, services, and brands, tailored to your professional profile.

• The performance of a contract, to provide you or your organisation with the requested service
• Our legitimate interests to: (i) contact you with information about our products and services; (ii) improve our products and services; (iii) better engage with you.
• Consent or explicit consent – to provide you with the service you have requested, for example, to accommodate the dietary requirement(s) you have requested.

The right to be informed

You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data, and your rights. This is why we are providing you with the information in this Privacy Policy.

The right of access

You have the right to access, and receive a copy of, any personal data we hold about you (subject to certain restrictions). In exceptional circumstances we may charge a reasonable fee for providing such access but only where permitted by law.

The right to rectification

You have the right to have your personal data rectified if it is incorrect or outdated and/or completed if it is incomplete. If you have an account, it may be easier to correct your own personal data via your “My Account” function.

The right to erasure/right to be forgotten

In some cases, you have the right to have your personal data erased or deleted. Note this is not an absolute right, as we may have legal or legitimate grounds for retaining your personal data.

The right to object to direct marketing, including profiling, and any processing based on our legitimate interests

You can unsubscribe or opt out of our direct marketing communication at any time. The easiest way to do this is by clicking on the “unsubscribe” link in any email or communication we send you. In circumstances where you have the right to object to profiling or any processing based on our legitimate interests, you should contact us using the details below.

The right to withdraw consent at any time for and personal data processing based on consent

You can withdraw your consent to our processing of your personal data when such processing is based on consent. Where you withdraw your consent, this does not affect the lawfulness of our processing before your withdrawal. Please see the table in section “what personal data do we collect from you and how do we use it” specifically the column “What is our legal basis for processing your personal data?” to see where/when our processing is based on consent.

The right to object to processing based on legitimate interests

You may object at any time to our processing of your personal data when such processing is based on our legitimate interests. Please see the table in section “what personal data do we collect from you and how do we use it” specifically the column “What is our legal basis for processing your personal data?” to see where/when our processing is based on legitimate interests.

The right not to be subject to a decision based solely on automated decision-making

Where we use your personal data to make an automated decision about you (please see “Automated Decision Making” above for examples), you have the right to object to our decision. Your right does not apply if: (i) you gave us your explicit consent to use your personal data to make our decision; (ii) we are allowed by law to make our decision; or (iii) our automated decision was necessary to enable us to enter into a contract with you.

The right to lodge a complaint with a supervisory authority

You have the right to contact the data protection authority of your country in order to lodge a complaint against our data protection and privacy practices. Do not hesitate to contact us at the details below before lodging any complaint with the competent data protection authority as we will always seek to resolve your complaint in the first instance.

The right to data portability

You have the right to move, copy or transfer personal data from our database to another. This only applies to personal data that you have provided, where processing is based on a contract or your consent, and the processing is carried out by automated means. Please see the table in section “what personal data do we collect from you and how do we use it” specifically the column “What is our legal basis for processing your personal data?” to see where/when our processing is based on consent or the performance of a contract.

The right to restriction

This right means that our processing of your personal data is restricted, so we can store it, but not use nor process it further.

It applies in the following limited circumstances set out in the General Data Protection Regulation:

• the accuracy of the personal data is contested by you, for a period enabling L’Oréal to verify the accuracy of the personal data;
• the processing is unlawful and you object the erasure of your personal data and request L’Oréal restricts the ways in which it processes your personal data;
• L’Oréal no longer needs your personal data for the purposes of its processing, but you require the personal data for the establishment, exercise or defence of legal claims;
• You object to L’Oréal’s processing of your personal data based L’Oréal’s legitimate interests, pending the verification whether the L’Oréal’s legitimate grounds override your rights and freedoms.

The right to deactivate cookies

The settings from the Internet browsers are usually programmed by default to accept cookies, but you can easily adjust it by changing the settings of your browser or, where available, by using the tools on our websites.

Many cookies are used to enhance the usability or functionality of a website; therefore disabling some types of cookies may prevent you from using certain parts of our websites.

If you wish to restrict or block all the cookies which are set by our websites, please use the tool available on the particular website (if applicable), or refer to the Help function within your browser to learn how to manage your settings within your browser. For more information please consult the following links:

http://www.aboutcookies.org/.