1 - Introduction
2 - Types of Information Collected
Personal Information We Collect
Personal information or personal information means any information we collect and by which you can be identified. Personal information includes, but is not limited to:
- Personal identifiers, such as your name, address, telephone number, birth date, email address, profile information, and social media profile;
- Commercial information, such as your purchase history;
- Internet or other electronic network activity information, including browsing and search history, where such information is linked to you; and
- Other information you voluntarily provide that is used to identify you.
Non-Personal Information We Collect
Non-personal information does not identify you personally. Non-personal information includes, but is not limited to, technical information and geolocation information. It can include Internet protocol (IP) address if that IP address does not identify an individual or household, internet service provider, site access times, referring websites, and web pages within the Clarins’ Websites visited and general location information (e.g., city, state) based on IP addresses. We sometimes refer to this data as “Anonymous Data.” We collect Anonymous Data in many ways including through automated logging of activity on the Clarins’ Websites. Anonymous Data is not linked to you or used to identify a specific person.
Although it may appear that we collect financial information from you on the Site or in providing services that you request, it is actually collected and processed through a third party service provider (“Payment Processor”) that processes payments for us. The Payment Processor may collect financial information such as banking information or credit card number, name, CVV code or date of expiration, from you on the Service. We do not hold your financial information.
3 - When We Collect Personal Information
We collect personal information from or about you when you voluntarily provide us with this information or when you visit the Site. However, if you choose not to provide the information we request, you may be unable to fully enjoy Clarins’ Sites and services, make a purchase, or complete a transaction.
We collect your personal information when you:
- Place an order through Clarins’ Sites or in our stores;
- Create an account on Clarins’ Sites;
- Enter a sweepstakes or contest, take a survey, sign up for a loyalty program or subscribe to a newsletter, rate or review our products and/or services, chat with other visitors in real time, contact us with a comment or question, sign up either online or in store to receive emails or marketing communications about our products or services; or
- Visit one of our pages on a third party social networking platform such as Facebook, YouTube, Instagram, Twitter or Pinterest.
If you give us personal information of another person, you represent that you have the authorization from that person to provide such information.
4 - Use of Information
We collect personal information to serve you better and to provide you with a customized experience while using Clarins’ Sites and visiting our stores. Your personal information is used:
- To administer Clarins’ Websites, perform analytics, anticipate and resolve problems with these sites, store contacts you enter, and improve the quality of service;
- To request feedback and develop, customize, and improve Clarins’ Sites, our products, and publications;
- To process your order, complete a transaction, and perform after-sales services;
- To keep track of any purchase made by you and/or notify you of any product or service we believe may be of interest to you;
- To contact or alert you about Clarins’ Sites, or any products, activities, special events or offers from us or our partners; and/or to contact or alert you for other marketing, informational, product development or promotional purposes;
- To conduct Customer Relationship Management (CRM) (including our loyalty program, newsletters, promotions, ratings and reviews, chat, product testing, and surveys);
- To conduct marketing analysis;
- To connect you to external third party applications, such as when you create an account using an external application;
- To prevent and detect fraud;
- To contact you about your use of Clarins’ Sites, or to otherwise respond to your emails, submissions, comments, requests or complaints, including customer support inquiries and questions about our products or services;
- To tie personal information to your non-personal information or demographic information in order to provide you with recommendations for products or services based on your interests, purchase history, age, or location;
- To combine the personal information you provide us with other information (such as demographic and past purchase information) from our records and from other sources, such as address update services, to use for future marketing initiatives and to help us improve Clarins’ Sites and your overall shopping experience;
- For other purposes about which we notify you or as required by law at the point of collection.
5 - When we Share Personal Information with Third Parties
To Comply with Legal Requirements
- To comply with laws or respond to lawful requests and legal process.
- To act in the event of a good faith belief that disclosure is needed to respond to an emergency or protect the safety of the public or any person.
To Fulfill a Service to You
- To complete your purchase. If you choose to make a purchase on Clarins’ Sites, we may collect from you your billing address, shipping address, and other information related to such purchase, and use and share this information to fulfill your purchase. We may also provide such information, or other personal information provided by you, to unaffiliated third parties as necessary to complete your purchase (for example, to delivery your product, and process returns).
- To provide advertisements to you about our products, services, and offers on our site and other websites tailored to your interests and history with Clarins.
- To provide relevant content to those who have registered on Clarins’ Sites.
- To perform entry collection, winner selection, and prize fulfillment for sweepstakes, contests, and promotions. We may also share your information with the co-sponsor of that promotion or in connection with the distribution of prizes.
- To provide you with third-parties services that you use such as ratings and reviews or community chat. Be sure to review the terms and the privacy policies of those third parties before using their services.
To Facilitate Your Use of Third Party Resources
Clarins’ Sites may include access to social networking websites established, owned, and controlled by third parties, such as Facebook.com. You may voluntarily use these third parties to access, purchase, or view products and services. If you choose to use third parties, we may facilitate sharing of your personal information with those third parties.
To Maintain Clarins’ Sites
We may have to share your information with our affiliates and subsidiaries, as well as unaffiliated third-party service providers, unaffiliated third-party service providers, agents, or independent contractors who help us maintain Clarins’ Sites and provide other administrative services to us. These services include, but are not limited to:
- Providing customer service;
- Tracking and analyzing usage and volume statistics;
- Maintaining and analyzing data;
- Manage charge backs and product returns; and
- Sending customer communications on our behalf.
We seek to ensure that these unaffiliated third parties will not use your personal information for purpose other than the administrative services for which they are responsible.
We reserve the right to share non-identifying data or anonymized information about our customers, sales, and traffic to our affiliates, subsidiaries, partners, and advertisers. We may share this -information when it is tied to your personal information in the manners described above.
In Connection with a Merger or Sale of Our Business
We will transfer your information as a result of, or in connection with, the sale of all or a part of our assets in the event of, a merger, acquisition, reorganization, bankruptcy, or any other change of control transaction. You grant us the right to assign your personal information collected if such information is connected with any such transaction.
6 - Data Collection Technologies We Use
Cookies and Web Tracking Techniques
Third Party Advertisers
We may use advertisers, third party ad networks, and other advertising companies to serve advertisements on Clarins’ Sites. These advertising companies may also gather information about your visit to Clarins’ Sites (such as through cookies, web beacons, and other technologies) to enable such advertising companies to market products or services to you and to monitor which ads have been served to your browser and which webpages you were viewing when such ads were delivered. For more information about Internet-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit: www.networkadvertising.org/managing/opt_out.asp and www.aboutads.info/choices.
Our Site uses what are called social plugins (“plugins”) from social networks such as Facebook, Twitter, YouTube, and Instagram. These plugins are indicated by the social networks’ respective logos on Clarins’ Websites, and are used to establish a direct connection with the servers of these social networks.
Integration of the plugin allows the social media networks to receive the information that you have loaded onto the corresponding page of the Site. If you are logged in with Facebook, for example, it will be able to assign your visit to your account. An exchange of this information already takes place when you visit our Site, regardless of whether you interact with the plugin or not. If you interact with the plugins, the corresponding information is sent directly to the social network by your browser and saved there. You can find information about how the data is used by the social networks, your rights, and optional settings to protect your privacy on the social networks’ websites.
If you do not want social networks to gather data about you via our Site, you must log out on the social network domain before visiting the Site. To prevent information being exchanged with the social networks during your visit to our Site, you can opt out of cookies through your browser settings and other tools.
7 - Information on Public Areas of Clarins’ Sites
Any information you submit in a public area of Clarins’ Sites – such as on a social media page, user comments, comments on Clarins’ blogs, reviews or comments on any ratings and reviews feature, questions or answer on a question and answer application or any other public forum – will not be treated as confidential and may be publicly disclosed. This applies to personal information, so please consider your public postings before doing so. Additionally, information posted on social media pages will be subject to the terms governing those pages and websites.
8 - Protecting Kids’ Privacy
Clarins’ Sites are not intended for children. We do not knowingly collect personal information from children, and Clarins’ Sites are not designed to attract children. If you believe we have collected personal information about your child under the age of 13, please contact us using the contact information in Section 16.
9 - Protecting Your Security
Clarins’ Sites employ security measures in accordance with industry standards to protect the security of your personal information both online and offline. For example, your personal information is stored on computer servers in a controlled environment that is reasonably protected from unauthorized use or disclosure. Only you can access your account information using the password you created when you created the account. It is your responsibility to maintain your password private. You should always sign off your account and close your browser when you are finished using your account.
10 - Your Choices Regarding Your Personal Information
You can exercise the following choices with respect to your personal information either through your online account or by sending us a request at the contact information included in Section 16 below:
- You can request access to your personal information we maintain;
- You can correct your personal information, which includes the right to have incomplete personal information completed;
- You can request that we stop sending you electronic marketing communications, including by following the procedures described in the Opt-Out section bellow;
- You can request that we delete your personal information, subject to our obligation or ability to retain your personal information under applicable law;
- If our use of your personal information is based on consent, you can withdraw your consent at any time.
11 - Opting Out
If you would like to opt out of receiving promotional emails from us, please follow the unsubscribe instructions located at the bottom of each email.
If you would like to opt out of receiving direct email, mail, mobile marketing or telephone marketing calls from us, please send your request, including your name, email address, street address, city, state, and zip code, via email to Help-USA@Clarins.com (please use the subject line: Privacy Opt-Out Request). We are not responsible for notices that are labeled or sent improperly or do not have complete information. We will process your request within 30 calendar days of the date we receive your request, but you may, in the meantime, receive previously scheduled emails, mail, or calls from us. Once you have opted out, you do not need to do so again.
12 - Changing, Updating or Deleting Personal Information
You can update, change, or delete certain personal information (such as your email address, mailing address, and payment method) on Clarins’ Websites by clicking “My Account” in the menu at the top of each page.
If the information you wish to update, change, or delete is not included in the “My Account” page, you can request an update, change, or deletion by emailing Help-USA@Clarins.com.
13 - International Transfer of Information
15 - Governing Law
16 - Contact Us
Clarins USA, Inc.
15 Olympic Drive
Orangeburg, NY 10962
Communication Preference Section in your Account
17 - Additional Notice to California Residents
Do Not Track Disclosures
Clarins does not support Do Not Track browser settings and does not currently participate in any “Do Not Track” frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your personal information or cookie data.
Third Party Marketing
Under California law, if you are a resident of California, you are entitled once per year to request and obtain certain information regarding our disclosure, if any, of your personal information to third parties for their direct marketing purposes during the immediately prior calendar year. To make such a request, please use any of the contact methods listed in Section 16 above. You must include your full name, email address, and postal address in your message. In response to your request, we will provide you with a notice describing the cost-free means to opt out of our sharing your personal information with third parties, if the third party will use it for their direct marketing purposes.
California Consumer Privacy Act Disclosure
If you are a resident of California, the California Consumer Privacy Act (“CCPA”) (Civil Code § 1798.100) provides you with specific rights regarding your personal information. These include:
- You can request information about our collection and use of your personal information over the past twelve (12) months concerning (i) the categories of personal information we collected about you, (ii) the business or commercial purpose for collecting your personal information, (iii) the categories of sources from which your personal information is collected, and (iv) categories of third parties with whom we share your personal information. You can request two separate lists disclosing (a) the categories of your personal information we sold and (b) the categories of your personal information we may share in connection with our business purpose.
- You can request to receive a copy of your personal information in a structured, commonly used and machine-readable format.
- You can request that we delete your personal information, subject to certain exceptions.
To exercise the rights described above, it may be necessary for us to verify your identity or authority to make the request and confirm the personal information relates to you. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. We will not discriminate against you for exercising any of your privacy rights under CCPA or applicable law.
During the past twelve (12) months we collected the categories of personal information listed above from California residents and third parties.
We also disclosed this personal information to third parties for the purposes noted above during the past twelve (12) months.
18 - Disclosure of Sale
19 - NOTICE OF FINANCIAL INCENTIVE
If the CCPA applies to you, and you have opted-in to one or more of our rewards programs, then in addition to the program specific terms provided to you at the time you opt-in (for each such program, the “Rewards Terms”), the following terms apply.
You agree that the incentive you receive as the result of your participation in a given program (e.g. cash, a different quality of goods or services, or discounts on goods or services that you purchase from us) is reasonably related to the value of any personal information (as explained in the applicable Rewards Terms) that you provide to us as a result of participating in said program(s).
You may opt-out of any rewards program at any time by emailing us at Help-USA@Clarins.com indicating that you want to opt-out and identifying the rewards program of which you are opting-out.
You acknowledge and agree that you may no longer receive the incentive(s) that are part of the opted-out program(s), that this is his difference in price or quality would not be considered a discriminatory practice against you for exercising your rights under the CCPA because the value of the incentive(s) that you received under the applicable program(s) is reasonably related to the value of your personal information (as described in the applicable Rewards Terms).
20 - Notice of Clarins’ Biometric Data Practices
In order to allow the Clarins’ Virtual Try On program (the “Feature”) to function properly, we may need to collect, capture, use, and store pictures of you, which may show your facial geometry. Some laws may label pictures of you and your facial geometry as “biometric identifiers”, “biometric information”, “biometric data”, or any number of similar terms referring to details about your physical appearance, or body, that can be used to identify you, which we will refer to here as “Biometrics”.
Before proceeding, we’d like to inform you of our practices relating to your Biometrics. We may collect or capture your Biometrics based on an image that you upload, or that is captured from a webcam or similar device. If collected, your Biometrics may be used to create a digital representation of your face so that you may apply any number of our products to the digital representation and gain a better understanding of how our products will look on you in real life before buying them.
If collected, we may store your Biometrics until you complete the session, at which point, we will permanently destroy and delete your Biometrics.
Clarins does not disclose your Biometrics to any third parties.
Please feel free to email us with any question at Help-USA@Clarins.com.