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CARITA – PRESTIGE ET COLLECTIONS INTERNATIONAL
PRIVACY POLICY

Introduction

L’Oréal’s ambition is to be an exemplary corporate citizen to help make the world a more beautiful place. We place great value on honesty and clarity and we are committed to building a strong and lasting relationship with our consumers based on trust and mutual benefit. Part of this commitment means safeguarding and respecting your privacy and your choices. Respecting your privacy is essential to us. This is why we set out “Our Privacy Promise” and our full Privacy Policy below.

OUR PRIVACY PROMISE

1. We respect your privacy and your choices.
2. We make sure that privacy and security are embedded in everything we do.
3. We do not send you marketing communications unless you have asked us to. You can change your mind at any time.
4. We never offer or sell your data.
5. We are committed to keeping your data safe and secure. This includes only working with trusted partners.
6. We are committed to being open and transparent about how we use your data.
7. We do not use your data in ways that we have not told you about.
8. We respect your rights, and always try to accommodate your requests as far as is possible, in line with our own legal and operational responsibilities.

For more information about our privacy practices, below we set out what types of personal data we may receive from you directly or from your interaction with us, how we may use it, who we may share it with, how we protect it and keep it secure, and your rights around your personal data. Of course all situations may not apply to you. This Privacy Policy gives you an overview of all possible situations in which we could interact together.
The more you interact with us, the more you let us know you and the more we are able to offer you tailored services.
When you share personal data with us or when we collect personal data about you, we use it in line with this Policy. Please read this information and our Q&A page (if any) carefully. If you have any questions or concerns about your personal data, please contact us at marketing.carita@loreal.com

WHAT WILL YOU FIND IN THIS PRIVACY POLICY?

Who are we?
What is personal data?
What data do we collect from you and how do use it?
     1. How do we collect or receive your data?
     2. Who may access your personal data?
     3. Where we store your personal data?
     4. How long do we keep your personal data?
     5. Is my Personal data secure?
     6. Links to third party sites and social login
     7. Social media and user generated content
Your rights and choices
Contact



Who we are?

Carita is brand of Prestige et Collections International, part of the L’Oréal Group. Carita is responsible for the personal data that you share with us. When we say “L’Oréal”, “us”, “our” or “we”, this is who we are referring to. L’Oréal is the “data controller” for the purposes of applicable data protection laws.

Prestige et Collections International
62 quai Charles Pasqua - CS 30141 - 92688 Levallois-Perret Cedex
Representative : Cyril Chapuy

What is personal data?

“Personal data” means any information or pieces of information that could identify you either directly (e.g. your name) or indirectly (e.g. through pseudonymized data such as a unique ID number). This means that personal data includes things like email/home addresses/mobile phone, usernames, profile pictures, personal preferences and shopping habits, user generated content, financial information, and welfare information. It could also include unique numerical identifiers like your computer’s IP address or your mobile device’s MAC address, as well as cookies.

What data do we collect from you and how do we use it?

L'Oréal believes that you, the consumer, are at the heart of what we do. We love hearing from you, learning about you, and creating and delivering products that you enjoy. And we know that many of you love talking to us. Because of this, there are many ways that you might share your personal data with us, and that we might collect it.

How do we collect or receive your data?

We might collect or receive data from you via our website. Sometimes you give this to us directly (e.g. when you contact us), sometimes we collect it (e.g. using cookies to understand how you use our websites/apps) or sometimes we receive your data from other third parties, including other L’Oréal Group entities.
When we collect data, we indicate the mandatory fields via asterisks where such data is necessary for us to:

- Provide you with the service you have asked for (e.g. to provide you with a newsletter); or
- Improve our website

If you do not provide the data marked with an asterisk, this may affect our ability to provide the products and services.

We set out further details in the table below, explaining:

1. During what interaction your data may be provided or collected? This column explains what activity or situation you are involved in when we use or collect your data. For example, whether you are signing up to a newsletter, or browsing a website/app.
2. What personal data may we receive from you directly or resulting from your interaction with us? This column explains what types of data we may collect about you depending on the situation.
3. How and why we may use it? This column explains what we may do with your data and the purposes for collecting it.
4.What is the legal basis for using your personal data? This column explains the reason we may use your data.

Depending on the purpose for which the data is used, the legal basis for the processing of your data can be:

• Your consent;
• 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 consumers’ benefit.
- 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.
• The performance of a contract: more specifically to perform the services you request from us;
• Legal grounds where a processing is required by law.

Information overview on your interactions with us and their consequences on your data?
> During which interactions may you provide and we may collect your data?

Newsletter and commercial communications subscription

> What personal data may we receive from you directly or resulting from your interaction with us?

Depending on how much you are interacting with us, those data may include:

• Email address;
• Name and surname;
• Personal description or preferences;
• Social media profile (where you share this personal data with us).

> How and why we may use your data ?

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 about you, and your preferences (incl. location of your favorite store);
• Run analytics or collect statistics.
• Keep an up to date suppression list if you have asked not to be contacted;

> What is the legal basis for using your personal data?


Consent
To send you direct marketing communications.
Legitimate Interest

To keep your details on a suppression list if you have asked us not to send you any direct marketing anymore

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> During which interactions may you provide and we may collect your data?

Online browsing
Information collected by cookies or similar technologies (“Cookies”*) as part of your browsing on L’Oréal website/apps and/or on third-party website/apps.
For information on specific Cookies placed through a given website/app, please consult the relevant cookie table.
* Cookies are small text files stored on your device (computer, tablet or mobile) when you are on the Internet, including on L’Oreal Group’s websites.
> What personal data may we receive from you directly or resulting from your interaction with us?

Depending on how much you are interacting with us, those data may include:
• Data related to your use of our websites/apps:
• Where you came from;
• Login details;
• Pages you looked at;
• Videos you watched;
• Ads you click on or tap;
• Products you search for;
• Your location;
• Duration of your visit;
• Products you selected to create your basket.

Technical information
• IP address;
• browser information;
• device information.
A unique identifier granted to each visitor and the expiration date of such identifier.

> What is the legal basis for using your personal data?

We use Cookies, where relevant, with other personal data you have already shared with us (such as previous purchases, or whether you’re signed up to our email newsletters) or the following purposes:
• To allow proper functioning of our website/apps:
o proper display of the content;
o creation and remembering of a cart;
o creation and remembering of your login;
o interface personalisation such as language;
o parameters attached to your device including your screen resolution, etc;
o improvement of our websites/apps, for example, by testing new ideas.
• To ensure the website/app is secure and safe and protect you against fraud or misuse of our websites or services, for example through performing troubleshooting.
• To run statistics:
o To avoid visitors being recorded twice;
o To know users’ reaction to our advertising campaigns;
o To improve our offers;
o To know how you discovered our websites / apps.
• To deliver online behavioural advertising:
o to show you online advertisements for products which may be of interest to you, based on your previous behaviour;
o to show you ads and content on social media platforms.
• To tailor our services for you:
o to send you recommendations, marketing, or content based on your profile and interests;
o to display our websites/apps in a tailored way like remembering your cart or login, your language, the user-interface customization cookies (i.e. the parameters attached to your device including your screen resolution, font preference, etc).
• To allow sharing of our content on social media (sharing buttons intended to display the site).

> What is the legal basis for using your personal data?

Legitimate interest
To ensure we are providing you with websites/apps, advertising and communications that are working properly and are continually improving for cookies that are (i) essential for the functioning of our websites/apps, (ii) used to keep our websites/apps safe and secure.

Consent

For all other cookies.

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> During which interactions may you provide and we may collect your data?

• Use of Apps and devices

Information collected as part of your use of our Apps and/or devices.
> What personal data may we receive from you directly or resulting from your interaction with us? Depending on how much you are interacting with us, those data may include :
• Location
• Geolocalisation

> What is the legal basis for using your personal data?
To provide you with the service requested;
• For monitoring and improvement of our Apps and devices;
• For statistics purposes.

> What is the legal basis for using your personal data?
• Performance of contract
To provide you with the service requested (including, where needed, analysis by the research and innovation team of the algorithm necessary to provide the service).
• Legitimate Interest
To always improve our products and services to match your needs and expectations and for research and innovation purposes.
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> During which interactions may you provide and we may collect your data?

• Enquiries
Information collected when you ask questions (e.g. through our consumer care) relating to our brands, our products and their use.

> What personal data may we receive from you directly or resulting from your interaction with us?

Depending on how much you are interacting with us, those data may include:
• 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).

> What is the legal basis for using your personal data?

• To answer your enquiries;
Where needed, to connect you with the relevant services
• For statistics purposes.
• For Cosmétovigilance:
- To monitor and prevent any undesirable effect linked to the use of our products;
- To perform studies relating to the safe use of our products;
- To perform and follow-up on corrective measures taken, where needed.

> What is the legal basis for using your personal data? • Consent

To process your enquiry.

• Legitimate interest

To help us better understand our customers’ needs and expectations and therefore improve our services, products and brands.
• Legal grounds

To comply with the legal obligation to monitor undesirable effects of its products.

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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, 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;
• 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.

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:
o By L’Oréal in accordance with this Privacy Policy;
o 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:
- 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 information 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 information and will delete the information promptly after the match process is complete.

We do not offer or sell your personal data.

Where 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 available here).
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 contact us for an enquiry, we keep your personal data for the duration needed for the processing of your enquiry;
• 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 and 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.
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 and 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.

Your Rights and Choices

L’Oréal respects your right to privacy: it is important that you are able to control your personal data. You have the following rights:

• Your right

The right to be informed
• What does that mean?
You have the right to obtain 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 Policy.

• Your right

The right of access
> • What does that mean?
You have the right to access to the personal data we hold about you (subject to certain restrictions). We may charge a reasonable fee taking into account the administrative costs of providing the information. Requests manifestly unfounded, excessive or repetitive may not be answered to. To do this, please contact us at the details below.

• Your right

The right of rectification
• What does that mean?
You have the right to have your personal data rectified if it is incorrect or outdated and/or completed if it is incomplete. To do this, please contact us at the details below. If you have an account, it may be easier to correct your own data via your “My Account” function.

• Your right

The right to erasure/right to be forgotten
• What does that mean?
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. If you would like us to delete your personal data, please contact us at the details below.

• Your right

The right to object to direct marketing, including profiling
• What does that mean?
You can unsubscribe or opt out of our direct marketing communication at any time. It is easiest to do this by clicking on the “unsubscribe” link in any email or communication we send you. Otherwise, you can contact us using contact detail below. If you would like to object to any profiling, please contact us at the details below.

• Your right

The right to withdraw consent at any time for data processing based on consent
• What does that mean?
You can withdraw your consent to our processing of your data when such processing is based on consent. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. We refer to the table inserted in section “what data do we collect from you and how do we use it” especially the column “What is our legal basis for processing your data?” to identify where our processing is based on consent. If you would like to object to withdraw your consent, please contact us at the details below.

• Your right

The right to object to processing based on legitimate interests.
• What does that mean?
You can oppose at any time to our processing of your data when such processing is based on the legitimate interest. We refer to the tables inserted in section “what data do we collect from you and how do we use it” especially the column “What is our legal basis for processing your data?” to identify where our processing is based on legitimate interests. To do so, please contact us at the details below.

• Your right

The right to lodge a complaint with a supervisory authority
• What does that mean?
You have the right to contact the data protection authority of your country in order to lodge a complaint against the data protection and privacy practices of L’Oréal.
Do not hesitate to contact us at the details below before lodging any complaint with the competent data protection authority.

• Your right

The right to data portability
• What does that mean?
You have rights to move, copy or transfer data from our database to another. This only applies to data that you have provided, where processing is based on a contract or your consent, and the processing is carried out by automated means. We refer to the tables inserted in section “what data do we collect from you and how do we use it” especially the column “What is our legal basis for processing your data?” to identify where our processing is based on the performance of a contract or on consent. For further details, please contact us at the details below.

• Your right

The right to restriction
• What does that mean?
You have the right to request restriction of our processing of your data. This right means that our processing of your data is restricted, so we can store it, but not use nor process it further.
It applies in limited circumstances listed by the General Data Protection Regulation which are as follow:
- the accuracy of the personal data is contested by the data subject (i.e. You), for a period enabling the controller to verify the accuracy of the personal data;
- the processing is unlawful and the data subject (i.e. You) opposes the erasure of the personal data and requests the restriction of their use instead;
- the controller (i.e. L’Oréal) no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims;
- the data subject (i.e. You) has objected to processing based on the legitimate interests of the data controller pending the verification whether the legitimate grounds of the controller override those of the data subject.

If you would like to request restriction, please contact us at the details below.

• Your right

The right to deactivate Cookies
• What does that mean?
You have 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. Many cookies are used to enhance the usability or functionality of websites/apps; therefore disabling cookies may prevent you from using certain parts of our websites/apps as detailed in the relevant Cookie Table. If you wish to restrict or block all the cookies which are set by our websites/apps (which may prevent you from using certain parts of the site), or any other websites/apps, you can do this through your browser settings. The Help function within your browser should tell you how. For more information please consult the following links: https://www.aboutcookies.org/ To deal with your request, we may require proof of your identity.

Contact

If you have any questions or concerns about how we treat and use your personal data, or would like to exercise any of your rights above, please contact us via the “contact us” form.

You can also contact our DPO at the following coordinates: dpo@loreal.com

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