Privacy Policy - Hong Kong

CHARLOTTE TILBURY CUSTOMER PRIVACY POLICY – HONG KONG

At Charlotte Tilbury Beauty Hong Kong Limited, we are committed to protecting your personal information and respecting your privacy. It is your personal data and we respect that.

This Privacy Policy tells you about how and why we collect and use the personal data which you provide to us or which we collect about you when you interact with us, for example, when you use our website or visit our stores.

We want you to be fully informed about how we use your data, how we keep it secure and your rights.

We trust this Privacy Policy will answer any questions you have, but if not, please do get in touch with us directly at [email protected] or using the contact details provided at the end of this Privacy Policy.

It is likely that we will need to update this Privacy Policy from time to time by updating this page. We will notify you of any significant changes, but would encourage you to come back and review it from time to time.

This Privacy Policy is provided by Charlotte Tilbury Beauty Hong Kong Limited (referred to as “we”, “us” or “our” in this Privacy Policy). We are the data controller of any personal data we collect about you in Hong Kong.

However, we are part of a wider group of Charlotte Tilbury companies that run and operate the Charlotte Tilbury business elsewhere across the globe. This includes in the UK, US, Canada, the Netherlands and Germany. When we refer to the Charlotte Tilbury Group we are referring to the wider group of Charlotte Tilbury companies.

We may share your personal data with other companies within the Charlotte Tilbury Group to enable us to run data analysis, develop new products, for other business development purposes and/or to allow another Charlotte Tilbury Group company to perform services on our behalf. Where we do this, we have written contracts in place between the companies within the Charlotte Tilbury Group to ensure your privacy is secure and respected.

If you want to know more about the Charlotte Tilbury Group, please get in touch with us using the contact details provided at the end of this Privacy Policy.

You can purchase products from the Charlotte Tilbury website http://global.charlottetilbury.com/uk/apac (the Website) for delivery in Hong Kong. In order to deliver to Hong Kong, we work with a third party called Borderfree and if you place an order on the Website you will be contracting with Borderfree and not us. Borderfree shares information with us, such as order placement, product preference, purchase history and where you have consented, Borderfree will also share marketing consents with us.

When you purchase via the Website, your personal data is used in accordance with Borderfree’s privacy policy. For more information, please see Borderfree’s privacy policy: https://www.borderfree.com/#/privacy/en_gb and terms and conditions: https://www.borderfree.com/#/terms/en_gb

You can purchase Charlotte Tilbury products and services at a Charlotte Tilbury concession in the store of our retail partner Lane Crawford (‘Concession’). Please note that when you purchase any products in the Concession you are contracting directly with us and we are the data controller of any personal data we collect when you purchase products at the Concession.

You can also purchase Charlotte Tilbury products and services via the website of our retail partner in Hong Kong, Lane Crawford. (‘Retail Partner’). Please note that when you are purchasing Charlotte Tilbury products and/or services online through the Retail Partner you are contracting directly with that Retail Partner and not with us or the wider Charlotte Tilbury Group.

Any personal data which you provide to a Retail Partner will be controlled by the Retail Partner and you should visit the Retail Partner’s website or contact them directly if you have any questions about how they process, handle and use your personal data.

We will only use your personal data where we have a lawful basis to use it. We will only use your data where it is necessary for us to perform our contract with you (for example, to fulfil your order), or in a way which might reasonably be expected as part of running our business and which does not materially impact your interests, rights or freedoms. For example, we might combine your shopping history to identify trends and ensure we can keep up with demand and develop the right new products for our customers. Please get in touch with us using the contact details provided at the end of this Privacy Policy if you would like further information about this.

We may sometimes need to use data to comply with our legal obligations (for example to pass on details related to fraud). In other instances, we will ask for your consent to use your data, for example, where you sign-up to receive our email newsletters.

Further details of how we use your personal information are provided below.

The information we collect about you and how we will use it, depends on how you interact with us, for example, if you purchase products from the Concession, contact us with a query by email or phone, or book an appointment in the Concession. The table below provides some examples of the information we collect about you and how we will use it.

The personal data we collect from you How we use it Lawful Basis
We will collect the personal data needed to identify you, such as your name, and date of birth. We will also collect your contact details, such as your email address and telephone number. To send you personal offers (using your purchase history) and email newsletters to keep you up-to-date about our new product launches, red-carpet secrets and other Charlotte Tilbury beauty related information that may be of interest to you. Where you consent.
To allow you to book an appointment with us or to attend an event. Legitimate business purposes
So that you can enter competitions, events or prize draws run by us. Where you consent.
To communicate with you in relation to your booking, or if you raise an enquiry or complaint with us. Legitimate business purposes
To allow you to complete any surveys we send you (if you wish to) or to comment on or review our products or service, to help us to improve them. Legitimate business purposes
Fraud prevention and detection Legal obligation/legitimate business purposes
Payment details and details of your transactions. To take payment of your order and, if required, to give refunds. We do not store any payment card numbers once the transaction has been completed. We will share this data with credit card companies and other payment providers. To fulfil our contract with you.
Fraud prevention and detection Legal obligation/legitimate business purposes
Information you provide to us when you contact us by telephone, by email, by post or on social media. Provide you with the support and customer service you have requested. Legitimate business purposes
Technical information about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies and full details as to how we process and use cookies can be found on our Cookies Policy To administer and to improve our Website, to ensure it is presented in the most effective manner for you and to give you the best Website experience and to allow you to participate in interactive features of our Website if you choose to do so. Legitimate business purposes
For data analysis, testing, research and statistical statistics to help us to improve our products and services. Legitimate business purposes
To keep our Website safe and secure. Legitimate business purposes
To make suggestions and recommendations to you and other users of our Website about products or services that may interest you or them. Legitimate business purposes
To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you. Legitimate business purposes
Additional information you choose to provide us, including your hair colour, eye colour and skin tone. To assist us to provide you with a more personalised beauty experience. Legitimate business purposes

You don’t have to give us any of the personal data set out above but, if you don’t provide us with certain information, we may not be able to provide you with the goods and services you have requested from us. The forms you fill in on our Website and in our stores will make it clear what information we need in order to provide the product or service you are requesting and what information you can choose to provide if you wish.

To help us form a better, overall understanding of you as a customer, we combine your personal data gathered across the Charlotte Tilbury Group, for example, your shopping history.

We don’t currently carry out automated decision-making, using information we hold about you.

SHARING YOUR DATA WITHIN THE CHARLOTTE TILBURY GROUP

We may share your personal data with other companies within the Charlotte Tilbury Group to enable us to run data analysis, develop new products, for other business development purposes and/or to allow another Charlotte Tilbury Group company to perform services on our behalf. Where we do this, we have written contracts in place between the companies within the Charlotte Tilbury Group to ensure your privacy is secure and respected.

SHARING YOUR DATA WITH TRUSTED THIRD PARTIES

We share your personal data with trusted third parties to allow us to provide our services to you. When we do share your data with these third parties we only provide the information they need to perform the service. We have written contracts in place with them to ensure they only use your data for the purpose we specify to them and that your privacy is secure and respected.

These trusted third parties include the following:

• Companies that help us fulfil your orders and, where required, get your purchases to you, such as delivery couriers and payment providers; Examples, Borderfree,
• Professional service providers such as website hosting providers, system providers, website analytics providers, advertisers and appointment booking providers, who help us run our business; Examples, Booking Bug, Google Analytics, Magento
• Direct marketing companies who help us manage our electronic communications with you Examples, Dotmailer, Ometria, Moveable ink
• Social Media or Web platforms to show you products that might interest you while you’re browsing the internet; and Examples, Facebook, Instagram, YouTube
• Companies who send segmented, personalized marketing communications on our behalf. Examples, Qubit, Revel, Implicit Design.

We may also share your personal data in connection with a business transition (such as a merger, acquisition by another company, or a sale of all of or portion of our assets). In these circumstances, we may need to share your personal data with a prospective buyer and external professional advisors such as accountants, insurers, lawyers or financial institutions.

We may be required to share your personal data with the police, administrative authorities or other enforcement, regulatory or Government bodies, where we are legally obliged to do so.

We will only share your personal data with third parties (including our group companies) for them to use for their own direct marketing purposes when you have given your consent for us to do so.

We may receive information about you from third parties, such as partners we run competitions and events with, for example, our Retail Partner and trade shows or from other organisations we work with, or from publicly available sources, such as Companies House, or information which is published in the media.

Depending on your settings or the privacy policies of social media or messaging services, such as Facebook, Twitter or WhatsApp, we may collect information about you from these sources, with your permission.

We may combine the information you have given us, with information obtained from other sources, but we will only do this when we have a lawful basis to do so.

We, like many other companies, target Charlotte Tilbury ads and banners to you when you are browsing on apps and other websites. We do this by way of various ad exchanges and digital marketing networks. We use various advertising technologies, for instance, ad tag, cookies, pixels, identifiers and web beacons. We also use services offered by some sites and social networks, for example, Facebook’s Custom Audiences.

The ads and banners you see are based on information that we hold about you, or on your prior use of our Website, for example, products you have browsed previously, content you have read on our Website, or on Charlotte Tilbury banners or ads that you have engaged with in the past.

We are a global business and some of our group companies and service providers are located in countries outside of Hong Kong.

As a result, it may be necessary for the personal data that we collect from you to be transferred to or accessed from outside Hong Kong in order for us to provide our services.

If we do this, we have procedures in place to ensure your data receives the necessary protections. Any transfer of your personal data will follow applicable laws and we will treat the information according to the principles set out in this Privacy Policy.

If you would like further information, please get in touch with us using the contact details provided at the end of this Privacy Policy.

We will only keep your personal data for as long as we need to for the reason we collected it, as set out in this Privacy Policy. For example, for as long as needed to allow us to fulfil your order or to provide any customer services support you have requested, or for as long as you hold an account with us.

We may also keep hold of some of your personal data if we are required to do so for legal purposes, for example, to meet our legal or regulatory requirements or to prevent fraud and abuse. For example, we will keep your order data for five years after you place an order with us to allow us to comply with our legal obligations.

When we are no longer required to keep your personal data, your data will either be deleted or completely anonymised. For example, by aggregation with other data so that it can be used in a non-identifiable way for business planning and analysis purposes.

It is important that the personal data we hold about you is accurate and current. If you have an account with us, please keep your details up-to-date.

We are committed to ensuring that your personal data is secure and we have put in place suitable physical, electronic, contractual and managerial procedures, including our Information Security Management System and Secure Sockets Layer (SSL) encryption, to protect your personal data. Our employees who have access to and process your personal data are obliged to respect the confidentiality and security of your personal data.

Our Website may contain links to other websites of interest. However, we do not have any control over third party websites and they will be governed by their own privacy policies, not this Privacy Policy.

We love keeping you up-to-date by email about our latest products, services, offers and events, but if you decide that you don’t want to receive these communications at any point, you can unsubscribe as follows:

Email us at: [email protected] or click on the unsubscribe button on the bottom of any email we send you. If you have an account with us, you can also unsubscribe by going to the Account Information page on the Charlotte Tilbury website, clicking on Newsletters, and unsubscribing to general subscription.

You may request details of personal information which we hold about you under the Personal Data (Privacy) Ordinance Cap 486. A small fee will be payable. If you would like a copy of the information held on you please write to Customer Care, Charlotte Tilbury Beauty Limited, Unit 5, 50 Brook Green, London, W6 7BJ or email [email protected]

If you are dissatisfied with how we have handled your personal data, you have the right to make a complaint to your data protection regulator. In Hong Kong, this is the Office of the Personal Data Privacy Commissioner (’PDPO’). You can make a complaint to the PDPO by calling their helpline on 2827 2827 or emailing them at [email protected]

We would, however, appreciate the chance to deal with your concerns before you approach the ICO or, (if you’re based outside of the UK, your data protection regulator), so please do contact us in the first instance.

You need to be over 18 to create an account with us or to sign up for our newsletter. We will not knowingly collect data about under 18s and if you are under 18, please do not provide us with your personal information. We would ask parents to please ensure that their children that are under 18 do not provide us with any personal information without their permission. If you believe that a child who is under 18 has provided personal data to us, please contact us, using the details below and we will seek to delete that data from our systems.

If you have any queries, comments or requests regarding this Privacy Policy, you have a complaint or you would like to exercise any of your rights set out above, you can contact us in the following ways:

• by email at [email protected]; or

• by post at General Counsel, Charlotte Tilbury Beauty Limited, Unit 5, 50 Brook Green, London W6 7BJ.