Date: 26 May 2021
At Charlotte Tilbury Beauty Limited, we are committed to protecting your personal information and respecting your privacy. It is your personal data and we respect that.
About Us - Who is the Charlotte Tilbury Group?
When you place an order on the Website, you are contracting with Charlotte Tilbury Beauty Limited, but 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 US, Canada, the Netherlands, Germany and Hong Kong. When we refer to the ‘Charlotte Tilbury Group’ we are referring to the wider global group of Charlotte Tilbury companies.
You can purchase Charlotte Tilbury products and services via our retail partners across the UK. For example in Selfridges & Co., Harrods, The John Lewis Partnership, House of Fraser etc (we refer to these as our ‘Retail Partners’). Please note that when you are purchasing Charlotte Tilbury products and/or services at through a Retail Partner, either online or in one of their stores, 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.
Ensuring the lawful use of your data
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.
What information we collect from you and how we use it
The information we collect about you and how we will use it, depends on how you interact with us, for example, if you place an order on our Website, contact us with a query by email or phone, make a purchase, or book an appointment in one of our stores. 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, username, password and date of birth. We will also collect your contact details, such as your email address, telephone number, mobile phone number and billing/delivery address.||To fulfil your order, for example, by delivering your products to you or to contact you about your order where necessary. For example, Royal Mail, DPD.||To fulfil our contract with you.|
|To allow you to create an account with us.||Legitimate business purposes.|
|To send you email newsletters to keep you up-to-date about our products and services which we think will interest you and our latest offers, and where you opt to participate in our loyalty and VIP programmes.||Where you consent.|
|To send you SMS messages to keep you up-to-date about our products, services and our latest offers which we think will interest you.||Where you consent.|
|To send you information with your Order to keep you up to date about our products, services and our latest offers which we think will interest you.||Legitimate business purposes.|
|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.||Legitimate business purposes.|
|To communicate with you in relation to your order or 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|
|Details of your transactions including purchase history and activity.||To assess whether you are eligible for a loyalty programme.||Legitimate business purposes|
|Information you provide to us when you contact us by telephone, by email, by post, on social media, via our Website, via LiveChat or via VideoChat, including your phone number, email address, social media profile/handle and image, as applicable.||Provide you with the support and customer service you have requested.||Legitimate business purposes or where you consent when required|
|CCTV footage in our stores.||To record images for security purposes.||Legitimate business purposes|
|For data analysis, testing, research and statistical statistics to help us to improve our products and services.||Where you consent|
|To keep our Website safe and secure.||Legal obligation. 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. To provide you with information about and remind you about the products and services that you have looked at on our Website.||Where you consent|
|To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.||Where you consent|
|To identify behavioural flows from emails we send to you, so that we are able to monitor and analyse the effectiveness of those emails||Where you consent|
|Additional information you choose to provide us, including your birthday, hair colour, eye colour, make-up tone, skin tone and beauty preferences. We may collect this in different ways, including via your Charlotte Tilbury account, via bookings you make, consultations or appointments you have with us, via games you play on our Website or via emails we send you or via marketing campaigns to collect additional optional data||To assist us to provide you with a more personalised beauty experience||Legitimate business purposes|
|Photographs, videos and video stills of you, where you choose to provide them to usCell||For use on the Website, social media channels and other Charlotte Tilbury channels and promotional materials for marketing purposes and product recommendations.||Where you consent. Legitimate business purposes|
|Personal data provided in audio or video recordings, such as when you call us, customer care calls or online consultation services||To improve and monitor our services and for learning and development, training and quality purposes.||Legal obligation. Legitimate business purposes. To fulfil our contract with you.|
|Social media handles||Where you have provided us with your social media handle to participate in a Charlotte Tilbury programme or similar, to enable us to identify and view your social media account(s)||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.
Automated decision making
Sharing your data
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, Royal Mail, DPD, Klarna, Stripe, PayPal|
|Professional service providers such as website hosting providers, system providers, website and social media analytics providers, advertisers and appointment booking providers, who help us run our business||Examples, Booking Bug, Google Analytics, Doubleclick, Magento, Traackr.|
|Direct marketing companies who help us manage our electronic communications with you||Examples, Emarsys, Ometria, Moveable ink.|
|Social Media or Web platforms to show you products that might interest you while you’re browsing the internet||Examples, Facebook, Instagram, YouTube|
|Companies who send segmented, personalised marketing communications on our behalf||Examples, Qubit, Revel, Implicit Design|
|Credit reference agencies, law enforcement and fraud prevention agencies, so that we can help tackle fraud||Examples, Stripe, PayPal and Klarna|
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 (such as HMRC) 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.
Information we receive from third parties
We may receive information about you from third parties, such as partners we run competitions and events with, for example, our Retail Partners 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. or where you have written a review about us.
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.
Seeing advertisements for our website online
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 may also work with and use services offered by other third parties to serve ads to you as part of a customised campaign on third-party sites and platforms (such as Facebook or Instagram). As part of these ad campaigns, we or the third parties may convert information about you, such as your email address and phone number, into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and to serve you advertising that is customised to your interests. For more information about this advertising, or to opt out of seeing these types of customised ads, please visit these third-party sites and platforms, which may offer you choices about this type of customised advertising.
MARKETING SERVICE PROVIDERS
Your personal data, which includes but is not limited to demographic information, transaction history, and online behaviour, may be shared with selected marketing service providers for the purposes of the following and is typically known as data profiling:
• helping us better understand the likely characteristics of our customers;
• creating predictive models that can offer suggestions and recommendations to you and other users about products or services that may interest you or them;
• improving the relevancy and appropriateness of our marketing to customers (e.g. offers, its products and services); and
• helping us to communicate with our customers more effectively offline and online. This may mean that you receive tailored advertising via direct mail or when you visit a website.
To ensure the security and protection of your data, all information shared with any marketing service providers will be transformed into a non-readable format. This means that your identifiable information will be removed and replaced with pseudonymous identifiers or encrypted tokens. The marketing service providers may have the capability to match the data we share with them with data from their or other third party sources. For example, combining the non-readable data received from us with data collected from various reputable sources to gain more comprehensive insights into consumer behaviour and preferences.
International transfer of your personal data
We are a global business and some of our group companies and service providers are located in countries outside of the UK or the EU.
As a result, it may be necessary for the personal data that we collect from you to be transferred to or accessed from outside the UK or the EU in order for us to provide our services.
If you are based outside the UK and place an order on the Website, or engage with us via the Website on LiveChat or VideoChat, your personal data may be accessed in the UK and/or the EU by Charlotte Tilbury Beauty Limited and the third parties detailed above.
How long will we keep your personal data?
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.
Ensuring your personal data is up to date and correct
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.
Third Party Links
How can I unsubscribe from marketing communications?
We love keeping you up-to-date by email and by SMS 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:
To unsubscribe from eEmails, eEmail us at: firstname.lastname@example.org 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.
To unsubscribe from SMS, follow the link at the end of any SMS we send you. You can also email us at email@example.com.
We may also send you details of products, services, offers and events we think you may be interested in when we send you your Order. If you decide that you don’t want to receive these communications let us know by email at firstname.lastname@example.org.
You have the following rights in relation to the personal information we hold about you, to request:
- Access to the personal data we hold about you (commonly known as a "data subject access request") including a copy of it.
- The correction of the personal information that we hold about you if it is incomplete or inaccurate (although if you hold an account with us, you may be able to do this in certain cases yourself by visiting the Account Information page on the Charlotte Tilbury website);
- The deletion or removal of personal data we hold about you where there is no good reason for us continuing to process it or where you have exercised your right to object to processing (see below);
- For our processing of your personal information to be restricted in certain circumstances, for example if you want to establish its accuracy or the reason for processing it; and
- To obtain a copy of the personal information you’ve provided us with and to reuse it elsewhere or to ask us to transfer it to a third party of your choice.
We may ask you for proof of your identity before dealing with your request, as a security measure to protect your data.
Right to Object
Where we are processing your personal data on the basis of our legitimate interests, you can ask us to stop processing it and we must do so unless we believe we have an overriding legitimate reason to continue processing your personal data.
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 the UK, this is the Information Commissioner's Office (ICO). You can make a complaint to the ICO by calling their helpline on 0303 123 1113 or on their website at www.ico.org.uk/concerns.
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.
For advertising purposes, we occasionally use information about our customers to generate a "lookalike audience" or similar audience of prospective customers through the Facebook, Google, Snapchat, Pinterest or TikTok advertising platforms. This allows us to target advertisements on their networks to potential customers who appear to have shared interests or similar demographics to our existing customers, based on the platforms' own data. We typically do this by uploading a list of email addresses. These third parties’ policy is to irreversibly hash (encrypt) such lists prior to uploading, match the hashed data against their own customers, generate the lookalike audience, then delete the uploaded list and use it for no other purpose. We do not have access to the identity of anybody in the lookalike audience, unless they choose to click on the ads. Based on this, we believe that generating lookalike audiences poses little or no threat to the privacy of our customers. If you wish to opt out of "similar audiences" in Google, you can do so through your Ads Settings. Many of the companies that display interest-based advertising are members of the Network Advertising Initiative ("NAI") and/or Digital Advertising Alliance ("DAA"). To learn more about interest-based advertising and how you may be able to opt-out of interest-based advertising, tracking, and/or sharing of tracking data by their members, visit their online resources at www.networkadvertising.org/choices and www.aboutads.info/choices, respectively. Other resources (not affiliated with NAI or DAA) include http://preferences-mgr.truste.com/, or for EU residents, www.youronlinechoices.eu.
Customers need to be over 18 to create an account with us or to sign up for our newsletter. or to contact us or to liaise with us via LiveChat or VideoChat. 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.
• by email at email@example.com; or
• by post at General Counsel, Charlotte Tilbury Beauty Limited, Surrey Street, London, United Kingdom, WC2R 2ND.