PRIVACY POLICY - HONG KONG

CHARLOTTE TILBURY CUSTOMER 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 legal@charlottetilbury.com 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.

ABOUT US – WHO IS THE CHARLOTTE TILBURY GROUP?

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.

PURCHASING FROM OUR WEBSITE

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

Concession

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.

ONLINE RETAIL PARTNER

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.

ENSURING THE LAWFUL USE OF YOUR 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.

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 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__: 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. __How we use it__ - 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. __On the lawful basis where you consent__ - To allow you to book an appointment with us or to attend an event. __On the lawful basis legitimate business purposes__ - So that you can enter competitions, events or prize draws run by us. __On the lawful basis where you consent__ - To communicate with you in relation to your booking, or if you raise an enquiry or complaint with us. __On the lawful basis 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. __On the lawful basis legitimate business purposes__ - Fraud prevention and detection. __On the lawful basis Legal obligation/legitimate business purposes__ - To email you to inform you when a product you want to order is back in stock. __On the lawful basis legitimate business purposes__ --- __The personal data we collect from you:__ Payment details and details of your transactions. __How we use it__ - 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. __On the lawful basis to fulfil our contract with you.__ - Fraud prevention and detection. __On the lawful basis Legal obligation/legitimate business purposes__ --- __The personal data we collect from you__: Information you provide to us when you contact us by telephone, by email, by post or on social media. __How we use it__ - Provide you with the support and customer service you have requested. __On the lawful basis Legal obligation/legitimate business purposes__ --- __The personal data we collect from you__: 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 __How we use it__ - 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. __On the lawful basis legitimate business purposes__ - For data analysis, testing, research and statistical statistics to help us to improve our products and services. __On the lawful basis legitimate business purposes__ - To keep our Website safe and secure. __On the lawful basis 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.__On the lawful basis legitimate business purposes__ - To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you. __On the lawful basis legitimate business purposes__ --- __The personal data we collect from you__: Additional information you choose to provide us, including your hair colour, eye colour and skin tone. __How we use it__ - To assist us to provide you with a more personalised beauty experience. __On the lawful basis legitimate business purposes__ --- __The personal data we collect from you__: Photographs of you, where you choose to provide them to us. __How we use it__ - For use on the Charlotte Tilbury website for marketing purposes and product recommendations.__On the lawful basis where you consent__ ---

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

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

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; (eg. 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; (eg. Booking Bug, Google Analytics, Magento) - Direct marketing companies who help us manage our electronic communications with you; (eg. Dotmailer, Ometria, Moveable ink) - Social Media or Web platforms to show you products that might interest you while you’re browsing the internet; (eg. Facebook, Instagram, YouTube) - Companies who send segmented, personalized marketing communications on our behalf; (eg.Qubit, Revel, Implicit Designs)

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.

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 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.

SEEING ADVERTISEMENTS FOR OUR WEBSITE ONLINE

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.

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 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.

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.

Security

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

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.

HOW CAN I UNSUBSCRIBE FROM MARKETING COMMUNICATIONS?

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: customercare@charlottetilbury.com 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.

YOUR RIGHTS

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 legal@charlottetilbury.com.

RIGHT TO OBJECT

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 enquiry@pcpd.org.hk. 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.

Children

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.

Contacting US

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 legal@charlottetilbury.com; or - by post at General Counsel, Charlotte Tilbury Beauty Limited, Unit 5, 50 Brook Green, London W6 7BJ.