Last updated and effective as of 13 January 2023.
- About Us
- Our Retail Partners
- Collection of Personal Information
- Use of your Personal Information
- Sharing of Personal Information
- Your Choices
- Advertising and Analytics Services Provided by Others
- Your Privacy Rights
- California Notice of Financial Incentive
- Contact Us
Our retail partners
Collection of Personal Information
Personal Information You Provide to Us
- Register for an online account;
- Request additional information about our products or services or sign up to receive news, information, or special offers from us;
- Interact with us on social media;
- Purchase any product or service from us;
- Book an appointment with a make-up artist;
- Apply to join our Pro Artist Program;
- Request information or assistance from us, including correspondence with our customer service team;
- Participate in or respond to surveys or requests for opinions, feedback, and preferences or fill out other forms on our website or in our stores;
- Engage with us via our Website, telephone or cell phone, via Livechat or via VideoChat;
- Engage with us via our marketing communications;
- Engage with us via games you play on our website or via emails we send you;
- Provide reviews of products or post other content in interactive areas of our website; and
- Sign up for and participate in events, contests, sweepstakes, or promotions. The types of personal information we collect directly from you include: your name, email address, phone number, mailing address, date of birth, credit card number or other payment information, password, personal preferences, age, gender, skin tone, hair color, eye color, facial image, video and audio recordings and any other information you choose to provide.
If you choose to use the Virtual Try-On, Foundation Finder, and/or Skin Reader services on our website, your image, which may include your skin tone, face shape, eye shape, brow shape, hair color, age or skin condition, will be used to enable the feature(s) to work. Your image is stored on your web browser and is not retained by the Charlotte Tilbury Group. Charlotte Tilbury Group may engage its trusted service partners to enable these features. We may need to share your image with these service partners so the features work properly; however, our service partners do not store this information in a manner that identifies individuals.
Automatically Collected Personal Information
- Log and Usage Information: We collect information about the device you use to access our website and your use of our website, including the type of browser you use, operating system, IP address, unique device identifiers, access times, pages viewed, links clicked, items placed in your cart, browsing behavior and the referring URL (the webpage you visited before navigating to our website);
- Transactional Information: When you make a purchase or return, we collect information about the transaction, such as product details, purchase price, and date and location of the transaction.
- Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use different technologies to collect personal information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our website, services and your experience, see which areas and features of our website are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that may be used in our website or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see Cookies below.
Personal Information We Collect from Third Parties
- Other customers, such as when a friend purchases a gift card for you and provides your email address so we can deliver the gift card electronically;
- Our Retail Partners, trade show organizers, and other organizations we partner with to organize contests and events or otherwise promote our products and services;
- Social media or messaging services, such as Facebook, Twitter, and WhatsApp, depending on your account settings with those third-party platforms and services; and
- Publicly available sources.
Personal Information We Derive
We may derive personal information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address, or that you are interested in a particular product based on your browsing behavior on our website.
Use of your personal information
- Facilitate and improve your in-store and online shopping experience
- Complete the transactions you request, perform our contractual obligations, and send you related information, including confirmations and receipts;
- Create and manage your online account and provide technical support (including to debug and troubleshoot) and send you technical notices, updates, security alerts, and support and administrative messages;
- Send promotional messages and newsletters (for information about how to manage promotional communications, please see Marketing Communications below);
- Respond to your questions and comments and provide customer support;
- Allow you to complete surveys or comment on or review our products or services;
- Organize and provide events, sweepstakes, contests, and promotions;
- Conduct internal research and development;
- Engage with you via LiveChat or VideoChat or via our Website;
- Provide advertising and marketing targeted toward your interests;
- Provide you information about and remind you about the products and services you have looked on our Website;
- Analyze traffic and user activities on our website, identify popular areas or features of our website, and optimize and personalize website content;
- Protect the rights and property of the Charlotte Tilbury Group and others and comply with our legal obligations, including to detect, investigate, and prevent fraud and other illegal activities and to enforce our agreements; and
- Carry out any other purpose described to you at the time the personal information was collected.
Sharing of personal information
- With other companies within the Charlotte Tilbury Group to enable us to run data analysis, develop new products and services, and for other business development purposes. We may also share personal information to allow another Charlotte Tilbury Group company to perform services on our behalf.
- With our vendors and service providers, who are trusted third parties we hire or work with, to allow us to provide our products and services to you. These service providers need access to your personal information in order to perform services on our behalf, such as web hosting, payment processing, email distribution, marketing and advertising, customer support, information technology, and analytics services.
- With our partners, such as organizations with whom we organize contests or events, our Retail Partners, or trade show organizers.
- With other website visitors when you choose to participate in certain interactive areas of our website, such as by posting a product review.
- In connection with a corporate transaction, such as any purchase, sale, lease, merger, or other type of acquisition, disposal, or financing involving the Charlotte Tilbury Group.
- With our professional advisors, such as our legal, financial, insurance, and other advisors in connection with the corporate transactions described above or the management of our business and operations.
- With law enforcement and individuals involved in legal proceedings, when it’s necessary for us to comply with applicable law or legal process, to respond to legal claims, or to protect the rights, property, or personal safety of the Charlotte Tilbury Group, our users, employees, or the public.
- With your consent or at your direction.
RETENTION OF PERSONAL INFORMATION
We love keeping you up-to-date 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 by following the unsubscribe instructions in those communications or by emailing us at firstname.lastname@example.org. You may also opt out of receiving our text messages by texting STOP to our SMS number. To unsubscribe to our marketing emails, you can also visit the Account Information page on the Charlotte Tilbury website, click on “Newsletters,” and unsubscribe from that page. If you opt out of marketing emails, please note that we may still send you non-promotional emails, such as those about your account or our ongoing business relationship.
Advertising and Analytics Services Provided by Others
Your Privacy Rights
Consumers residing in certain states are afforded additional rights with respect to their personal information under the laws applicable to them. If you are a resident of a state that provides its residents additional rights with respect to their personal information, this section applies to you.
We have collected the following categories of personal information: identifiers, telephone numbers, characteristics of protected classifications under state or federal law, commercial information, internet and electronic network activity, audio and visual information, inferences drawn about you, and other categories of personal information that relates to or are reasonably capable of being associated with you. For details about the precise data points we collect and the sources of collection, please see sections titled “Collection of Personal Information” and “Personal Information We Collect from Third Parties” above. We collect personal information for the business and commercial purposes described in the “Use of Your Personal Information” section above.
In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:
|Category of Personal Information||Categories of Recipients|
|Identifiers||Internet service providers, data analytics providers, operating systems and platforms, social networks, customer service partners, fraud prevention partners, marketing partners, advertising partners, retail partners, payment processors, cloud service providers, other users (if you choose to share certain information, such as product reviews, publicly on our website), other companies within the Charlotte Tilbury Group, and our professional and legal advisors|
|Telephone Numbers||Advertising networks, social networks, and marketing partners.|
|Characteristics of protected classifications under California or U.S. law||Other companies within the Charlotte Tilbury Group, operating systems and platforms|
|Commercial information||Internet service providers, data analytics providers, government entities, operating systems and platforms, customer service partners, fraud prevention partners, marketing partners, payment processors, cloud service providers, other users (if you choose to share certain information, such as product reviews, publicly on our website), other companies within the Charlotte Tilbury Group, and our professional and legal advisors|
|Internet and electronic network activity||Internet service providers, data analytics providers, operating systems and platforms, fraud prevention partners, marketing partners, advertising partners, cloud service providers, other companies within the Charlotte Tilbury Group, and our professional and legal advisors|
|Audio and visual information||operating systems and platforms, social networks, customer service partners, fraud prevention partners, marketing partners, other users (if you choose to share certain information, such as product reviews, publicly on our website), other companies within the Charlotte Tilbury Group, and our professional and legal advisors|
|Inferences drawn about you||Data analytics providers, operating systems and platforms, social networks, customer service partners, marketing partners, advertising partners, other companies within the Charlotte Tilbury Group, and our professional and legal advisors|
Certain state laws require that we provide transparency about personal information we “sell,” which broadly means scenarios in which we have shared personal information with third parties in exchange for valuable consideration. Additionally, certain state laws require that we are transparent about the information we “share” for cross-context behavioral advertising, targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects. We “sell” or “share” personal information for the commercial purposes of advertising and marketing our products to you across other websites and via social networks and platforms. In the preceding 12 months, we have “sold” or “shared” the following categories of personal information to the following categories of third parties:
|Category of Personal Information||Category of Third Parties|
|Identifiers||Advertising networks, social networks, and marketing partners.|
|Telephone Numbers||Advertising networks, social networks, and marketing partners.|
|Internet or other electronic network activity information||Advertising networks, social networks, and marketing partners.|
|Inferences drawn about you||Advertising networks, social networks, and marketing partners.|
You state of residence may provide you the right to opt out of “sale” or “sharing” of your personal information at any time by visiting our “Do Not Sell or Share My Personal Information” webpage or calling us at +1-855-528-8495. We do not knowingly sell or share personal information about individuals under the age of 16.
In addition to the right to opt out of the “sale” or “sharing” of your personal information explained above subject to certain limitations, your state of residence may provide you the right to (1) request to know more details about the categories and specific pieces of personal information we collect, use, disclose, sell or share (2) request deletion of your personal information, subject to certain exceptions, (3) request that we provide a copy of the personal information we have collected about you, in a portable and, to the extent technically feasible, readily usable format, (4) correct personal information we have about you, (5) not be discriminated against for exercising their rights, and (6) opt-out of the sale of your personal information for valuable consideration or sharing of your personal information for purposes of cross-context behavioral advertising, targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects.
If you are a resident of a state that provides you one or more of these rights (or other rights related to your personal information), you may make a request to exercise such right(s) by calling +1-855-528-8495 or visiting this page. Once we receive your request, we may verify it by asking you to verify your contact information and may ask you for information related to your recent interactions with us, such as information about a recent purchase.
Your state of residence may allow you to appoint an authorized agent to exercise these rights on your behalf. Authorized agents may submit requests on behalf of consumers by contacting us at email@example.com. If you use an authorized agent registered with the California Secretary of State to exercise your rights, we may ask you to verify your identity with us directly or confirm with us that the agent otherwise has your permission to submit the request on your behalf.
Your state of residence may also require that we not discriminate against you by treating you different for exercising your rights in connection with your personal information, in such case, we will not discriminate against you if you choose to exercise your rights.
If you are a resident of Colorado, Connecticut, or Virginia, and you make a request to exercise any of the above data access rights and we are unable to comply with your request, you may request to appeal our decision. To appeal any data privacy request decision, please contact us contact us at firstname.lastname@example.org. Indicate in the subject line “Data Access Request Appeal.” You may also contact your Attorney General to file a complaint if you are not satisfied with our handling of your request. Below is the contact information for the appropriate entity for appeal inquiries:
Colorado Residents: Office of the Attorney General, Colorado Department of Law, Ralph L. Carr Judicial Building, 1300 Broadway, 10th Floor Denver, CO 80203
Connecticut Residents: Office of the Attorney General, 165 Capitol Ave, Hartford, CT 06106
Virginia Residents: Office of the Attorney General, 202 North 9th Street, Richmond, Virginia 23219
Phone: (804) 786-2071
CALIFORNIA NOTICE OF FINANCIAL INCENTIVE
We make available various offers and financial incentives to our customers. For example, we provide discounts, special offers and other benefits to individuals who participate in our loyalty programs and we may offer you a discount if you sign up to receive our email newsletters. When you participate in the financial incentives we offer, we collect personal information from you, such as identifiers like your name and email address and commercial information like your purchasing habits. In some cases, additional terms may govern a financial incentive, which we will specify when you sign up. You can opt into the financial incentive or price or service difference by following the instructions provided at sign-up, including submitting the relevant personal information. If you do not wish to opt-in to the financial incentive or price or service difference, do not sign up or submit the requested personal information.
If you subsequently wish to withdraw from the financial incentive or price or service difference, the method for doing so will be explained at the time the personal information is to be submitted, or you may request such withdrawal by contacting us at email@example.com.
Each financial incentive or price or service difference offered is valued based upon our reasonable determination of the estimated value of such personal information submitted, which takes into consideration, without limitation, estimates in respect of the anticipated revenue generated from such information, the anticipated expenses that may be incurred in the collection, storage, and use of such information in the operation of our business, and other relevant factors related to the estimated value of such information to our business, as permitted under the CPRA. The value of your personal information is reasonably related to the value of the discount or benefit presented to you.
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. To opt out of our use of your personal information in this manner, please see the Your Privacy Rights section above. We do not have access to the identity of anybody in the lookalike audience, unless they choose to click on the ads. 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.