PRIVACY POLICY - US

Last updated and effective as of 31 January 2020

This Privacy Policy explains how Charlotte Tilbury Beauty Inc. (“Charlotte Tilbury,” “we,” or “us”) collects, uses, and discloses information about you when you access or use www.charlottetilbury.com/us, visit our US stores, or otherwise interact with us from the US. Please note that we provide different or additional privacy notices in connection with certain activities, programs, and offerings. For more information about our privacy practices in another jurisdiction, please refer to the privacy policy posted on our website, for that jurisdiction.

If you have any questions about this Privacy Policy or our information practices, please contact us at legal@charlottetilbury.com.

We will update this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification). We encourage you to review this Privacy Policy whenever you access our website or otherwise interact with us to stay informed about our information practices and the choices available to you.

About us

This Privacy Policy is provided by Charlotte Tilbury Beauty Inc. We are responsible for the Charlotte Tilbury US website (www.charlottetilbury.com) and any orders placed by customers on this website or in our US Charlotte Tilbury stores.

When you place an order on our website, you are contracting with Charlotte Tilbury Beauty Inc., but we are part of a wider group of Charlotte Tilbury companies across the globe. This includes companies in the UK, Canada, the Netherlands, Germany, and Hong Kong. When we refer to the “Charlotte Tilbury Group,” we are referring to the wider family of Charlotte Tilbury companies.

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

Our retail partners

You can purchase Charlotte Tilbury products and services via our retail partners across the US, including at select Sephora, Bloomingdales and Nordstrom stores (our “Retail Partners”). When you purchase Charlotte Tilbury products or services through a Retail Partner online or in one of their stores, you are contracting directly with that Retail Partner and not with us. Any personal information you provide to the Retail Partner will be managed by the Retail Partner and governed by its privacy policy. If you have questions about how our Retail Partners collect, use, and disclose information, you must contact them directly.

Collection of Personal Information

When you use our website, visit our stores, or otherwise interact with us, we collect information from and about you. Some of this information may be considered “personal information,” meaning it identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to you or your household. We also collect, use, and disclose aggregated or de-identified data that cannot reasonably be used to identify you and is not subject to this Privacy Policy.

Personal Information You Provide to Us

We collect personal information directly from you in a variety of ways. For example, we collect information when you:

  • 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 Programme;
  • 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;
  • 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, and any other information you choose to provide.

Automatically Collected Personal Information

We automatically collect personal information when you access and use our website or transact business with us in our stores, including:

  • 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

We may collect personal information about you from other sources. For example, we may collect personal information about you from:

  • 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

We collect and use personal information to provide, maintain and improve our products and services and to:

  • 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;
  • Provide advertising and marketing targeted toward your interests;
  • 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

We may share personal information about you as follows or otherwise described in this Privacy Policy:

  • 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.
  • When you write product reviews on our website.
  • With your consent or at your direction.

Your choices

You have options in relation to the personal information we collect about you, as described below.

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 by following the unsubscribe instructions in those emails. You may also unsubscribe by going to the Account Information page on the Charlotte Tilbury website, clicking on “Newsletters,” and unsubscribing from that page. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relationship.

Cookies

For detailed information about the cookies we use and the purposes for which we use them, see our Cookie Policy. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

Advertising and Analytics Services Provided by Others

We may allow others to provide analytics services and serve advertisements on our behalf across the web. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of our website and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by Charlotte Tilbury and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our website and other websites, and better understanding your online activity. For more information about interest-based ads, or to opt out of having your web browsing activity used for behavioral advertising purposes, please visit www.aboutads.info/choices.

We may also work with third parties to serve ads to you as part of a customized campaign on third-party platforms (such as Facebook, Snapchat or Instagram). As part of these ad campaigns, we or third-party platforms 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 customized to your interests. Note that the third-party platforms may offer you choices about whether you see these types of customized ads.

Your California Privacy Rights

Consumers residing in California are afforded certain additional rights with respect to their personal information under the California Consumer Privacy Act (“CCPA”). If you are a California resident, this section applies to you.

Collection and Use of Personal Information: In the preceding 12 months, we have collected the following categories of personal information: identifiers, characteristics of protected classifications under California or U.S. law, commercial information, internet and electronic network activity, audio and visual information, biometric information, inferences drawn about you, and other categories of personal information that relates to or is reasonably capable of being associated with you. For examples of the precise data points we collect and the sources of collection, please see “Collection of Personal Information” and “Personal Information We Collect from Third Parties”. We collect personal information for the business and commercial purposes described in the “Use of Your Personal Information” section above.

Disclosure of Personal Information: We may share the categories of personal information listed above with third parties as described in the “Sharing of Information” section.

Sale of Personal Information: California law requires that we provide transparency about personal information we “sell,” which for purposes of the CCPA broadly means scenarios in which we have shared personal information with third parties or partners in exchange for valuable consideration. Charlotte Tilbury does not, and will not, sell your identifying information (such as your name, email address, phone number, or postal address); however, we do allow our advertising partners to use cookies and other technologies to collect personal information about you in order to show ads that are targeted to your interests. In order to opt out of having your personal information used for targeted advertising purposes, please see “Advertising and Analytics Services Provided by Others” above.

Your Rights: Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories and specific pieces of personal information we collect, to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights. If you are a California resident, you may make these requests by calling +1-855-528-8495 or visiting this page. Once we receive your request, we will verify it by asking you to provide contact information and information related to your recent interactions with us. If you would like to use an authorized agent to exercise your rights, we may request evidence that you have provided the agent with power of attorney or that the agent otherwise has valid written authority to submit requests on your behalf. We will not discriminate against you if you choose to exercise your rights under the CCPA.

Contact Us

If you have questions regarding this Privacy Policy, you can contact us at legal@charlottetilbury.com.