PRIVACY POLICY - US

Last updated and effective as of 8 July 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;
  • Engage with us via our Website, via Livechat or via VideoChat;
  • Engage with us via our marketing communications;
  • 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;
  • Engage with you via LiveChat or VideoChat or via our Website;
  • 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 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 customercare@charlottetilbury.com. 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.

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.

CALIFORNIA PRIVACY NOTICE AT COLLECTION:

This Notice at Collection is for California Residents and provides information about the categories of personal information that we collect from California residents, the purposes for which we use the information and the categories of third parties we disclose the information to for business purposes, as required by the CCPA. This Notice supplements our above Privacy Policy and Your California Privacy Rights section, which contains additional information for California residents regarding their rights under the CCPA.

Categories of Personal Information Collected Purposes of Use Categories of third parties we disclose the information to for business and operational purposes
Information needed to identify you

Such as your name, username, password, and date of birth. We may also collect your contact details, such as your email address, telephone 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.
  • Vendors and Service Providers

  • Other companies within the Charlotte Tilbury Group

  • Our Partners

  • Our professional Advisors

  • Entities for legal purposes

To allow you to create an account with us
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.
To allow you to book an appointment with us or to book and attend an event.
So that you can enter contests, sweepstakes or promotions run by us and we can administer the prize.
To communicate with you in relation to your order or booking, or if you raise an enquiry or complaint with us.
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.
To allow you to sign up to a programme or scheme we are offering.
To personalize and customize your experience.
Security and fraud prevention and detection and legal compliance.
Financial and transactional information

Payment details and details of your transactions such as credit or debit card number, verification number, and expiration date. Also information about the transaction such as product details, purchase price, and date and location of transaction

To process payments for your order to complete a purchase, to take payment of your order and, if required, to give refunds.
  • Vendors and Service providers
  • Other companies within the Charlotte Tilbury Group
  • Our partners
  • Our professional advisors
  • Entities for legal purposes
To provide you potential access to any available deferred payment services.
Security and fraud prevention and detection and legal compliance.
To assess whether you are eligible for a loyalty programme
Customer Interaction and Service Information

Information you provide to us when you contact or interact with us by telephone, by email, by post, on social media, via our Website, via LiveChat or via VideoChat or via our marketing communicatons.

The information may include questions, comments and other messages you address to us, your name, your voice, facial image or identity via video and/or voice recordings, your personal preferences and other information you choose to share such as your gender, birthday, skin tone, make-up tone hair color and eye color.

We may collect this information in different ways, including via your account or via your Charlotte Tilbury account or via marketing campaigns to collect additional optional data.

To communicate with you and provide the support and customer service or interaction you have requested.
  • Vendors and Service providers
  • Other companies within the Charlotte Tilbury Group
  • Our partners
  • Our professional advisors
  • Entities for legal purposes
To allow us to provide you with a more personalized beauty experience.
Security and fraud prevention and detection and legal compliance.
Where you complete any surveys or to comment on or review our products or service, to help us to improve them.
Internet network and device information and activity data

Information about your equipment (such as computer, mobile etc.) browsing actions and patterns. This may include IP address, browser type/language, landing pages, device type, platform type; browsing activity, pages viewed, content/ads viewed and clicked (on our website, app and marketing), search terms, uploads/downlads, referral and exit URLs and other web activity/data logged by our web servers.

We collect this personal data by using cookies and similar technologies – for further information see our Cookie Policy.

To administer and to improve the effectiveness of our Website and marketing.
  • Vendors and Service providers
  • Other companies within the Charlotte Tilbury Group
  • Our partners
  • Marketers
  • Our professional advisors
  • Entities for legal purposes
To enable you to participate in interactive features of our Website and marketing if you choose to do so.
Data analysis, testing, research and statistical statistics to help us to improve our products and services.
Security and fraud prevention and detection and legal compliance.
To personalize your experience and customize services to you.
To measure and improve the effectiveness of marketing and advertising we serve
To identify behavioural flows from emails we send to you, so that we are able to monitor and analyse the effectiveness of those emails
Photographs of you, where you choose to provide them to us. For use on the Charlotte Tilbury website and, social media channels or other locations notified to you, for marketing purposes and product recommendations.
  • Vendors and Service providers
  • Other companies within the Charlotte Tilbury Group
  • Our partners
  • Marketers
  • Our professional advisors
  • Entities for legal purposes
Social media information

Where you engage with us via social media (including comments, direct messages, likes, sharing content), or have provided us your social media handle to participate in a Charlotte Tilbury program or similar.

We may have access to information you provide via that social network (subject to your privacy settings) such as your name, username, profile picture and other images, gender, your “likes” and check-ins, your list of friends, your comments. We will also collect information from you if you interact with our pages on social networking sites (e.g., Facebook, Instagram, Twitter).

Enable us to identify and view your social media account(s)
  • Vendors and Service providers
  • Other companies within the Charlotte Tilbury Group
  • Our partners
  • Marketers
  • Our professional advisors
  • Entities for legal purposes
  • Other social media visitors (who may see your content)
Provide our services and customer services to you.
Improve, personalize and customize your experience and the services we provide.
Understand your preferences and engage in research, analysis, and reports
Our marketing and advertising purposes
Security and fraud prevention and detection and legal compliance.

CALIFORNIA NOTICE OF FINANCIAL INCENTIVE:

If you are a California resident, you have a right to receive this Notice of Financial Incentive, as defined in the CCPA. This Notice is to provide you with information regarding any financial incentive or “price or service difference” that we may provide in exchange for your personal information. All terms used in this Notice are as defined in the CCPA or applicable regulations thereunder.

We make available various offers and financial incentives to our customers. When you participate in such offers and use our services, you may provide personal information from time to time, directly or indirectly, in exchange for a financial incentive or price or service difference. These include our Pro Artist Program, our loyalty scheme(s) and other opportunities to receive a discount, reward or other financial incentive or price or service difference where you provide us personal data. The terms of and amount or nature of such incentive will be specified in each instance at the time the personal information is to be submitted. This will include the categories of personal information involved.

You can opt into the financial incentive or price or service difference by submitting the personal information. If you do not wish to opt-in to the financial incentive or price or service difference, do not submit the personal information.

In some instances, you may have the opportunity to provide personal information on an ongoing basis in exchange for a financial incentive or price or service difference on an ongoing basis, the amount or nature of which will be specified in each instance at the time the personal information is to be submitted. You can opt-in to the financial incentive or price or service difference by submitting the 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 customercare@charlottetilbury.com. For more information see the “Your Choices” section of our Privacy Policy. 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 CCPA.

Contact Us

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