How do we collect or receive your data?

We might collect, record, hold, store, use, disclose, receive and/or process (collectively referred to as "Process") Personal Data from you via our websites, forms, apps, devices, L’Oréal products or brands pages on social media or otherwise. Sometimes you may give this to us directly (e.g. when you create an account, when you contact us, when you purchase from our websites/apps or stores/beauty salon), sometimes we collect it indirectly (e.g. using cookies to understand how you use our websites/apps), or sometimes we receive your Personal Data from other third parties, including other L’Oréal Group entities.

When we collect data, we indicate the mandatory fields via asterisks where such data is necessary for us to:

- Perform our contract with you (e.g. to deliver the products you have purchase on our websites/apps);
- Provide you with the service you have asked for (e.g. to provide you with a newsletter); or
- Comply with legal requirements (e.g. invoicing).

If you do not provide the data marked with an asterisk, this may affect our ability to provide the products and services.

We set out further details in the table below, explaining:

1. During what interaction your data may be provided or collected? This column explains what activity or situation you are involved in when we use or collect your data. For example, whether you are making a purchase, signing up to a newsletter, or browsing a website/app.
2. What personal data may we receive from you directly or resulting from your interaction with us? This column explains what types of data we may collect about you depending on the situation.
3. How and why we may use it? This column explains what we may do with your data and the purposes for collecting it.
4. What is the legal basis for using your personal data? This column explains the reason we may use your data.

Depending on the purpose for which the data is used, the legal basis for the processing of your data can be:

• Your consent;
• Our legitimate interest, which can be:
• Improvement of our products and services: more specifically, our business interests to help us better understand your needs and expectations and therefore improve our services, websites / Apps / devices, products and brands for our consumers’ benefit.
• Fraud prevention: to ensure payment is complete and free from fraud and misappropriation .
• Securing our tools: to keep tools used by you (our websites/Apps/devices) safe and secure and to ensure they are working properly and are continually improving.
• The performance of a contract: more specifically to perform the services you request from us;
• Legal grounds where a processing is required by law.

During which interactions may you provide and we may collect your data?	What personal data may we receive from you directly or resulting from your interaction with us?	How and why we may use your data ?	What is the legal basis for using your personal data?
Account Creation and management Information collected during the creation of an account on L’Oréal websites/apps, through a social media login, or in store.	Depending on how much you are interacting with us, those data may include: Name and surname; Gender; Email address; Address; Phone number; Photo; Birthday or age range; ID, username, and password; Personal description or preferences; Order details; Social media profile (where you use social login or share this personal data with us).	To: Manage your orders; Manage any competitions, promotions, surveys or contests you choose to enter; Respond to your questions and otherwise interact with you ; Offer you a loyalty program; Allow you to manage your preferences;	Performance of a contract: To provide you with the service you requested (e.g. create an account, complete a survey, or purchasing a product).
		Send you marketing communications (where you have asked us to) which may be tailored to your “profile” (i.e. based on the personal data we know about you and your preferences);	Consent To send you direct marketing communications.
		Offer personalized services based on your beauty characteristics; Monitor and improve our websites/apps ; Run analytics or collect statistics Secure our websites/apps and protect you and us against fraud;	Legitimate Interest To ensure our websites/apps remain secure, to protect them against fraud, and to help us better understand your needs and expectations and therefore improve our services, products and brands.
Newsletter and commercial communications subscription	Depending on how much you are interacting with us, those data may include: Email address; Name and surname; Personal description or preferences; Social media profile (where you use social login or share this personal data with us);	To: Send you marketing communications (where you have asked us to) which may be tailored to your “profile” based on the personal data we know about you, and your preferences (incl. location of your favorite store);	Consent To send you direct marketing communications.
		Run analytics or collect statistics.	Legitimate Interest To tailor our marketing communications, understand their effectiveness, and ensure you receive the most relevant experience; to help us better understand your needs and expectations and therefore improve our services, products and brands.
		Keep an up to date suppression list if you have asked not to be contacted;	Legal grounds To keep your details on a suppression list if you have asked us not to send you any direct marketing anymore.
Purchases and order management Information collected during the purchase process made on L’Oréal website/apps/social pages or in store	Depending on how much you are interacting with us, those data may include: Name and surname; Email address; Address (delivery and invoicing); Phone number; Personal description or preferences; Social media profile (where you use social login or share this personal data with us); Transaction information including purchased products and store location; Payment and information; or Purchase history	To Contact you to finalize your order where you have saved your shopping cart or placed products in your cart without completing the checkout process; Inform you when a product you wanted to purchase is available; Process and follow your order including delivering the product to the address you indicated; Manage the payment of your order. To be noted, payment information (credit card number / Paypal information / bank account details) are not collected by us but directly by payment service providers; Manage any contact you have with us regarding your order;	Performance of a contract: To provide you with the service you requested (purchase).
		Secure the transactions against fraud. To be noted, we use a third party provider’s solution to detect fraud and ensure the payment is complete and made by you or someone authorized by you; Enrich your profile if you place a purchase using your account information; Measure satisfaction; Manage any dispute relating to a purchase; For statistics purposes.	Legitimate interest To protect you and us from fraudulent transaction and to ensure the payment is complete and free from fraud and misappropriation.
Online browsing Information collected by cookies or similar technologies (“Cookies”*) as part of your browsing on L’Oréal website/apps and/or on third-party website/apps. For information on specific Cookies placed through a given website/app, please consult the relevant cookie table. * Cookies are small text files stored on your device (computer, tablet or mobile) when you are on the Internet, including on L’Oréal Group’s websites.	Depending on how much you are interacting with us, those data may include: Data related to your use of our websites/apps: Where you came from; Login details; Pages you looked at; Videos you watched; Ads you click on or tap; Products you search for; Your location; Duration of your visit; Products you selected to create your basket. Technical information: IP address; browser information; device information. A unique identifier granted to each visitor and the expiration date of such identifier.	We use Cookies, where relevant, with other personal data you have already shared with us (such as previous purchases, or whether you’re signed up to our email newsletters) or the following purposes: To allow proper functioning of our website/apps: ○ proper display of the content; ○ creation and remembering of a cart; ○ creation and remembering of your login; ○ interface personalisation such as language; ○ parameters attached to your device including your screen resolution, etc; ○ improvement of our websites/apps, for example, by testing new ideas. To ensure the website/app is secure and safe and protect you against fraud or misuse of our websites or services, for example through performing troubleshooting. To run statistics: ○ To avoid visitors being recorded twice; ○ To know users’ reaction to our advertising campaigns; ○ To improve our offers; ○ To know how you discovered our websites / apps.	Legitimate interest: To ensure we are providing you with websites/apps, advertising and communications that are working properly and are continually improving for cookies that are (i) essential for the functioning of our websites/apps, (ii) used to keep our websites/apps safe and secure.
		To deliver online behavioural advertising: ○ to show you online advertisements for products which may be of interest to you, based on your previous behaviour; ○ to show you ads and content on social media platforms. To tailor our services for you: ○ to send you recommendations, marketing, or content based on your profile and interests; ○ to display our websites/apps in a tailored way like remembering your cart or login, your language, the user-interface customization cookies (i.e. the parameters attached to your device including your screen resolution, font preference, etc). To allow sharing of our content on social media (sharing buttons intended to display the site).	Consent For all other cookies.
Promotional operations Information collected during a game, contests, promotional offer, sample requests, surveys.	Depending on how much you are interacting with us, those data may include: Name and surname; Email address; Phone number; Birth date; Gender; Address; Personal description or preferences; Social media profile (where you use social login or share this personal data with us); Other information you have shared with us about yourself (e.g. via your “My Account” page, by contacting us, or by providing your own content such as photos or a review, or a question via the chat function available on some websites/apps, or by participating in a contest, game, survey).	To complete tasks that you have asked us to, for example to manage your participation in contests, games and surveys, including to take into account your feedback and suggestions;	Performance of contract To provide you with the service you requested.
		For statistics purposes.	Legitimate Interest To help us better understand your needs and expectations and therefore improve our services, products and brands.
		To send you marketing communications (where you have asked us to)	Consent To send you direct marketing communications.
User Generated Content Information collected when you submitted some content on one of our social platforms or accepted the re-use of content you posted on social media platforms by us.	Depending on how much you are interacting with us, those data may include: Name and surname or alias; Email address; Photo; Personal description or preferences; Social media profile (where you use social login or share this personal data with us); Other information you have shared with us about yourself (e.g. via your “My Account” page, by contacting us, or by providing your own content such as photos or a review, or a question via the chat function available on some websites/apps).	In accordance with the specific terms and conditions accepted by you: ○ To post your review or content; ○ To promote our products.	Consent To reuse the content you posted online.
		For statistics purposes.	Legitimate interest To help us better understand your needs and expectations and therefore improve and promote our services, products and brands.
Use of Apps and devices Information collected as part of your use of our Apps and/or devices.	Depending on how much you are interacting with us, those data may include: Name and surname; Email address; Location; Birth date; Personal description or preferences; Photo; Welfare data including skin tone, skin/hair type Geolocation.	To Provide you with the service requested (for example, virtually test our products, purchase our products through the App or on related e-com websites; advice and notifications regarding your sun exposure, your hair routine); Analyse your welfare characteristics and recommend the appropriate products (including bespoke products) and routines; Provide you product & routine recommendations;	Performance of a contract To provide you with the service requested (including, where needed, analysis by the research and innovation team of the algorithm necessary to provide the service).
		For research and innovation by scientists within L’Oréal Group; For monitoring and improvement of our Apps and devices; For statistics purposes.	Legitimate interest To always improve our products and services to match your needs and expectations and for research and innovation purposes.
Enquiries Information collected when you ask questions (e.g. through our consumer care) relating to our brands, our products and their use.	Depending on how much you are interacting with us, those data may include: Name and surname; Phone number; Email address; Other information you have shared with us about yourself in relation to your enquiry (which may include welfare and health data).	To answer your enquiries; Where needed, to connect you with the relevant services	Consent To process your enquiry.
		For statistics purposes;	Legitimate Interest To help us better understand our customers’ needs and expectations and therefore improve our services, products and brands.
		For Cosmétovigilance: ○ To monitor and prevent any undesirable effect linked to the use of our products; ○ To perform studies relating to the safe use of our products; ○ To perform and follow-up on corrective measures taken, where needed.	Legal grounds To comply with the legal obligation to monitor undesirable effects of its products.
Sponsorship	Depending on how much you are interacting with us, those data may include: Name and surname; Phone number; Email address;	To send information on our products and or information tagged in a wish list to a person at another person’s request.	Performance of a contract To process the request. And Legitimate Interest To contact the person at another person’s request.

Automated Decision Making

For purposes of securing transactions placed through our websites/apps/devices against fraud and misappropriation, we use third party provider’s solution(s).The method of fraud detection is based on, for example, simple comparisons, association, clustering, prediction and outlier detections using intelligent agents, data fusion techniques and various data mining techniques.

This fraud detection process may be completely automated or may involve human intervention where a person takes the final decision. In any case, we take all reasonable precautions and safeguards to limit access to your data.

As a result of automatic fraud detection, you may (i) experience delay in the processing of your order / request whilst your transaction is being reviewed by us; and (ii) be limited or excluded from the benefit of a service if a risk of fraud is identified. You have the right to access information on which we base our decision. Please see “Your Rights and Choices” section below.

Profiling

When we send or display personalised communications or content, we may use some techniques qualified as “profiling” (i.e. any form of automated processing of personal data consisting of using those data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s personal preferences, interests, economic situation, behaviour, location, health, reliability, or movements). This means that we may collect personal data about you in the different scenarios mentioned in the table above. We centralize this data and analyse it to evaluate and predict your personal preferences and/or interests.

Based on our analysis, we send or display communications and/or content tailored to your interests/needs.

You have the right to object to the use of your data for “profiling” in certain circumstances. Please see “Your Rights and Choices” section below.

Who may access your Personal data?

We may share your personal data within L’Oréal Group to comply with our legal obligations, to prevent fraud and/or to secure our tools, to improve our products and services, or after having obtained your consent to do so.

Depending on the purposes for which they were collected, and only on a need-to-know basis some of your personal data may be accessed by L’Oréal Group entities worldwide, where possible in a pseudonimized way (not allowing direct identification), and where necessary to provide you with requested services.

We may also share your personal data in a pseudonimized way (not allowing direct identification) with L’Oréal Research & Innovation scientists, including those located outside of your country, for research and innovation purposes.

Where permitted, we may also share some of your personal data including those collected through Cookies between our brands to harmonize and update the information you share with us, to perform statistics based on your characteristics and to tailor our communications.

Please visit the L’Oréal group website, for further details on the L’Oréal Group, its brands and its locations.

We may share your personal data for marketing purposes with third party (whether within or outside of the United Arab Emirates/your country of residence) or entities of the L’Oréal Group.

We only share your personal data with third parties for direct marketing purposes with your consent. In this context, your data is processed by such third party, acting as a data controller, and its own terms and conditions and privacy notice apply. You should carefully check their documentation before consenting to the disclosure of your information to that third party.

Your personal data may also be processed on our behalf by our trusted third party providers (whether within or outside of the United Arab Emirates/your country of residence):

We rely on trusted third parties to perform a range of business operations on our behalf. We only provide them with the information they need to perform the service, and we require that they do not use your personal data for any other purpose. We always use our best efforts to ensure that all third parties we work with keep your personal data secure. For instance, we may entrust services that require the processing of your personal data to:

• Third parties that assist and help us in providing digital and e-commerce services such as social listening, store locator, loyalty programs, identity management, ratings and reviews, CRM, web analytics and search engine, user generated content curation tools;
• Advertising, marketing, digital and social media agencies to help us to deliver advertising, marketing, and campaigns, to analyse their effectiveness, and to manage your contact and questions;
• Third parties required to deliver a product to you e.g. postal/delivery services;
• Third parties that assist and help us in providing IT services, such as platform providers, hosting services, maintenance and support on our databases as well as on our software and applications that may contain data about you (such services could sometimes imply access to your data to perform the required tasks);
• Payment service providers and credit reference agencies for the purpose of assessing your credit score and verifying your details where this is a condition of entering into a contract with you;
• Third parties that assist us for customer care and cosmetovigilance purposes.
• Third parties that provide us with consulting services in the field of market research and analytics, collect feedback and conduct market surveys on our products, services and otherwise for customer relationship management purposes.
• Third Parties Providing Services On Our Behalf: We share information with third party service providers fulfilling the above purposes on our behalf, including service providers that host or assist with technical operation of our Sites; information technology vendors that provide information technology services; analytics, and research vendors; fraud prevention, legal, compliance, and risk management vendors; order processing fulfilment vendors who process orders, transactions and payments, provide customer service, loyalty program administration, and redemption services; marketing and advertising vendors, social media, or other third parties that participate in or administer our promotions, contests, sweepstakes, surveys or provide marketing or promotional assistance. We may also share information with third parties to help us identify your online preferences, including the ads with which you interact. This data may be matched with information that we process about you to provide a better experience using our websites and products. Categories of Information shared include identifiers, internet or network activity, geolocation data, purchasing information, protected classifications, professional or employment-related information, audio-visual information, geolocation information, payment information, and inferences generated from the foregoing categories of information.

We may also disclose your personal data to third parties (whether within or outside of the United Arab Emirates/your country of residence):

• In the event that we sell any business or assets, in which case we may disclose your personal data to the prospective buyer of such business or assets. If L’Oréal or a part of its assets is acquired by a third party, personal data held by it about its customers relating to those assets is one of the transferred assets. Where appropriate, in such case, the buyer acting as the new data controller processes your data and its privacy policy governs the processing of your personal data.
• If we are under a duty to disclose or share your personal data in order to comply with a legal obligation, or in order to enforce or apply our terms of use/sales or other terms and conditions you have agreed to; or to protect the rights, property, or safety of L’Oréal, our customers, or employees.
• If we have your consent to do so
• Or if we are permitted to do so by law.

We may disclose your personal data to our partners (whether within or outside of the United Arab Emirates/your country of residence):

• In the event the service you subscribe to was co-created by L’Oréal and a partner (for example, a co-branded app). In such case, L’Oréal and the partner process your personal data each for their own purposes and as such your data is processed:
  
• By L’Oréal in accordance with this Privacy Policy;
• By the partner acting also as a data controller under its own terms and conditions and in accordance with its own privacy policy.
• In the event you agreed to receive marketing and commercial communications from a L’Oréal partner through a dedicated opt-in (for instance, through an App branded by L’Oréal and made available to its partners). In such case, your data is processed by the partner acting as a data controller under its own terms and conditions, and in accordance with its privacy policy.
• We may publish on our supports content from social networks. In the event you consult content from social networks on our website/apps, a Cookie from such social network may be stored on your device. We invite you to read the Cookie Policy of these social networks for more information.

We do not offer or sell your personal data.

When we use Google advertising services on our websites / apps, Google will access and use your Personal Data. If you wish to learn more on how Google uses your Personal Data in this context, please consult their Google Privacy & Terms available here which govern these services and data processing.

Information that Facebook collects and share with us

All Facebook features and services available on our website/app are governed by the Facebook Data Policy, in which you can get more info about your privacy rights and settings options. By using this website/app, you may:

• sign-up with your Facebook login. If you do so, you consent to share some of your public profile information with us;
• use the Facebook social plug-ins, such as “like” or “share” our content on the Facebook platform;
• accept cookies from this website/app (also identified as “Facebook Pixel”) that will help us understand your activities, including information about your device, how you use our services, the purchase you make and the ads you see, whether or not you have a Facebook account or are logged into Facebook.

When you’re using those Facebook features, we collect data that help us to:

• show you adds you might be interested in on Facebook (or Instagram, Messenger or any other Facebook services);
• measure and analyze the effectiveness of our website/app and adds.

We may also use the personal information you gave us on this website/app (such as your name and surname, email, address, gender and phone number) to identify you in Facebook (or Instagram, Messenger or any other Facebook services) in order to show you adds that are even more relevant for you. While doing this, Facebook will not share your personal information and will delete the information promptly after the match process is complete.

Where we Store your Personal Data

The data that we collect from you may be transferred to, accessed from, and stored at a destination outside the United Arab Emirates or your country of residence. It may also be processed by staff members operating outside the United Arab Emirates or your country of residence who work for us or for one of our service providers.

L’Oréal transfers personal data outside of the United Arab Emirates or your country of residence only in a secure and lawful way. As some countries may not have laws governing the use and transfer of personal data, we take steps to make sure that third parties adhere to the commitments set out in this Policy. These steps may include reviewing third parties’ privacy and security standards and/or entering into appropriate contracts.

For further information, please contact us as per the “Contact” section below.

How Long Do We Keep Your Personal Data

We only keep your personal data for as long as we need it for the purpose for which we hold your personal data, to meet your needs, or to comply with our legal obligations.
To determine the data retention period of your data, we use the following criteria:

• Where you purchase products and services, we keep your personal data for the duration of our contractual relationship;
• Where you participate in a promotional offer, we keep your personal data for the duration of the promotional offer;
• Where you contact us for an enquiry, we keep your personal data for the duration needed for the processing of your enquiry;
• Where you create an account, we keep your personal data until you require us to delete it or after a period of inactivity (no active interaction with Brands) defined in accordance with local regulations and guidance;
• Where you have consented to direct marketing, we keep your personal data until you unsubscribe or require us to delete it or after a period of inactivity (no active interaction with Brands) defined in accordance with local regulations and guidance;
• Where cookies are placed on your computer, we keep them for as long as necessary to achieve their purposes (e.g. for the duration of a session for shopping cart cookies or session ID cookies) and for a period defined in accordance with local regulations and guidance.

We may retain some personal data to comply with our legal or regulatory obligations, as well as to allow us to manage our rights (for example to assert our claims in Courts) or for statistical or historical purposes.

When we no longer need to use your personal data, it is removed from our systems and records or anonymised so that you can no longer be identified from it.

Is Your Personal Data Secure?

We are committed to keeping your personal data secure, and taking all reasonable precautions to do so. We contractually require that trusted third parties who handle your personal data for us do the same.

We always do our best to protect your personal data and once we have received your personal data, we use strict procedures and security features to try to prevent unauthorised access. As the transmission of information via the internet is not completely secure, we cannot guarantee the security of your data transmitted to our site. As such, any transmission is at your own risk.

Links to Third Party Sites and Social Login

Our websites and Apps may from time to time contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we are not responsible or liable for these policies. Please check these policies before you submit any personal data to these websites.

We may also offer you the opportunity to use your social media login. If you do so, please be aware that you share your profile information with us depending on your social media platform settings. Please visit the relevant social media platform and review its privacy policy to understand how your personal data is shared and used in this context.

Social Media and User Generated Content

Some of our websites and Apps allow users to submit their own content. Please remember that any content submitted to one of our social media platforms can be viewed by the public, so you should be cautious about providing certain personal data e.g. financial information or address details. We are not responsible for any actions taken by other individuals if you post personal data on one of our social media platforms and we recommend that you do not share such information.