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The Cosmetics Companies Store


UNITED KINGDOM AND REPUBLIC OF IRELAND CONSUMER PRIVACY POLICY

Last Update: 21st September, 2023

The Estée Lauder Companies respects your privacy and values the relationship we
have with you.

The Estée Lauder Companies has a diverse portfolio of prestige brands, including
The Cosmetics Company Store. You can find a list of these brands on
ELCompanies.co.uk, each referred to in this Privacy Policy as a “Brand”.

This Privacy Policy describes how our Brands in the United Kingdom and Republic
of Ireland collect, use, disclose and safeguard your personal information.
Unless otherwise indicated, all Brands in the United Kingdom and Republic of
Ireland follow this Privacy Policy.

References in this Privacy Policy to “we”, “us”, “our”, “ELC” are references to
the entity or entities in the United Kingdom responsible for establishing the
purposes for the processing of your personal information. See the Data
Controller section below for details.


TABLE OF CONTENTS

 * Information we process
 * How we collect information
 * How we use information
 * Our legal basis for processing personal information
 * How we share information
 * How you control your information
 * How we use cookies
 * How we use information to advertise
 * International transfers
 * How we protect information
 * How long we retain information
 * How we treat children’s information
 * Updates to our privacy policy
 * Your data controller
 * How to contact us


INFORMATION WE PROCESS

We may collect or process the following types of information about you. The
specific information we collect about you will vary depending on how you
interact with us.

 * Personal identifiers and contact information, such as your name, address,
   email address, telephone number, and username or social media handle.
 * Device identifiers, such as information about your device like your MAC
   address, IP address, or other online identifiers.
 * Demographic information, such as your age or date of birth, sex, and gender.
 * Physical characteristics, such as your hair type and colour, skin type, eye
   colour, and facial geometry if you use certain of our virtual try-on
   applications.
 * Commercial and transactional information, such as the products or services
   you have purchased and the location of purchase, products returned or
   considered and your product preferences.
 * Payment information, such as your method of payment and payment card
   information (including payment card number, delivery address and billing
   address).
 * Identity verification information, such as photo identification for in-store
   pick-ups at one of our retail stores, loyalty member ID, and authentication
   information (like passwords).
 * Online or network activity information, such as information regarding your
   interaction with our websites, mobile applications, digital properties and
   advertisements, information about your browsing and search history on our
   websites or mobile applications and log file information like your browser
   type and webpages you visit.
 * Geolocation information, such as information that can help identify your
   physical location (like your GPS coordinates or the approximate location of
   your device).
 * Audio and visual information, such as recordings of your voice when you call
   our customer service and images we record through video surveillance in our
   retail stores.
 * Professional or employment-related information, such as professional licenses
   or certifications in connection with our professional programs.
 * Health and medical information, such as skincare concerns or condition,
   diagnoses, medical reports and history.
 * User Content, such as your communications with us and any other content you
   provide (including photographs and images, videos, reviews, articles, survey
   responses and comments).
 * Inferences drawn from or created based on any of the information identified
   above, such as derived ethnicity and household income range.


HOW WE COLLECT INFORMATION

We may collect personal information about you from various sources. For example:

 * Directly from you, such as when you make a purchase on one of our websites or
   in one of our retail stores, contact us with a question or complaint, use one
   of our mobile applications or virtual try on experiences, create an account
   on one of our websites, register for one of our brand loyalty programs or
   marketing lists, respond to a survey, participate in a contest or other
   promotion, make an appointment or sign-up to attend an event.
 * From your friends or family members, such as when your friend or family
   member sends you a gift or makes a referral. If you are submitting contact
   information of others, please ensure that you only submit information of
   individuals with whom you have a personal or family relationship and who have
   consented to such sharing.
 * When you interact with our websites or emails. When you visit our websites,
   or when you open or click on emails we send you, we (and third parties we
   work with) may automatically collect information from your browser or device,
   such as device identifiers and online and other network activity information
   using technologies such as cookies, pixel tags, and similar technologies.
   Cookies are small text files that websites place on your Internet-connected
   device to uniquely identify your browser or to store information or settings
   in your browser. Pixel tags are small images which are embedded into our
   websites or emails. We use pixel tags to collect information about your
   browser or device, how you interact with our websites, or whether you open or
   click on the emails we send you. Pixel tags also enable us (and third parties
   we work with) to place cookies on your browser.
 * Through in-store and other offline technologies, such as video surveillance,
   traffic counting devices and Wi-Fi technology in and around our retail
   stores, and call recording technology when you speak to customer service.
 * From our business partners and service providers, such as demographic
   companies, analytics providers, advertising companies and networks,
   third-party retailers or distributors, loss prevention services and other
   third parties that we choose to collaborate or work with.
 * From social media platforms and networks, such as Facebook, Instagram,
   Twitter, Pinterest, and Google. For example, we may obtain your information
   from a social media platform or network if you interact with us on social
   media or choose to log-in to our websites using your social media
   credentials.
 * From other ELC Brands that you have interacted with.

We may combine the information we obtain from the above sources. For example, we
may combine information we collect in our stores with information we collect
online.


HOW WE USE INFORMATION

We may use the information we have about you:

 * To provide products and services to you, such as fulfilling orders and
   processing payments; creating, servicing and/or maintaining your account or
   loyalty program membership; identifying concerns and assisting with product
   recommendations; and facilitating product reviews. To communicate with you,
   including to respond to your inquiries or complaints, and to help you place
   an order.
 * To administer your participation in special events, contests, sweepstakes,
   surveys or promotions.
 * For marketing and advertising, such as to send you postal mail, text
   messages, email, push notifications or other messages, show you
   advertisements for products and/or services tailored to your interests or
   profile on social media and other websites.
 * To operate and understand your use of our websites and mobile applications,
   such as to remember your information so you do not have to re-enter it,
   understand your preferred method of purchasing with us; determine what
   browser and devices you use to visit our websites or mobile applications; and
   to evaluate and improve our services, advertisements, websites, and mobile
   applications. For example, we use Google Analytics on our websites. For
   specific details on how Google collects and uses your personal information
   when we use its services, please visit: How Google Uses Information From
   Sites Or Apps That Use Our Services.
 * To operate and improve our business, including to conduct analytics, provide
   quality assurance and process adverse event or product-related claims,
   conduct research and development, and perform accounting, auditing and other
   internal business functions.
 * For legal and security purposes, such as to detect, prevent, and prosecute
   harmful, fraudulent, or illegal activity or activity that violates our
   policies, terms and conditions; loss prevention; identify and repair bugs on
   our websites or mobile applications; and to comply with applicable legal
   requirements, relevant industry standards and our policies.

We also may use your information in other ways for which we provide specific
notice at the time of collection.


OUR LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION

Where required by law, we will use the information you provide for the above
purposes if:

 * it is necessary to perform a contract to which you are party (e.g., to
   process your payment and fulfil your order);
 * we have obtained your consent (e.g., for marketing communications);
 * we have a legitimate interest in doing so (including a legitimate interest in
   performing marketing activities, video surveillance, research activities,
   data analytics, internal administration functions, or for fraud prevention
   purposes, enforcement of adherence to our policies, terms and conditions, and
   conducting our business in compliance with relevant industry standards and
   our policies); or
 * we need to comply with a legal obligation under applicable laws.


HOW WE SHARE INFORMATION

We may share your personal information with:

 * Our Brands. When you interact with a Brand, we may share your personal
   information with other Brands. Those other Brands may use your personal
   information for marketing and advertising and other purposes identified in
   this Privacy Policy.
 * Our Subsidiaries and Affiliates. We may transfer your personal information to
   our subsidiaries and affiliates on a need-to-know basis for the purposes
   identified in this Privacy Policy.
 * Service providers. We may transfer personal information to service providers
   who perform services on our behalf based on our instructions. We do not
   authorise these service providers to use or disclose the information except
   as necessary to perform services on our behalf or comply with legal
   requirements. Examples of these service providers include entities that
   process credit card payments, fulfil orders, track and investigate
   contraventions of our policies, terms and conditions, and that provide
   website and application functionality, hosting, analytics, advertising and
   marketing services.
 * Parties to a corporate transaction. We also reserve the right to transfer
   personal information we have about you in the event we sell or transfer all
   or a portion of our business or assets (including in the event of a merger,
   acquisition, joint venture, reorganisation, divestiture, dissolution, or
   liquidation).
 * Advertising Companies. We work with third party advertising companies (such
   as advertising networks) to serve advertisements on our behalf. For
   additional information, see the How We Use Information to Advertise section.
 * Other third parties. In addition, we may disclose personal information about
   you (i) if we are required to do so by law or legal process, (ii) to law
   enforcement authorities or other government officials, (iii) when we believe
   disclosure is necessary or appropriate to prevent physical harm or financial
   loss, or in connection with an investigation of suspected or actual
   fraudulent or illegal activity, (iv) when disclosure of your personal
   information is otherwise required or permitted by law, or (v) with your
   consent (such as third-party salons and spas).


HOW YOU CONTROL YOUR INFORMATION

You have rights and choices in connection with the personal information we have
about you.

 * Data Subject Rights: Depending on applicable laws, you have rights with
   respect to your personal information. For example, you can request access to
   the personal information we maintain about you, update and correct
   inaccuracies in your personal information, and have the personal information
   deleted or transmitted to a third-party. You can also request to withdraw
   your consent you previously provided to us, to restrict or to object to the
   processing of your personal information, or to provide us with general or
   specific guidelines relating to the storage, deletion and sharing of your
   personal information after your death. You can make such requests through our
   Privacy Request Portal. We may take reasonable steps to verify your identity
   when you make a request. We'd like the chance to resolve directly any
   complaints you have concerning the way we have responded to your request, but
   you have the right at all times to raise a complaint with the Information
   Commissioner’s Office (ICO). Go to: https://ico.org.uk/ for further
   information.
 * Marketing & Advertising Preferences: Your online account may offer you the
   ability to edit your marketing preferences. You can also opt-out of receiving
   marketing communications (such as email, postal mail or text messages) by
   following the unsubscribe instructions sent within those communications or
   you can make a request through our Privacy Request Portal. When you
   unsubscribe from our marketing communications, we will no longer use the
   related personal information (such as your email address or phone number) for
   targeted advertising purposes.
 * Mobile Device & Browser Preferences: Depending on your mobile device or web
   browser, we may request your location or request to send you push
   notifications. You can edit your preferences using the settings on your
   device.
 * Cookie Preferences: You can choose how certain cookies are used in connection
   with our websites. You can edit your cookie preferences at any time by
   editing your browser settings or, in some countries, selecting the “Manage
   Cookies” link at the bottom of each of our Brand websites. For additional
   details see the HOW WE USE COOKIES Section.


HOW WE USE COOKIES

Cookies are small text files that websites place on your Internet-connected
device to uniquely identify your browser or to store information or settings in
your browser which allows us to remember you when you come back to our websites
and provide you with personalised experiences and advertisements. We use
different types of cookies on our websites, including strictly necessary
cookies, performance cookies, functional cookies and targeting cookies.

You can edit your cookie preferences at any time by using the tool available on
the Brand website (if available) or by editing your browser settings. In
countries where the tool is available, you can find a list of cookies used in
connection with any of our websites and edit your preferences by accessing the
“Manage Cookies” link at the bottom of each of our Brand websites. When editing
your cookie preferences, please note that your settings only apply to the
browser you use to submit your opt-out request, so if you use multiple browsers
or devices, you must opt-out on each browser, on each device. Your opt-out is
enabled using cookies, so once you opt-out, if you delete your browser’s saved
cookies on a device, you will need to opt-out again on that browser on that
device.

Our websites are not designed to respond to “do not track” signals from
browsers.


HOW WE USE INFORMATION TO ADVERTISE

We may use, disclose or otherwise process your personal information to advertise
our products and services in different ways, including targeted advertising. We
work with third party advertising companies (such as advertising networks) to
serve advertisements on our behalf. These advertising companies may use cookies,
pixel tags and similar technologies to collect device identifiers, online or
network activity information, commercial information, or inferences, such as
information about the websites you visit over time and the advertisements you
click on to deliver advertisements that are targeted to you or your profile. You
can opt-out of cookie-based advertising based on your visits to our sites by
editing your cookie preferences as described in the HOW WE USE COOKIES Section.
Please note that even if you opt-out, you may still see ads from us, but the ads
will not be targeted based on the websites you visit over time and the
advertisements you click on and may therefore be less relevant to you and your
interests.

We also work with third-party platforms, including platforms operated by social
networks, to show you advertisements or measure the effectiveness of our
advertisements. We may convert your email address, telephone number, or other
information into a unique value and have these third-party platforms match this
unique value with a user on their platform or with other data they may have.
This matching enables us to deliver advertisements to you and others on these
platforms. You also can request that we refrain from using your personal
information in this way by contacting us through our Privacy Request Portal.


INTERNATIONAL TRANSFERS

In offering and providing our products and services, your personal information
may be transferred, stored or processed in countries other than the United
Kingdom and Republic of Ireland in which the information was originally
collected (such as the United States). Those countries may not have the same
data protection laws as your country of residence, and your personal information
will be subject to applicable foreign laws. When we transfer your personal
information to other countries, we will protect that information in the manner
described in this Privacy Policy. We will also comply with applicable legal
requirements providing adequate protection for the transfer of personal
information, such as the conclusion of data transfer agreements, E.U. Standard
Contractual Clauses, the UK’s International Data Transfer Agreement or other
applicable data transfer mechanisms. If you have questions about our data
transfers or would like to receive a copy of any applicable data transfer
agreements (where required by law), you can submit a request through our Privacy
Request Portal.


HOW WE PROTECT INFORMATION

We maintain administrative, technical, and physical safeguards designed to
protect the personal information you provide against accidental, unlawful or
unauthorised destruction, loss, alteration, access, disclosure, or use. We
restrict access to personal information on a need-to-know basis to employees and
authorised service providers who require access to fulfil their job
requirements.


HOW LONG WE RETAIN INFORMATION

In general, we retain personal information as long as reasonably needed to
achieve the purposes outlined in this Privacy Policy. There are many factors
that we use to determine how long personal information is retained, such as:

 * the purposes for which the personal information was collected, including to
   provide our products and services;
 * your marketing preferences and how you engage with our Brands;
 * any legal or regulatory requirements that apply to the personal information;
   and
 * whether the personal information may be relevant to us in protecting our own
   rights (e.g. applicable limitation periods).

For additional information about data retention policies, please submit a
request through our Privacy Request Portal.


HOW WE TREAT CHILDREN’S INFORMATION

Our products and services are designed for a general audience and are not
intended for or directed to children.


UPDATES TO OUR PRIVACY POLICY

This Privacy Policy may be updated periodically and without prior notice to you
to reflect changes in our personal information practices. We will post a notice
on our websites to notify you of any significant changes to our privacy
practices and indicate at the top of the Privacy Policy when it was most
recently updated.


YOUR DATA CONTROLLER

A data controller is the entity or entities responsible for establishing the
purposes and means for the processing of your personal information.

The data controller in the United Kingdom and Republic of Ireland for all our
brands, including The Cosmetics Company Store is: Estée Lauder Cosmetics
Limited, a company registered in England and Wales with company number 659213
and having its registered office at One Fitzroy, 6 Mortimer Street, London W1T
3JJ.

You can find a list of the Brands in the UK and Ireland on ELCompanies.co.uk.


HOW TO CONTACT US

If you have any questions or comments about this Privacy Policy or if you would
like to exercise your rights, you can contact our Data Protection Officer by
submitting a request through our Privacy Request Portal.

If we need, or are required, to contact you concerning any event that involves
your personal information, we may do so by postal mail, telephone, email or
through a notice on our websites.

The Cosmetics Companies Store