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1 - Introduction
Clarins places great importance on the protection of Users’ privacy and its obligations in accordance with the legal provisions in force.
Clarins Groupe (Middle East) Ltd. whose registered office is Dubai Airport Freezone and Clarins SAS whose registered office is located 9 rue du Commandant Pilot, 92200 Neuilly-sur-Seine, France are joint data controllers for the website www.ae.clarins.com.
2 - When do we collect your information?
We collect personal information from you when:
- you visit our website;
- you create an account on our website;
- you make a purchase or a reservation on our website or in certain approved points of sale of our distribution network;
- you subscribe to our newsletters;
- you sign up for one of our loyalty programs;
- you participate in special operations, in particular games, competitions, product tests, customers surveys or market researches;
- you share content on social networks such as Instagram, Facebook, Pinterest or Twitter using the hashtag #clarins or other hashtags we offer;
- you contact us, in particular when you call or submit a request or a complaint to our Customer Service teams, or through our Site when you rate or review our products and/or services or when you chat with other visitors in real time;
- you have a consultation or make a purchase in store at one of our counters;
- you have given your consent to third parties to send us personal information about you.
3 - What information do we collect about you?
We consider all information that could identify you directly or indirectly as "personal information". We may mainly collect the following personal information:
- information about your identity, in particular your gender, last name, first names, address, telephone numbers, email address, usernames and passwords, date of birth or age;
- information about your payment method, in particular your credit card number and the expiration date;
- information about our commercial transactions, in particular transaction numbers, history of your purchases, your request or your communications with our Customer Service team, your preferences and interests, your activity on the web or information about one of our loyalty program;
- content information (photos, videos, reviews, comments, etc.);
- information about wellness (beauty concerns, skin type, skin sensitivity, contraindications, etc.) subject to your prior and explicit consent, in particular for cosmetovigilance or when asking for a beauty prescription Clarins or a treatment Clarins in one of our Spas;
- information about your social media accounts (username, caption information, location, etc.), uploads and posts when you share content or use the hashtag #clarins or other hashtags we offer;
- recordings of telephone conversations to offer the best quality of service, in particular for the purpose of staff training and appraisal;
- technical information, in particular your IP address or information about how your device navigates through our website;
- other information you provide when you contact us or we have received from external providers.
4 - Why is your personal information collected?
Personal information may be collected mainly for the following purposes:
- Website administration and improvement of the quality of service. This processing is necessary for the purposes of the legitimate interest referred to above;
- Processing of your orders (orders, deliveries, invoices, after sales service, etc.). This processing is necessary for the performance of a contract to which you are party;
- Customer Relationship Management (CRM), in particular to help us get to know you better and to provide you with personalized offers about our products and services (in particular by email, by SMS, on social networks or any other medium and by displaying targeted ads on websites and on social networks), to manage your membership to our Loyalty program and to analyse and anticipate market trends in order to best meet your needs. For these purposes, we may perform segmentation operations based on your preferences, interests and purchasing behavior, analyse your browsing and requests on our website or perform any other actions to better qualify our database.
This processing is made with your consent or is necessary for the purposes of the legitimate interest referred to in section 4;
- We use Facebook’s “Custom Audience” feature and e-mail re-targeting features, which enables us to create an audience using your customer data such as email addresses and phone numbers. Such processing requires your consent, gained in Facebook’s data processing agreement.
- Social interaction. This processing is made with your consent;
- Prevention and detection of fraudulent or other illegal activity. To assist in fraud prevention, investigation and decision-making, we use a real-time fraud detection service that assesses the level of risk associated with each transaction. Categories that could indicate a transaction as fraudulent include for example: Address verification; Card verification; Identity morphing and Bespoke Clarins rules. Depending on the outcome of this data processing we may refuse to enter into a contract with you.
- Managing your request (samples, advice, participation in a promotional operation, complaints, right to access, rectify, oppose and remove, etc.). This processing is necessary to process your request;
- As otherwise permitted by law and/or if we need to notify to you from time to time.
5 – Do we disclose your personal information?
We never sell nor rent your personal information to other companies for marketing purposes.
The personal information we are collecting about you will be used by Clarins SAS and Clarins Middle East Ltd. and are likely to be communicated to other Group companies.
It may also be shared with service providers chosen for their expertise and reliability and acting on our behalf and at our direction (order processing and fulfilment, secure payment, customer service management, maintenance and technical development operations, rate and reviews, analytics, spam prevention, management of digital campaigns and affiliation, etc.). We authorize these service providers to use your personal information only to the extent necessary to perform services on our behalf or to comply with legal requirements and we strive to ensure that your personal information is always protected.
These third parties may be located in or out of the UAE, including in countries that do not provide the same level of data protection as the UAE. In such a case, we will ensure that:
- we obtain your unambiguous consent to share your personal information with these third parties;
- we enter into appropriate data transfer agreements conforming to the Standard Model Clauses established by the European Commission ;
- we comply with Binding Corporate Rules (BCR) approved by competent authorities;
- Finally, we may also transmit your personal information to local authorities if required by law or as part of an investigation and in accordance with applicable regulations.
6 - How will we protect the information about you?
We cannot warrant or guarantee the security of any information you sent us. We have undertaken all reasonable security measures to protect ensure your data is secure and prevent it from being accidentally lost, or used, or accessed, altered or disclosed in an unauthorized way, altered or disclosed. We also regularly review and update such measures to meet new perceived threats that may arise from technological advances.
Clarins takes appropriate technical and organizational measures, in relation to the nature of data and risks, to preserve the security and confidentiality of your personal information and, in particular, to prevent them from being altered, disclosed or transmitted to any unauthorized parties.
This may include practices such as limited access by members of staff who, by virtue of their duties, are authorized to access data, contractual guarantees in case of third-party providers, privacy impact assessments, internal reviews of our practices and privacy policies and/or implementation of physical and/or systematic security measures (secure access, authentication process, backup, antivirus, firewall, etc.).
7 - What is our policy on minors?
This website www.ae.clarins.com is not aimed at minors.
We do not knowingly collect nor process personal information from minors. Assuming we would have knowledge of the collection of personal information from minors without prior authorization from the holder of the parental responsibility, we will take appropriate measures to contact the person and, if necessary, to delete this personal data from our servers and/or those of our service providers.
Anyone with reason to believe we might have information from or about a minor without legal parental or guardian consent should immediately contact us and provide us with the information required in order to address and rectify the matter.
8 – What is our cookies policy?
For more information on our Cookies Policy please click here to review our Cookies policy.
9 - How is the content you share on social networks using our hashtags managed?
You can choose to use our hashtags to tag your content on social networks such as Instagram, Facebook, Pinterest or Twitter.
By using these hashtags, you acknowledge and agree that your content may appear on our website, be accessible to the public and be used to refer to our products or services.
We remind you that the information you share on social networks can be consulted, used and saved by others around the world, particularly in countries without legislation guaranteeing an adequate level of protection of your personal information as defined in your country of residence.
We also draw your attention to the fact that when you submit content using one of our hashtags, your use of social networks is exclusively governed by the general conditions of these social networks. We invite you to read them and to refer to them regularly.
If you no longer want your content to appear on our site, please remove it from the social network or stop using hashtags.
10 - For how long is your data kept?
As a general rule:
- Customer / prospect data will be kept for three years from the date of collection or after the last contact or the end of the commercial relationship, unless it is opposed or requested to be deleted by you. At the end of this three-year period, we may make contact with you again in order to find out whether or not you wish to continue to receive marketing approaches. If no clear positive answer is given by you, your data will be deleted or archived in accordance with the provisions in force.
- Data on credit cards will be deleted after the transaction or archived for evidence purposes in accordance with the provisions in force. Subject to your express consent, banking data may be kept until the expiration date of the credit card. We never store your visual cryptogram.
- Data to prove a right or a contract, or kept under compliance with a legal obligation can be archived in accordance with the provisions in force.
- Recordings of telephone conversations may be kept for up to six months.
If a judicial action is initiated, the above personal information may be kept until the end of such action, including any potential periods of appeal.
11 - What are your rights regarding your personal information and how do you contact us?
If you give us your email address, phone number or mailing address, you may receive emails, calls or periodic messages from us about our products, services or upcoming events. You can unsubscribe at any time from our mailing lists by contacting us at the address below or by following the link "unsubscribe" contained in each of our emails. You can also change your preferences at any time in your account.
In accordance with the provisions in force, you have a right to access, rectification, erasure and data portability of your personal data as well as a right to object and restriction of processing. You can also withdraw your consent at any time. To exercise these rights, you must send us a request by justifying your identity:
- E-mailing a request to the Customer Service team
- By writing to the following address:
CLARINS GROUPE (MIDDLE EAST) Ltd.
DUBAI Airport Freezone
UNITED ARAB EMIRATES
You will be informed of the actions to be taken as soon as possible and in any case no later than one month after your request. However, we reserve the right not to respond to unfounded or vexatious requests.
In accordance with the provisions in force, you can also file a complaint with the competent authority responsible for data protection or lodge an appeal if your data are misused.
|CLARINS Groupe (Middle East) Ltd.||Clarins|
|Building #1w Al Quds Street||Direction Juridique / Délégué à la Protection des|
|Dubai Airport Freezone, 30522 Dubai||Données|
|United Arab Emirates||12 avenue de la Porte des Ternes|
Director of Human Resources