L'ORÉAL SINGAPORE PTE LTD

PRIVACY POLICY

FOR OUR BUSINESS CUSTOMERS

 

L’Oréal’s ambition is to be an exemplary corporate citizen to help make the world a more beautiful place. We place great value on honesty and clarity, and we are committed to building a strong and lasting relationship with you based on trust and mutual benefit. Part of this commitment means safeguarding and respecting your privacy and your choices. Respecting your privacy is essential to us. This is why we set out “Our Privacy Promise” and our full Privacy Policy below.

This Privacy Policy covers how we use personal data shared with us by our customers operating in a business capacity, for example salons, pharmacists, retailers, or any other stakeholders such as influencers.

OUR PRIVACY PROMISE

1. We respect your privacy and your choices.
2. We make sure that privacy and security are embedded in everything we do.
3. We will not send you marketing communications unless you have asked us to. You can change your mind at any time.
4. We will not sell your personal data.
5. We are committed to keeping your personal data safe and secure. This includes only working with trusted partners.
6. We are committed to being open and transparent about how we use your personal data.
7. We will not use your personal data in ways that we have not told you about.
8. We respect your rights, and will always try to accommodate your requests as far as is possible, in line with our own legal and operational responsibilities.

For more information about our privacy practices, below we set out what types of personal data we might collect or hold about you, how we use it, who we share it with, how we protect it and keep it secure, and your rights around your personal data.

Note that all of the information set out below may not apply to you. We have explained below an overview of all possible situations in which we could interact together, and one or more of these may apply to you depending on how you have interacted with us. For example, if you have not provided us with a photo for your account, then these details will not apply to you.

If this Privacy Policy changes in any way, it will be updated on this page. Regularly reviewing this page ensures you are updated on the information which is collected, how it is used and under what circumstances, if any, it is shared with other parties.

When you share personal data with us or when we collect personal data about you, we will use it in line with this Privacy Policy. Please read this information carefully. If you have any questions or concerns about your personal data, please contact via the contact details set out in the "Contact" section below.

Please note that you must be at least eighteen (18) years old, or have obtained your parent’s or legal guardian’s consent, to use our services.

WHO WE ARE ?

L’Oréal Singapore Pte. Ltd. (UEN: 199001413D) is a subsidiary of the L’Oréal Group, with a portfolio of numerous brands provided by our four divisions: Consumer Products, L’Oréal LUXE, Professional Products and Active Cosmetics as follows:

Consumer products

• - Garnier
• - L’Oréal Paris
• - Maybelline

L’Oréal LUXE

• - Giorgio Armani Beauty
• - IT Cosmetics
• - Kiehl’s
• - Lancôme
• - Shu Uemura
• - Yves Saint Laurent

Professional Products

• - Kerastase
• - L’Oréal Professionnel

Active Cosmetics

• - La Roche-Posay
• - Vichy
• - Skin Ceuticals

(The brands listed above are hereinafter collectively referred to as the (“Brands”).

The above Brands are part of the L’Oréal Singapore Pte. Ltd. brand portfolio. L’Oréal Singapore is responsible for the personal data that you share with us. When we say “L’Oréal”, “us”, “our” or “we”, this is who we are referring to. L’Oréal is the “organisation” for the purposes of the Singapore Personal Data Protection Act (No.26 of 2012), and the “data controller” for the purposes of applicable data protection laws in other jurisdictions.

Business address: L’Oréal Singapore Pte. Ltd., 1 Raffles Quay, #47-01, North Tower, 048583

Website: https://www.loreal.com/en/singapore/

WHAT IS PERSONAL DATA ?

“Personal data” means any information or pieces of information that could identify you either directly (e.g. your name) or indirectly (e.g. through pseudonymised data, such as a unique ID number) and / or information which makes you identifiable. This means that personal data includes things like email/home addresses, usernames, profile pictures, personal preferences and shopping habits, user generated content, financial information, and health information. It could also, in certain circumstances, include unique numerical identifiers like your computer’s IP address or your mobile device’s MAC address, as well as cookies.

This Privacy Policy covers all personal data about you that is collected and used by L'Oréal.

WHAT PERSONAL DATA DO WE COLLECT FROM YOU AND HOW DO WE USE IT?

You, the customer, are at the heart of our activities. We love hearing from you, learning about you, and creating and delivering products that you enjoy and can use to strengthen and grow your business.

At L’Oréal, we have the ambition of building relationships based on transparency and mutual trust.

We know that many of you also love interacting with us and because of this, there are many ways that you might share your personal data with us, and ways that we might collect it.

How Do We Collect Or Receive Your Personal Data?

We might collect, record, hold, store, use, disclose,receive and/or process (collectively referred to as "Process" or “Processing”) personal data from you via our websites, forms, apps, devices, L’Oréal products or brand pages on social media, through your direct interactions with your account managers or customer care teams, or otherwise. Sometimes you give this to us directly (e.g. when you create an account, when you contact us, when you purchase from our websites/apps or in our stores), sometimes we collect it (e.g. using cookies to understand how you use our websites) or sometimes we receive your personal data from other third parties, including other L’Oréal Group entities.

In addition to the above, your personal data has and / or may be obtained from the following sources, where applicable, or such other sources which we may see fit from time to time:

• a. information provided or submitted by you through among others, your business card, your business proposals or quotations, the forms which you have submitted for our vendor registration process, our MyMarket platform, our SAP platform and/or others;
• b. information gathered through promotional activities / business meetings;
• c. information gathered by virtue of entering into contractual agreements with you or your organisation;
• d. as applicable, publicly available or publicly accessible information; and / or
• e. such other written or verbal communications or documents delivered to us prior to and during the course of our contractual or pre-contractual dealings with your organisation.

When we collect personal data, we will indicate which types of personal data are mandatory via asterisks. Some of the personal data we request from you are either necessary for us to:

• • enable you or your organisation to enter into the necessary agreement and/or contract to purchase / provide the products/ services from/to us or perform our contract with you (e.g. to create your account, or deliver the goods you have purchased on our websites/apps);
• • Provide you with a service you have asked for;
• • Comply with legal requirements (e.g. invoicing) or for billing purposes;
• • the delivery of notices, services or products to you or your organisation;
• • relationship management procedures;
• • to enable you or your organisation to promote our products and brand via you or your organisation's social media platform and / or at marketing events;
• • for business contact purposes;
• • for corporate secretarial purposes;
• • for the facilitation of transactions that you or your organisation have or may have with us;
• • processing of orders and payment clearance;
• • planning and controlling administrative budget;
• • those purposes specifically provided for in any particular service or product offered by us or service provided by you or your organisation;
• • credit assessments and other background checks as we may determine to be necessary or appropriate;
• • collection of outstanding payments and/or processing of payments in general from you or your organisation;
• • conducting marketing and client profiling activities in connection with our services and related products;
• • for general marketing purposes;
• • for research, benchmarking, and statistical analysis purposes;
• • to enable us and / or our selected authorised third parties to send you information by e-mail, telecommunication (telephone calls and text messages) or via social media concerning related and unrelated products and services offered by us and our business partners which may include but is not limited to the abovementioned purposes which we consider will or may interest you;
• • our internal record keeping;
• • the prevention of crime including but not limited to fraud, money-laundering, and bribery; and / or
• • meeting any legal or regulatory requirements relating to our provision of services and products and to make disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular, code applicable to us or any of our member companies.

We may retain the personal data and that of other individuals as representatives of you, that you provide to us for a reasonable period in accordance with commercial requirements and at all times subject to prevailing legal requirements.

If you do not provide the personal data marked with an asterisk, this may affect the goods and services that we can provide to you.

It is obligatory for you to provide the categories of personal data which we request from you for the said purpose. Failure to supply and consent to the Processing of the personal data in relation to the purpose will:

• a. result in us being unable to provide you or your organisation with the information, notices, services and/or products requested;
• b. affect the ability of the parties to enter into the necessary agreement in relation to the provision of our services to you or your organisation and/or to receive services from you or your organisation.

In the table below, we explain :

1. During which interactions you may provide and we may collect your data: This column explains what activity or scenario you are involved in when we use or collect your personal data. For example, whether you are making a purchase, signing up to a newsletter, or browsing a website.
2. What personal data we may receive from you directly or resulting from your interactions with us: This column explains what types of personal data we may Process when you take part in a particular activity.
3. How and why we use your personal data: This table below further explain what we do with your personal data, and the purposes for Processing:
4. What is our legal basis for using your personal data: Whenever we use your personal data, we will have a legal basis to do this. For example, you have asked us to provide a service, you have given us your consent, or we have a legitimate interest in using your personal data.

The legal basis for the processing of your personal data can be:

• • Your consent.
• • The performance of a contract – This applies where you provide us with your personal data in order for us to provide you with a service (e.g. you ask us to create a customer account for you or you wish to purchase a product and we can manage the associated logistics).
• • 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 customers’ 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.
• • Legal grounds – This is where we need to keep your personal data for legal reasons (e.g. when you make a purchase we need to keep your transaction information to comply with our tax and financial reporting obligations).

Information Overview on Your Interactions With Us and Their Consequences on Your Personal Data

Please note that regardless of the legal basis set out above, to the extent consent is necessary under local applicable laws, our processing of your personal data is on the lawful basis of your consent.

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.

How May Access Your Personal Data ?

Personal data provided to us will, generally, be kept confidential but you hereby consent and authorise us to provide and / or disclose your personal data, in your capacity as your organisation's representative, to the following categories of parties:

• a. any person to whom we are compelled or required to do so under law or in response to a legitimate instruction from a competent or government agency;
• b. pursuant to an order of a court of competent jurisdiction;
• c. any related companies and subsidiaries of L'Oréal, including those established in the future, whether within or outside of Singapore;
• d. where applicable, third parties who provide related services or products in connection with our business, whether within or outside of Singapore;
• e. government agencies, statutory authorities and industry regulators;
• f. to organisations including their professional service providers and relevant regulatory authorities whether within or outside Singapore, in connection with the acquisition, disposition and / or intended acquisition or disposition of the Company's assets and / or of the Company itself whether directly or indirectly;
• g. our auditors, consultants, accountants, lawyers or other financial or professional advisers; and / or
• h. our sub-contractors or third party service or product providers as we may determine to be necessary or appropriate including without limitation, our mailing vendors, as well as vendors that carry out promotional operations on our behalf, whether within or outside of Singapore.

Please rest assured that consistent with the law, we will only disclose the minimum amount of information which we deem necessary for the purpose and that we will take all appropriate safeguards to ensure the integrity and security of the personal data.

In addition, we are part of the L'Oréal Group of companies which operates in multiple jurisdictions. Accordingly, access to your personal data as your organisation's representative may be granted to other entities within the L'Oréal Group and may be transferred out of Singapore for the purpose of data storage to L'Oréal Group globally.

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 Singapore) 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 Singapore).

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:

1. Third parties that assist and help us in providing digital and e-commerce services such as social listening, store locator, loyalty programs, identity management, reviewing social media and public profiles, ratings and reviews, CRM, web analytics and search engine, user generated content curation tools;
2. 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 and our relationships;
3. Third parties required to deliver a product to you e.g. postal/delivery services;
4. 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);
5. 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;
6. Third parties that assist us for customer care and customer vigilance purposes;
7. Third parties that assist us in providing training, seminars, and events, such as training providers travel agencies, and event management companies; and/or
8. 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.

We may also disclose your personal data to third parties (whether within or outside of Singapore):

1. 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.
2. 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.
3. If we have your consent to do so.
4. Or if we are permitted to do so by law.

We may disclose your personal data to our partners (whether within or outside of Singapore):

1. 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:
2. By L’Oréal in accordance with this Privacy Policy;
3. By the partner acting also as a data controller under its own terms and conditions and in accordance with its own privacy policy.
4. 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.
5. 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;
6. 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, which govern these services and data processing.

Information that Facebook collects and shares 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:

1. Sign-up with your Facebook login. If you do so, you consent to share some of your public profile information with us;
2. Use the Facebook social plug-ins, such as “like” or “share” our content on the Facebook platform;
3. 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 are using those Facebook features, we collect data that help us to:
4. Show you adds you might be interested in on Facebook (or Instagram, Messenger or any other Facebook services);
5. Measure and analyze the effectiveness of our website/app and ads

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 and/or those who have similar profile like yours in Facebook (or Instagram, Messenger or any other Facebook services) in order to show you and the others, ads that are even more relevant for you and the others. While doing this, Facebook will not share your personal information and will delete the information promptly after the match process is complete.

We do not offer or sell your personal data.

Where Do We Store 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 as guidance:

1. Where you purchase products and services, we keep your personal data for the duration of our contractual relationship;
2. Where you participate in a promotional offer, we keep your personal data for the duration of the promotional offer;
3. Where you contact us for an enquiry, we keep your personal data for the duration needed for the processing of your enquiry;
4. 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;
5. 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;
6. 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/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/apps.

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/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.

YOUR RIGHTS AND CHOICES

L’Oréal respects your right to privacy: it is important that you are able to control your personal data. You have the following rights:

To deal with your request, we may require proof of your identity.

CONTACT

If you have any questions or concerns about how we treat and use your Personal Data, or would like to exercise any of your rights above, you may contact our Data Protection Officer via e-mail at [email protected] or by writing to us at L’Oréal Singapore Pte. Ltd., 1 Raffles Quay, #47-01, North Tower, 048583 (Attention: Data Protection Officer).

If you would like to unsubscribe from receiving text messages, emails or phone communications from L’Oréal, you may email us at [email protected] or by clicking the “unsubscribe” link at the bottom of each communication from us.

Please note that by visiting our website and / or utilizing and procuring our products and services, you are deemed to have consented to the terms in this Privacy Policy unless and until you otherwise notify us via the contact details set out above.

(Updated as of: October 2023)