ESTEE LAUDER (HONG KONG) LIMITED
THE ESTÉE LAUDER COMPANIES’ BREAST CANCER CAMPAIGN PRIVACY POLICY
Effective Date: 14 October 2020
Estee Lauder (Hong Kong) Limited (“we”, “us”, or “our”) respects your concerns about
privacy
and value the relationship we have with you. This Privacy Policy describes the types of personal
information we collect about our customers, how we use the information, with whom we share it,
and
the choices available to our customers regarding our use of the information. We also describe
the
measures we take to protect the security of the information and how our customers can contact us
about our privacy practices.
Click on one of the links below to jump to the listed section:
Information We Collect
We may obtain personal information about you from various sources. We may collect this
information
when you provide it on or via our website, via, download and/or use our social media/ social
networking pages (or their relevant platforms or corresponding mobile applications, e.g.
Facebook,
Instagram), when you via either Apple iOS or Android download one of our mobile applications
unto
(and/or use such applications in) your mobile device, when being at one of our stores or events,
when joining any of our loyalty program or when applying for any membership program. Our
products
are available for sale in many department stores. Unless otherwise indicated at the time that
you
provide your personal information, any personal information collected in these department stores
is
not provided to us. This Privacy Policy does not address any data collection by our retail
partners.
When you visit this site, our social media/ social networking pages (or their relevant platforms
or
corresponding mobile applications), or when you use the services or features of one of our
mobile
applications, we may also collect certain information about your device or usage by automated
means
or by using technologies such as cookies, web server logs and web beacons.
Information You Provide
You may choose to provide personal information to us in a number of ways, such as when you
participate in an offer or promotion, or when you make a purchase at any of our counters in
department stores, our stores or on our site, via our social media/social networking pages (or
their
relevant platforms or corresponding mobile applications) or through one of our mobile
applications.
The types of personal information you may provide to us, if applicable, include:
- Contact information (such as name, postal address, email address, mobile phone or other
phone
numbers, mobile service provider);
- Age and date of birth;
- Ethnicity, gender, preferred language;
- Username and password;
- Payment information (such as your payment card number, expiry date, delivery address, and
billing address);
- Purchase history;
- Product preferences and communication channel preferences;
- Your physical characteristics and skincare concerns and/or skincare regimes, skin type, skin
conditions (sensitive or allergies) and medications for the same that may be deemed
sensitives
personal information under applicable laws;
- Contact information of friend(s) or other people you would like us to contact (under the
circumstance that you have obtained the required consent of such individuals for such use by
us);
- Content you provide (such as photographs, videos, reviews, articles, survey responses and
comments);
- Information provided to us when you visit our social media pages or use one of our social
networking or mobile applications (such as your name, profile picture, likes, location,
friend
list and other information described on the social media network or application sign-up
page, or
your geo-location details when using one of our mobile applications);
- Your membership program or loyalty program account identification number.
It is voluntary for you to provide your personal information to us, but certain services and
promotions may not be available to you if you do not provide your personal information.
How We Use the Information
We may use the information you provide for the below purposes:
- Send you promotional materials or other communications;
- Provide requested information and services to you;
- Contact you to follow up or confirm your orders, appointments, returns, or refunds and to
send
you other non-marketing communications related to products and services we provide to you;
- Process your payment and/or gift card transactions;
- Create and manage your account, including access to your on-line and in-store purchase
history;
- Assist with product selection and replenishment, including through our customer registry;
- Administer our membership list and loyalty program list, if any;
- Respond to your inquiries;
- Tailor ads on our website, social media platforms and elsewhere to your interests and
history
with us;
- Communicate with you about, and administer your participation in, special events, contests,
sweepstakes, programs (such as loyalty program, if any), surveys and other offers;
- Operate and communicate with you about our social networking or mobile applications;
- Operate, evaluate and improve our business (including developing new products and services;
enhancing and improving our products and services; managing our communications; analyzing
our
products; performing market researches, data analytics and customer relations management
programs, and performing accounting, auditing and other internal functions);
- Comply with applicable legal requirements, relevant industry standards and our policies;
- To avoid duplication and ensure accuracy of your Information, periodically conduct data
cleansing, linking or merging of our records, either internally or through our service
providers.
We also may use the information in other ways for which we provide specific notice at the time of
collection.
If you provide us with your personal information, we intend to use it for direct marketing
purpose to
offer or advertise the availability of our goods and/or services. However, we may not use your
personal information for such purpose unless we have received your consent to our intended use.
All types of personal information listed in the section “Information You Provide” above may be
used
by us in direct marketing if you provide such information to us and you expressly consent to
such
use in writing. In such event, we may market the following classes of goods and services
directly to
you using your personal information:
- Beauty and skincare products;
- Hair care and hair styling products;
- Hair dye;
- Makeup;
- Perfumes, scents, aromas, deodorants, home fragrance and candles;
- Shampoo, conditioners and cleansers;
- Tea and teabags;
- Special events, contests, sweepstakes, programs and surveys; and
- Any other products or services offered by us.
Direct marketing communications may be sent to you through various channels, including by
telephone,
post, email, SMS, through mobile apps, online apps, social media platforms and other online
means.
We, Estee Lauder (Hong Kong) Limited, are an affiliate of the Estée Lauder Companies Inc. (“ELC”)
– a
global leader which is dedicated exclusively to prestige beauty and the owner of a number of
worldly
renowned brands in the arena of cosmetics, beauty, fragrance industry, such as Estée Lauder,
Bobbi
Brown, Clinique, Jo Malone London, La Mer, M.A.C., Origins, etc. Please visit
www.elcompanies.com/en/our-brands for further details on our company and brands. To share with
you
more of our multi-brands’ beauty tips and information through our connection with you, when you
sign
up for an account or program with us (e.g. membership account, loyalty program etc.), or when
you
receive services from us, in addition to any interaction that you may have with the brand that
you
originally have contact with, you may be invited by that brand (i.e. us) to subscribe to
marketing
materials of our multiple adjacent brands offered by our company as a whole. Upon your consent,
the
personal data you provided in the form, or the personal data you provided at the time when you
consented to the said subscription, would simultaneously be used by us for that marketing
purpose.
Our handling of any data transfer issues concerned under this paragraph would remain consistent
with
what is provided in this Privacy Policy.
If you do not wish us to use your personal information in direct marketing, you may opt out of
our
direct marketing at any time by following the procedures set out in the section “Your Rights and
Choices” below. We must, without charge to you, cease to use your personal information in direct
marketing if you so require.
We will use the personal information supplied by you for direct marketing only in accordance with
the
Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (“Ordinance”). Our direct
marketing materials may come in several forms, including but not limited to marketing mails,
emails
and text messages, the details of which are set out in the following sub-sections.
Information We Collect by Automated Means
When you visit this site or click on our online advertisements (including our advertisements on
third
party websites), visit our social media/ social networking pages (or their relevant platforms or
corresponding mobile applications), or download and/ or use one of our mobile applications, we
also
collect certain information about your usage or device by automated means or by using
technologies
such as cookies, web server logs and web beacons. For example, if you use one of our mobile
applications, we may collect your IP address, your unique device identifier (or other device
identifier) and/or geo-location data in order to offer you certain features or functionalities
within that mobile application. As set forth in more detail below, we may also collect
information
about your usage and browsing habits using various web-based technologies.
For your convenience, our mobile applications may also include functionality that allows you to
remain logged in to the application so that you do not have to reenter a password each time you
want
to access the application. IF YOU CHOOSE TO REMAIN LOGGED IN, YOU SHOULD BE AWARE THAT ANYONE
WITH
ACCESS TO YOUR MOBILE DEVICE WILL BE ABLE TO ACCESS AND MAKE CHANGES TO YOUR MOBILE ACCOUNT AND
MAY
BE ABLE TO MAKE PURCHASES THROUGH YOUR ACCOUNT. For that reason, if you choose to remain logged
in
to the application on your mobile device, we strongly recommend you enable the Passcode Lock
security feature on your mobile device to protect against unauthorized access to and use of your
mobile device and your account in the application.
Technologies We Use
Cookies, Web Server Logs, Web Beacons and Geo-location technologies
-
Cookies:
“Cookies” are small bits of information or small text files that websites send to your
browser
which may then be stored on the hard drive of your computer as a tag that identifies your
computer. Cookies remember information about your activities on the site to make your visits
to
our website more enjoyable and valuable to you by providing a customized experience and
recognizing your preferences when you visit our website. Your browser may tell you how to be
notified when you receive certain types of cookies and how to restrict or disable certain
cookies. If you have chosen to disable cookies on your browser, some of the functionality of
our
website may be lost.
-
Flash cookies:
“Flash cookies” (also called Local Shared Objects or “LSOs”) are data files similar to
cookies,
except that they can store more complex data. Flash cookies are used to remember settings,
preferences, and usage, particularly for video, interactive gaming, and other similar
services.
-
Web server logs:
Web server logs are records of activity created by the computer that delivers the webpages
you
request to your browser. For example, a web server log may record the search term you
entered or
the link you clicked to bring you the webpage. The web server log also may record
information
about your browser, such as your IP address of the device you use to connect to the
Internet,
operating system type, browser type, domain, the cookies set on your browser by the server,
the
language your system uses and country and time zone in which your device is located.
-
Web beacons, clear pixels, or pixel tags:
To control which web servers collect this information, we may place tags on our web pages
called
“web beacons”. “Web beacons” are computer instructions that link web pages to particular web
servers and their cookies. They are small graphic images on a Web page or in an e-mail that
can
be used for such things as recording the pages and advertisements clicked on by users, or
tracking the performance of e-mail marketing campaigns.
-
Geo-location technologies:
Geo-location technology refers to technologies that permit us to determine your location. We
may
ask you to manually provide location information on our website, or to enable your mobile
device
to send us precise location information. We may also automatically collect general location
information from your web browser.
Third Party Web Analytics Services
We may use third party web analytics services on this site, our social media/ social networking
pages
(or their relevant platforms or corresponding mobile applications), or our mobile applications,
such
as those of Adobe Site Catalyst and/or Google Analytics. The service providers that administer
these
services use technologies such as cookies, web server logs and web beacons to help us analyze
how
visitors use the site. The information collected through these means (including IP address) is
disclosed to these service providers, who use the information to evaluate use of the website.
You
may deactivate the ability of these analytics services to analyze your browsing activities on
this
site. To learn more about web analytics services, and exercise your choice with respect to their
collection of information on this site:
For Adobe Site Catalyst, please click here: http://www.adobe.com/privacy/opt-out.html.
To disable Google Analytics, please download the browser add-on for the deactivation of Google
Analytics provided by Google at http://tools.google.com/dlpage/gaoptout?hl=en.
To
learn more about privacy and Google Analytics please consult the Google Analytics overview
provided
by Google at: http://www.google.com/intl/en/analytics/privacyoverview.html.
We have implemented certain Google Analytics Advertising Features (Google Analytics Demographics
and
Interest Reporting). You can opt out of the Google Analytics Advertising Features through Google
Ad
settings or by visiting https://tools.google.com/dlpage/gaoptout/. We will use the
data
provided by Google Analytics Demographics and Interest Reporting as described under “How We Use
the
Information”.
To disable other third-party web analytics service provider cookies, some browsers indicate when
a
cookie is being sent and allow you to decline cookies on a case-by-case basis. You may also turn
off
cookies in your browser.
Targeted Advertising
We also may contract with third-party advertising networks that collect IP addresses and other
information through the use of cookies, web server logs and web beacons on our websites and
emails;
on third-party websites and emails; and on our advertising placed on third-party websites. They
use
this information to provide advertisements about products and services tailored to your
interests
(including for companies not affiliated with us). You may see these advertisements on other
websites. This process also helps us manage and track the effectiveness of our marketing
efforts. To
learn more about advertising networks and to opt out of interest-based advertising, visit the
Digital Advertising Alliance at www.aboutads.info/choices or the Network Advertising Initiative
at
www.networkadvertising.org/choices.
We may also use third-party platforms, including platforms operated by social networks, such as
Google, Facebook, Pinterest, WeChat, LINE, Kakao etc., to show interest-based ads. We may
convert
your email address, telephone number or other information into a unique value which can be
matched
by those third parties with a user on their platform or with other data they may have collected
from
you. This matching allows interest-based ads to be delivered on those platforms. To opt out of
these
ads, you must change your advertising preferences on those third-party platforms. These
platforms
may have their own privacy notices or policies, which we strongly suggest you review.
How We Use the Information Collected by Automated Means
We may use the information collected through automated means on this site for market research,
data
analytics and system administration purposes, such as to determine whether you have visited us
before or are new to the site, to tailor ads displayed to you on our site and elsewhere to your
interests and history with us, and for compliance with our legal obligations, policies and
procedures, including compliance with relevant industry standards and the enforcement of
our Terms
and Conditions. We also may use the information in other ways for which specific notice is
provided
at the time of collection.
Push Notifications and In-App Alerts and Updates
When you download one of our mobile applications, we may provide you with the option to opt in to
receive push notifications from us on your mobile device in connection with that mobile
application.
These push notifications may include promotional communications regarding our products and
services.
You may, after downloading the applicable mobile application, opt out of receiving push
notifications by adjusting the settings on your mobile device. Opting out of push notifications
will
not affect other communications you receive from us, such as email communications. You also may
receive alerts and updates within our mobile applications regarding our products and services or
your accounts with us. To opt out of receiving these alerts and updates, you may uninstall the
applicable mobile application from your mobile device.
Information We Share
We do not rent, or sell, or otherwise (except as described here) disclose personal information we
collect about you, so as to permit those third parties to directly market to you. But as may be
required for the performance of the purposes discussed in earlier sections, we may share your
personal information with:
- our affiliates within the Estée Lauder Companies umbrella of companies for the purposes
described in this Privacy Policy or as otherwise specified in the notice provided at the
time of
collection. For additional information regarding our corporate affiliates, please see http://www.elcompanies.com/;
- service providers, licensees and/or joint venture partners who may be located overseas
(including Singapore, South Korea, and the United Kingdom), and they may perform services on
our
behalf based on our instructions and send you direct marketing materials in relation to the
Goods and Services. We do not authorize 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, fulfill orders, and provide web hosting, advertising and marketing services;
- other third parties through social networks, widgets and plug-ins. If you use any features
made
available to you on our website by a third party, it may result in information being
collected
or shared between us and the third party. For example, if you use Facebook’s “Like” feature,
Facebook may register the fact that you “liked” us and may post that information on
Facebook.
Also, some of our Facebook applications may share your information collected through those
apps
with your Facebook friends or other Facebook users.
Where we need to share your personal information to third parties for the performance of purposes
discussed above on our behalf, we would request such parties to adopt a privacy practice with
personal data handling at an equivalent or even stricter level. We may not be able to offer
certain
services or benefits to you if you do not consent to the sharing of your data.
In addition, we may disclose 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, or (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.
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. Should such a sale or transfer occur, we
will
use reasonable efforts to direct the transferee to use personal information you have provided to
us
in a manner that is consistent with our Privacy Policy. Following such a sale or transfer, you
may
contact the entity to which we transferred your personal information with any inquiries
concerning
the processing of that information.
Your Rights and Choices
We offer you certain choices in connection with the personal information we collect from you,
such as
how we use the information and how we communicate with you. To update your preferences, ask us
to
remove your information from our mailing lists or submit a request, please contact us as
specified
below.
-
Email Opt-Out
You can at any time tell us not to send you marketing communications by email by clicking
on
the unsubscribe link within the marketing emails you receive from us or by contacting us
as
indicated in the “How to Contact Us” section below. You also may opt out of receiving
marketing emails from us by sending an opt-out request to cs@esteelauder.com.hk .
-
Postal Mail Opt-Out
You can request us to stop sending you marketing communications by postal mail by
following
the instructions that may be included in our promotional mail. You can also request us
to
refrain from sending you promotional mails by contacting us as indicated below.
-
Text Message Opt-Out
You can request that we refrain from sending you text messages by contacting us as
indicated
below.
-
Social Networking Application Opt-Out
To remove or delete our social media applications from your social networking account,
follow
the instructions from the social network.
For Facebook: please see instructions provided by the Facebook Help Center.
-
Geo-Location Information
When you use one of our mobile applications, you may be asked for your geo-location via
such
mobile application. You may choose not to share your geo-location details by adjusting
your
mobile device’s location services settings. To decline sharing your geo-location
details,
follow the instructions on your mobile device on changing the relevant settings;
otherwise,
please contact your service provider or device manufacturer.
-
Withdrawing Consent
You may withdraw any consent you previously provided to us, or object at any time on
legitimate grounds, to the processing of your personal information. We will apply your
preferences going forward. In some circumstances, withdrawing your consent to our use or
disclosure of your personal information will mean that you cannot take advantage of some
of
our products or services.
-
Reviewing, Updating and Modifying Personal Information
We may retain and use your Information for as long as necessary to fulfill the purposes
set
out above. You have the right to request access to and receive details about the
personal
information we maintain about you, update and correct inaccuracies in your personal
data,
and have the information blocked or deleted, as appropriate. The right to access
personal
information may be limited in some circumstances by local law requirements. We may take
reasonable steps to verify your identity before granting access or making corrections.
You
may request to review, change or delete your personal information by sending an email to
cs@esteelauder.com.hk with attention to our data protection officer.
Data Transfers
We may transfer the personal information we collect about you to countries other than the country
in
which the information was originally collected (including China, Singapore, Japan and South
Korea)
and your personal information may be processed and stored outside your country of residence.
Those
countries may not have the same data protection laws as the country in which you initially
provided
the information. When we transfer your information to other countries, we will protect that
information as described in this Privacy Policy.
How We Protect Personal Information
We maintain appropriate administrative, technical and physical safeguards designed to protect the
personal information you provide against accidental, unlawful or unauthorized destruction, loss,
alteration, access, disclosure or use. However, no security system is perfect, and we cannot
promise
that information about you will remain secure in all circumstances, including the security of
your
data during transmission to us or the security of data on your mobile device.
Links to Other Websites
Our website may provide links to other websites for your convenience and information. These
websites
may operate independently from us. Linked sites may have their own privacy notices or policies,
which we strongly suggest you review if you visit any linked websites. To the extent any linked
websites you visit are not owned or controlled by us, we are not responsible for the sites’
content,
any use of the sites, or the privacy practices of the sites.
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 prominent notice on our website to notify you
of
any significant changes to our Privacy Policy and indicate at the top of the Policy when it was
most
recently updated.
How to Contact Us
If you have any questions or comments about this Privacy Policy, or if you would like us to
update
information we have about you or your preferences, please contact us by email us at .
Discrepancies
If there is any conflict between the English and the Chinese versions of this Privacy Policy, the
English version shall prevail.
