Jo Malone London India Online Privacy Policy

We at Estee Lauder group’s Indian subsidiary, ELCA Cosmetics Private Limited having our corporate office at having its corporate office at Unit 904, 905, 906, 9th Floor, Godrej BKC, Plot C-68, G Block, Bandra Kurla Complex, Bandra East Mumbai - 400051 (“Jo Malone London India Online”) respect your privacy and value the relationship we have with you. Your visit to this Site (defined hereinafter) is subject to this Privacy Policy and our Terms and Conditions. If you do not agree with the terms of this Privacy Policy, please stop using this Site immediately.

This Privacy Policy describes, inter alia, the types of personal information provided by you on registration together with information we learn about you from your use of our service and your visits to Jo Malone London’s regional website developed and dedicated for India, currently located at www.jomalone.in ("Site") or other websites accessible from them as well as the information provided by you (including on registrations with customer relationship management software/application(s) installed on the iPads/tablets and/or computer systems) at the brick and mortar retail stores which distribute our products (to clarify, we do not own and operate such stores) (collectively, the “Sources”), how we may use that information and with whom we may share it. Our Privacy Policy also describes the measures we take to protect the security of this information as well as how you can access, modify or delete your personal information. It also explains how you can object to the processing of your personal information or to receiving communications about our products and services.

Please note that this Privacy Policy governs all the information provided on/ through the Sources and including any other information or communications that may have reference to Jo Malone London, e.g., communications from Jo Malone London counters located within brick and mortar retail stores. In this regard, it is hereby clarified that we do not own or operate retail stores in India. The retail stores selling Jo Malone London products are owned and operated by third parties. If you visit any such brick and mortar stores and it links you to our other regional websites, e.g. www.jomalone.in, you are subject to the privacy policy applicable for the Site. However, if you access the Site and it links you to another website accessible from the Site, you are subject to the privacy policy applicable for that website and we suggest that you consult such privacy policy.

Information We Collect and How We Use It

You may choose to provide us with personal information when you visit our Sources, such as your name, email address and mobile phone number and sensitive personal data or information sensitive only to the extent of skin type, tone, shade, colour or other physical condition. Except these types of information, we do not collect any other sensitive personal data or information.

If you would prefer that we do not collect any personal information from you, please do not provide us with any such information.

Use of Personal Information by Jo Malone London India Online

Marketing Emails

If you so elect at the time of providing information on the Sources, the information so provided may be used by Jo Malone London India Online to create and deliver to you emails such as our newsletters, surveys or other email messages containing product and event information, cosmetics tips or promotions (“Emails”). If you do elect to receive them and later decide that you would no longer like to receive these Emails, see the “Your Choices” Section below. You may receive the benefit of hearing from Jo Malone London India Online via mail even if you have not elected to receive Emails. If you do not wish to receive direct mail, see “Your Choices” Section below.

Marketing Calls and Messages

If you elect to provide your mobile phone number to us, the same may be used by us or our third-party service providers to send text message alerts ("Text Messages") or phone calls (“Calls”) containing product and event information, cosmetics tips or promotions. There is no fee charged by us to you to receive Marketing Calls and Messages, however, your mobile service provider may charge you for sending and/or receiving text messages and airtime, as well as any other standard applicable rates charged by your mobile service provider. If you do elect to receive them and later decide that you would no longer like to receive these Calls and Text Messages, see the “Your Choices” Section below.

Communications to Serve You

If you have elected to provide us with your contact information through any of the Sources, we may provide you with service-related announcements by any means, including Emails, Calls and Text Messages (collectively, the “Communication”), concerning the Site or contact you regarding your customer service requests or questions. For example, all registered users will receive a welcoming Email to confirm their registration on the Site. These types of communications are necessary to serve you, respond to your concerns and to provide you the high level of customer service that Jo Malone London India Online offers to its customers.

Customized Service

We may use your personal information to provide you with customized service and use of our Site. For example, we may suggest products that would be of particular interest to you.

Special Events, Questionnaires and Surveys

On occasion, Jo Malone London India Online may sponsor special events (such as contests, sweepstakes or other offerings), questionnaires and surveys. There may be specific rules applicable to these promotions/ events that explain how any personal information you provide will be processed. We strongly suggest you review any applicable rules before participating. To the extent any special event, questionnaire or survey is not subject to specific rules, the processing of personal information is governed by this Privacy Policy and the purposes it sets forth.

Employment

If you provide personal information to us with respect to employment, such as your resume, if such feature is available on the Site we will treat such personal information as confidential and use it only to consider you for current and future employment opportunities and to contact you with respect to employment with us or our Affiliates (as defined). An “Affiliate” is a person or entity that directly or indirectly through one or more intermediaries, controls or is controlled by, or is under common control with, our company. We will retain your information for further recruitment opportunities that may arise, unless you tell us that you no longer wish for us to retain your information.

Technologies That Allow Us to Customize Your Experience on Our Site

We use various technologies to collect information (such as your web request, Internet Protocol address, browser type, browser language, the date and time of your request) about your visit to our Site and to enhance and customize your experience on our Site. For example, we may collect the Internet Protocol (IP) address identifying your computer or device and indicating your geographic region for statistical purposes. In some instances, we may use these technologies in combination with the personal information you provide on the Site. These technologies may provide a variety of information such as whether you have visited our Site before. They also may enable you to save your preferences. Each technology is explained below.

Web Beacons and Tracking Links

Web beacons (also called clear gifs and pixel tags), tracking links and/or similar technology consist of a few lines of code and are embedded on the pages of our Sources. They are often used in combination with cookies and are often not visible to the user of the Site. Web beacons may relay information to third parties such as our service providers and may be used in order to track customer response to certain advertising, to better target interactive advertising and to enhance customer support and usability. If you reject our cookies (see Cookie section below), you will prevent Web beacons from relaying this information about you and may limit your use of some of our Site features.

Cookies

Browser cookies are bits of text that are placed on your computer’s hard drive when you visit our Site. Flash cookies are similar to browser cookies except that they can store data more complex than simple text and are stored in your browser rather than on your hard drive.

You can have your browser and/or plugs to your browser, such as flash, notify you of, or automatically reject, cookies. If you reject our cookies or opt-out of the use of cookies, you may still use this Site, but you may be limited in the use of some of its features.

Third Party Web Analytics Services

We may use third party web analytics services on this Site or our mobile applications or other Sources, 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 the Site. To exercise your choice with respect to their collection of information on the Site:

• For Adobe Site Catalyst, please click here.
• To disable the Google Analytics cookie and any 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.

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 or the information provided by you on the digital registration process in the brick and mortar stores which distribute our products. To clarify, we do not own or operate such stores and all such stores are operated by third parties. 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 our websites and other websites. This process also helps us manage and track the effectiveness of our marketing efforts. To learn more about these and other advertising networks and their opt-out instructions, please write to info@jomalone.in.

Information We Share and With Whom We Share It

We will not provide your personal information to third parties for their use in marketing their products or services to you without your consent, except as described in the Business Transfers Section below. In addition, we do not sell or otherwise disclose personal information about our Site visitors except as described here.

Estee Lauder Companies

We may share your personal information with our Affiliates that distribute and market Estee Lauder products (the “Estee Lauder Companies”). Estee Lauder Companies may use this information in accordance with this Privacy Policy including, if you have so elected, to send you Communications containing product information, cosmetic tips or promotions. If you prefer that we not share your personal information with Estee Lauder Companies, please do not provide it to us. We are unable to offer the benefits of Jo Malone London India Online to anyone who does not consent to the sharing of their personal information with Estee Lauder Companies or its Affiliates.

Third Parties

We may retain other companies and individuals to perform functions on our behalf consistent with this Privacy Policy. Examples include data analysis firms, customer support specialists, email vendors, webhosting companies and fulfilment companies (e.g., companies that coordinate mailings). Such third parties may be provided with access to personal information needed to perform their functions but may not use such information other than on our behalf and in accordance with this Privacy Policy. If you prefer that we not share your personal information with such Third Parties, please do not provide it to us.

In addition, in some instances, you may be offered the opportunity to consent to the sharing of your information with a third party such as an event or promotion co-sponsor. If you consent, we will share your information with such third party and the information you provide may be used by such third party for their own purposes and in accordance with their own policies.

Business Transfers

As we continue to develop our business, we might sell certain of our assets. In such transactions, user information, including personal information, generally is one of the transferred business assets, and by submitting your personal information on the Sources you agree that your data may be transferred to such parties in these circumstances. You may choose not to have your information transferred as a business asset by contacting us as described in Your Choices.

Compliance with Law

We may disclose information that is necessary to comply with any applicable law, regulation, legal process or obligation or governmental request. In addition, we may disclose any information when it is necessary to prevent physical harm or financial loss or in connection with suspected or actual illegal activity. We may also disclose your information to government agencies mandated under the law to obtain information for the purposes of verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment of offences.

Dealers/ distributors

We may also share information with our dealers, distributors, resellers, marketplace sellers which sell/ distribute Jo Malone London products.

Other than as set out above, you will receive notice when information about you might go to third parties and you will have an opportunity to choose not to share the information.

Transfer of Data to Third Parties in or Outside India

The Affiliates, Estee Lauder Companies and third parties who may receive your personal information in accordance with this Privacy Policy and the databases in which your personal information is stored shall be located in Dubai, as well as in the United States and other countries which may have varying legal protections applicable to personal information. All Affiliates, Estee Lauder Companies and third parties that receive your personal information are required to honor the privacy representations made in this Privacy Policy, regardless of where they are located.

Children’s Privacy

If you are under 18 years of age, you may browse our Site. However, you may not provide personal information to us through any Sources. For example, you cannot register with Jo Malone London India Online through the Sources. The Site is not designed for persons under the age of 18 and we do not knowingly collect personal information from anyone under the age of 18. If we become aware that we have inadvertently received personal information from a visitor under the age of 18 on the Site or at other Sources, we will delete the information from our records and will not use such information to contact the provider of such information.

How We Protect Personal Information

Your personal information will be stored on systems owned or operated by Jo Malone London India Online or those of our specific suppliers. All our supplier contracts mandate that they comply with this privacy policy and our security policies. Your information will be stored on secured systems and will be encrypted during transmission and storage, in accordance with the Estee Lauder Information Security Policy.

Estee Lauder Companies and Jo Malone London India Online follow the US National Institute for Science and Technology (NIST) Cyber Security Framework. Our Information Security Policy and security standards follow this NIST framework and are implemented globally.

Our security controls are tested and audited regularly, and we are PCI-DSS certified. If you have any questions about security at Jo Malone London India Online, you can send an email to info@jomalone.in.

Retention of Personal Information

Personal Information will not be retained for a period more than necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required by or permitted under applicable law.

Updates/ Revisions to Our Privacy Policy

We may revise this Privacy Policy from time to time without any prior notice. If we decide to change our Privacy Policy, we will post the revised policy here. We suggest that you periodically consult this Privacy Policy. Please find the effective date of the Privacy Policy at the top of this page.

Your Choices

Updating Your Information

You have the ability to review, change or request deletion of your personal information by sending an email to info@jomalone.in and consequently your information will be updated in the records. You will not be required to provide a fresh subsequent consent in case of changing any personal information in accordance with this Section. Opt-Out and Managing Your Preferences

You permit Jo Malone London India Online to contact you through the personal information provided by you by any means of Communication (Email, Calls and/or Text Messages). You may change your preferences with respect to the type of Communication at any time by emailing us at info@jomalone.in. You may also choose not to receive any type of Communications by emailing us at info@jomalone.in and specifying that this is your preference.

Withdrawing Consent

You may withdraw any consent you previously provided to us by emailing us at info@jomalone.in, 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 services.

Data Controller / Data Processor

Jo Malone London India Online will assume control and responsibility for the personal information that you provide to us. Estée Lauder Cosmetics Limited, Constellation House, 3 Kites Croft Business Park, Warsash Road, Fareham, PO14 4FL, England, and ELC Online Inc., 40 W 23 Street, New York, New York, 10010 will collect, host, and process such personal information.

Comments/ Grievances

We have taken great measures to ensure that your visit to our Site is an excellent one and that your privacy is constantly respected. If you have any questions, comments, grievances or concerns about our privacy practices or with respect to processing of information, please contact the grievance officer at:

Name: Joanna Huang

Email: corporate@in.estee.com

Address: ELCA Cosmetics Private Limited, Unit 904, 905, 906, 9th Floor, Godrej BKC, Plot C-68, G Block, Bandra Kurla Complex, Bandra East, Mumbai, 400 051, India

Telephone number: +91 22 6147 9800

The grievance officer shall redress the grievances of provider of information expeditiously but within one month from the date of receipt of grievance.

If you have questions related to the means of Communication, please contact us at info@jomalone.in.