Effective Date: 1st January 2022
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- INFORMATION WE COLLECT
- INFORMATION YOU PROVIDE
- HOW WE USE THE INFORMATION
- INFORMATION WE COLLECT BY AUTOMATED MEANS
- HOW WE USE THE INFORMATION COLLECTED BY AUTOMATED MEANS
- INFORMATION WE SHARE
- YOUR RIGHTS AND CHOICES
- DATA TRANSFERS
- HOW WE PROTECT PERSONAL INFORMATION
- LINKS TO OTHER WEBSITES
- HOW TO CONTACT US
INFORMATION WE COLLECT
Device identifiers, such as information about your device like your MAC address, IP address, or other online identifiers.
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 on our site, at our counters or in our stores. The types of personal information you may provide to us, if applicable, includes:
- Contact information (such as name, postal address, email address, and mobile or other phone number)
- Age and date of birth
- Ethnicity, gender, preferred language
- Username and password
- Payment information (such as your payment card number, expiration 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 (sensitivities or allergies) and medications for the same that may be deemed sensitive personal information under applicable laws
- Contact information of friends or other people you would like us to contact under their consent
- Content you provide (such as photographs, videos, reviews, articles and comments)
- Information provided to us through social media networks or one of our mobile applications when you visit our social media pages, register for our site or loyalty program using a social media account or use one of our mobile applications (such as your name, profile picture, likes, location, friend list and other information described on the social media network or in 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 to:
- 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 online account, including access to your online and in-store purchase history
- Assist with product selection and replenishment, including through our customer registry
- Administer our membership list and loyalty program list
- 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;
- 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.
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 Protection Act 2010 of Malaysia (“PDPA”). 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 And Web Beacons
- Cookies: Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. Please note, however, that without cookies you may not be able to use all of the features of our website.
- 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 logs also may record information such as the address of the web page that linked you to our site and the 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. These 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.
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.
We may also use third-party platforms, including platforms operated by social networks, such as Google, Facebook and 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 & 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:
- 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 and marketing services.
- Other third parties through social networks, widgets and plug-ins with your consent. 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 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.
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.
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.
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 Bobbi Brown by CLICKING HERE.
Postal Mail Opt-Out
You can ask Bobbi Brown to stop sending you marketing communications by postal mail by following the instructions that may be included in a particular promotion mail. You also can request that we refrain from sending you promotional postal mail 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: http://www.facebook.com/help.
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.
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. Subject to applicable law, you may 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 email@example.com with attention to our data protection officer.
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.
HOW TO CONTACT US
Bobbi Brown Malaysia
Estee Lauder Malaysia Sdn. Bhd.
Suite 18.01, Level 18,
Centrepoint South, The Boulevard,
Mid Valley City, Lingkaran Syed Putra,
59200 Kuala Lumpur,