Complice Skin

PRIVACY POLICY LAST UPDATED 25. April 2022

We invite you to read this policy, which explains how your personal data are processed by the company listed in the data controllers and contact section below (“Complice Skin”, “we”, “us”).
It also tells you how you can access and update your personal data and make certain choices about how your personal data is used including a right to object to some of the processing (including personalized marketing) we carry out or where we rely on your consent, a right to withdraw this consent.

 This policy covers our data collection activities, including personal data we collect through our various channels online (such as websites, apps, and social networks) and offline (such as at points of sale, customer service and events). It also explains how we collect information through the use of cookies and related technologies on our websites and apps. Certain sections may not be applicable to you depending on how you provide your personal data to us or interact with Complice Skin. Please note that we combine personal data that we collect via one channel (e.g. Complice Skin website) with personal data we collect via another channel, which can include combining personal data that were originally collected. More information about these activities is set out below.
If we change the way we handle your personal data, we will update this policy and notify you or seek your consent as and when appropriate, usually by placing an updated policy on our websites. If we make significant changes that materially alter our privacy practices, we may also notify you by other means, such as sending an email prior to the changes taking effect. We reserve the right to make changes to our practices and this policy at any time. We invite you to check our platforms from time to time for any updates or changes to this policy.
We may also provide you with additional information when we collect personal data where we feel it would be helpful to provide relevant and timely information.

We obtain personal data from or about you from various online and offline sources including when you: (i) interact with our websites listed on http://www.compliceskin.com or mobile sites/applications (together “the Platforms”); (ii) interact with us on our social media pages, chat services, forums or blogs; (iii) visit one of our boutiques, stores or counters; (iv) participate in our events and demonstrations, loyalty or other client programs, competitions, promotions or surveys; or (v) participate in beauty consultations or interact with our beauty advisors and customer service.
Our products are sold through various authorized retailers. Unless otherwise indicated at the time that you provide your personal data, any personal data that our retail partners collect is not provided to us and this policy does not apply to such personal data.
We collect the following personal data:

• Information provided by you (for example, by creating a web account with us, signing up to our loyalty or other client programs, or by providing information about yourself to us at one of our boutiques, stores or counters):
• Contact information (such as your name, phone number (home and mobile), home address and email address);
• Age, date of birth, gender, nationality, preferred language, interests and lifestyle; billing information (including delivery address and payment details).

We reserve the right to request additional evidence or proof of billing information where, in our reasonable opinion, this is necessary. Please note we do not keep your payment card details on file (except where required for refund purposes).
Website registration credentials (including username and password). By creating an account, you can securely store your debit and credit card information (held by our third party service provider) for easier and faster checkout, store and edit your delivery addresses and billing information and review your previous purchases and order history;
expressed personal preferences (such as communication and language settings); interactions with us (such as your transaction history or information about your physical characteristics and skincare concerns obtained through a beauty consultation or survey or when you visit our social media pages, blogs or forums or interact with customer service or our chat service); and/or
correspondence and communication between us and you.
In addition, we sometimes run promotions or events where you can tell us about someone known to you who may be interested in our products and services. If this person gives you their permission to provide us with their details, then we will only use their information for that reason and not to send them any other unrelated offers. We may also mention that it was you who made the referral in the message that we send to them.
We do not knowingly collect information about minors.
Information automatically collected from your use of our platforms, social media pages or interaction with our online adverts.
We automatically collect the following information:
technical information, including your device’s IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system, unique device identifiers and advertising identifiers; and information about your visit, including the URL clickstream to, through and from our platforms (including date and time); products you viewed or searched for, the content (and any ads) that you view or interact with, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. Some of this information is collected using cookies and related technologies.

Information collected from third party sources
From time to time (where permitted by applicable law), we collect information such as your preferences, interests and other demographic data from trusted third party sources that are either publicly or commercially available (e.g. business and retail partners, payment and delivery services, social media networks, advertising networks, analytics providers, and search information providers) which will be used for the purposes outlined in this policy. We also receive personal data you provide to authorised distributors of our products and services which will be used for the purposes outlined in this policy.

When you pay for your products (either in-store or online), we get information from our payment processing service provider who will carry out credit and antifraud checks on you and the payment method you provide in order to verify your identity, to validate your credit or debit card, to obtain an initial credit or debit card authorization and/or to authorize individual purchases.
In order to ensure data accuracy and to offer you a better customer experience, we link or combine the information that we collect from the different sources and channels outlined above to provide personalized services, content, targeted communications and advertising. (e.g. we combine data about your online purchases with information gathered from our boutiques, stores and counters such as details from a beauty consultation so that we can provide you with personalized offers and skincare recommendations in accordance with your communication preferences). This includes combining personal data collected by Complice Skin.
You do not have to provide personal data to access the platforms but certain functionalities (such as being able to buy our products via the website) will not otherwise be available to you. You may however choose whether or not to receive marketing communications from us and we will only send you such communications where we have the appropriate consent to do so.
You must not provide information about anyone else unless you have their permission to do so.

We process your personal data for the reasons set out below:
To fulfil a contract or take steps linked to a contract: this is relevant where you make a purchase from us:
This includes:

• Setting up and managing your online account on our platform.
• Fulfilling orders and processing your transactions (including the processing of your payment details, credit card checks and fraud prevention activities); these checks may be required, amongst other things, to verify your identity, to validate your credit or debit card, to obtain an initial credit or debit card authorization and/or to authorise individual purchases; and
• Send service-related communications and to respond to your enquiries.

Where this is necessary for the purposes which are in our, or third parties legitimate interests.
These interests are:

• To allow you to participate in the interactive features of the website;
• To ask your opinion or to take part in market research
• To provide you with personalized services, content, targeted communications, and advertising both on our platforms and other selected partner websites, loyalty, and other client programmes.

We may do this by linking or combining the information that we collect from the different sources and channels outlined above or by creating segments based on various factors such as your age and gender or your inferred interests. We work with data management platform providers to assist with this process. Some of these activities may involve the use of cookies and other similar technologies to monitor your account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime in accordance with applicable law;

• to investigate any complaints received from you or from others about our platforms or our products and services and
• to monitor use of our platforms and use your information to help us monitor, improve and protect our products, content, services and platforms, both online and offline and your experiences with us including via research and demographic studies; analytics and data cleansing and measuring the effectiveness of our advertising campaigns;
• to use personal data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such personal data in connection with legal process or litigation) or to enforce or apply our terms of use or any other agreements; or to protect the rights, property, or safety of Complice Skin our customers, or others;
• for our internal corporate reporting purposes.

Where you give us consent:
where you ask us to tell you about our products, services, promotions and events by telephone, post, SMS, e-mail or online or via our applications or to send you samples, gifts and rewards in accordance with your communications preferences and to the extent permitted by applicable laws. This includes being contacted by any of our group companies for these purposes, where you give us consent to place cookies and related technologies in accordance, on other occasions where we ask for your consent, for the purpose for which we explain at the time.

For purposes which are required by law
In response to requests by government or law enforcement authorities conducting an investigation.

Disclosure of your personal data
In addition to the Complice Skin company mentioned in the data controllers & contact section below, we may share your personal data: (where permitted in accordance with applicable privacy laws) with:

• other companies in our group for the purposes outlined above.
• authorized distributors for the purposes outlined above;
• banks and our payment services provider for the purpose of transaction processing;
• third parties, where we have your permission to do so (e.g. social networks providers, concierge service or our retail partners). Your personal data will become subject to the privacy policies of those third parties when your personal data is shared with them;
• prospective or eventual buyers of our business;
• any law enforcement agency, court, regulatory, government authority or other third party where in our reasonable opinion this is necessary to comply with a legal or regulatory obligations or otherwise to enforce or apply our terms of use or any other agreements; or to protect the rights, property, or safety of Complice Skin, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; or

• our third party service providers, who perform services on our behalf based on our instructions. We do not authorize these parties to use or disclose the information except as necessary to perform services on our behalf or to comply with legal requirements. Examples of these parties include companies that fulfill orders and manage refunds, and provide data hosting and support, content personalization, advertising and marketing services (including digital and personalized advertising) and data cleansing, management, segmentation and analysis.

We also share information with third parties including social media and search engine partners:
We aggregate your personal data with the information of other customers, creating a dataset of information about the usage of our platforms, purchase of our products, and other general, grouped information about our customers. Although this dataset is aggregated and anonymised, meaning it cannot directly identify you as an individual, it provides a valuable insight into the use of our platforms and we will share it with select third parties.
We also transfer information about you to ad technology providers and our social media and search engine partners (including Facebook, Google and Twitter) so that they may recognize your devices and deliver interest based content and advertisements. The information can include your name, postal address, email, device ID, or other identifier in encrypted form. The providers often process the information in hashed or de-identified form. These providers can collect additional information from you, such as your IP address and information about your browser or operating system; combine information about you with information from other companies in data sharing cooperatives in which we participate; and may place or recognize their own unique cookie on your browser. The third parties that generate these cookies have their own privacy policies and we have no access to read or write these cookies.

Data Transfers
We also transfer personal data about you (whether collected online or offline) to our company and other service providers who perform functions on our behalf which are based around the world including in countries outside of the European Economic Area (EEA) and Switzerland and this information may be stored and processed in those countries which may have different data protection standards to those which apply in your country of residence.

Data Retention
Your personal data will be retained for a certain period of time based on the following criteria: (i) as long as necessary to fulfill the purposes outlined in this policy; (ii) any applicable legal requirements; or (iii) any request for deletion from you in applicable situations. Personal data used to provide you with personalized communications and services will be kept for a duration permitted by applicable laws.