UK Site

INFORMATION WE COLLECT AND HOW WE USE IT

PRIVACY POLICY

GENERAL

Your privacy is important to us, and this Privacy Policy (“Privacy Policy”) together with our Terms of Use and any other documents referred to on it, will tell you what information we collect, how we protect it, and what choices you have about how the collected information is used.

For the purposes of this Privacy Policy, the term “Personal Data” means any information which identifies you or which allows you to be identified when combined with other information.

Important information and who we are

For purposes of this Privacy Policy, the data controller is KOSÉ Corporation, European Branch of Königsallee 92a, 40212 Düsseldorf, Germany (“we”, “us”, “our”).

The words “you” and “your” refers to each user of the website located at decortecosmetics.co.uk (“Site”). All capitalised terms used but not defined herein shall have the meanings set forth in the Terms of Use.

By visiting the Site you are accepting and consenting to the practices described in this Privacy Policy.

Our Site, products and services are not intended for children and we do not knowingly collect data relating to children.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

Full name of legal entity: KOSÉ Corporation, European Branch

Title of data privacy manager: Data Protection Representative

Email address: dataprotection@decortecosmetics.co.uk

Postal address: Königsallee 92a, 40212 Düsseldorf, Germany

You have the right to make a complaint at any time to the North Rhine-Westphalia Commissioner for Data Protection and Freedom of Information (LDI NRW) the German supervisory authority for data protection issues in North Rhine-Westphalia https://www.ldi.nrw.de/. We would, however, appreciate the chance to deal with your concerns before you approach the LDI NRW so please contact us in the first instance.

Changes to the Privacy Policy and your duty to inform us of changes

This version was last updated on 5th July 2018.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

INFORMATION WE COLLECT AND HOW WE USE IT

  1. The data we collect about you

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together follows:

  • Identity Data includes first name, maiden name, last name and title.
  • Contact Data includes billing address, email address and telephone numbers.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us including the type of card used for a particular transaction (but not any other card details).
  • Technical Data includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, authorisation tokens where integrations have been made by you to our services, operating system and platform and other technology on the devices you use to access this Site.
  • Profile Data includes your purchases or orders made by you, your interests, preferences, feedback, product reviews and survey responses.
  • Usage Data includes information about how you use our Site, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

  1. How is your Personal Data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Profile Data by filling in forms or by corresponding with us by post, phone, email, online or otherwise. This includes Personal Data you provide when you:
  • purchase products from our Site;
  • complete a form on our Site requesting us to contact you;
  • request our catalogue or other publications to be sent to you;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey;
  • submit a product review; or
  • give us some feedback.
  • Automated technologies or interactions. As you interact with our Site, we may automatically collect Technical Data about your equipment and Usage Data about your browsing actions and patterns. We collect this Personal Data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.
  • Third parties or publicly available sources. We may receive Personal Data about you from various third parties as set out below:
  • Technical Data from the following parties:
    • analytics providers;
    • advertising networks; and
    • search information providers.
  • Contact and Transaction Data from providers of payment services.
  1. How we use your Personal Data

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your Personal Data other than where you ask us to use your Personal Data to send you our catalogue, newsletters or other direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us using the contact details above.

  1. Purposes for which we will use your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please by contact us using the contact details above if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity

(b) Contact

(c) Profile

(a) Performance of a contract with you (where you are using the Site as an individual)

(b) Necessary for our legitimate interests (where you are using the Site as an authorised user of one of our enterprise customers, in order for us to perform our contract with that customer, to optimise your onboarding and user experience by ensuring you receive relevant instructions and tutorials regarding the use of our Site, products and service)

To process and deliver orders for our products   including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Transaction

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(c) Dealing with your enquiries and complaints

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our Site, products and services)

To enable you to submit product reviews, partake in a prize draw, competition or complete a survey (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our Site, products and services, to develop them and grow our business)

To administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To make claims or defend claims in relation to our Site, products and services (a) Transaction Necessary for our legitimate interests (to ensure we are able to resolve disputes with customers relating to our Site, products and services)
To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

 

Necessary for our legitimate interests (to study how customers use our Site, products and services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Site, products and services, marketing, customer relationships and experiences (a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

(a) Consent

(b) Necessary for our legitimate interests (to develop our products/services and grow our business)

  1. Marketing

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at the above contact details at any time.

  1. Sharing Information with Affiliates and Service Providers

We may have to share your Personal Data with the parties set out below for the purposes set out in the table above.

  • our affiliates who provide IT and system administration and other shared services.
  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • Our third party advertising partners to advertise products and services to you on third party sites which are tailored to meet your preferences and likely interests.
  • Our third party analytics partners to analyse Site traffic and understand customer needs and trends.
  • Third parties if we are required to do so by law, or if we believe that such action is necessary to: (a) fulfil a government, or regulatory authority request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Site or customers.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

WHERE WE STORE YOUR PERSONAL DATA

Our affiliates and third party service providers may be based outside the European Economic Area (EEA) so their processing of your Personal Data will involve a transfer of data outside the EEA.

Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal Data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.

DATA RETENTION

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.  Some of your data may be retained by us after you cease using our Site and services, including on backups, where it is in our legitimate interests to do so.

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

You can request further details of retention periods for different aspects of your Personal Data by contacting us.

In some circumstances you can ask us to delete your data: see “Your Rights” below for further information.

In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 YOUR RIGHTS

Under certain circumstances, you have the following rights under data protection laws in relation to your Personal Data:

  • Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
  • Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

THIRD-PARTY WEB SITES

This Privacy Policy applies only to the Site. This Site may contain links to other sites. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our Site and to read the privacy policies of each and every web site that collects Personal Data.

SECURITY

We maintain physical, electronic, and procedural safeguards to help guard Personal Data. Please be aware, however, that any email or other transmission you send through the Internet cannot be completely protected against unauthorised interception.

In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

CHANGES TO THIS PRIVACY POLICY

We may revise this Privacy Policy from time to time. If we decide to change our Privacy Policy, we will post the revised policy here. As we may make changes at any time without notifying you, we suggest that you periodically consult this Privacy Policy. Please note that our rights to use Personal Data will be based on the privacy policy in effect at the time the information is used.