THE COMPANY I KEEP WEBSITE PRIVACY POLICY

Last updated: July 31, 2020

Thank you for visiting The Company I Keep website (the “Site”). The Site is hosted by The Estée Lauder Companies Inc. (“we, us, or our”). We respect your privacy and value the relationship we have with you. This Privacy Policy describes the types of personal information we collect, how we use the information, with whom we share it, and the choices available regarding our use of the information. We also describe the measures we take to protect the security of the information and how to contact us about our privacy practices.

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INFORMATION WE COLLECT

We collect or may have collected the following categories of information about you.

  • Online or network activity information, such as information regarding your interaction with our Site, other digital properties, and advertisements, information about your browsing and search history on our Site, and log file information which includes, but may not be limited to, your browser type, webpages you visit, and other electronic network activity.

HOW WE COLLECT INFORMATION

We may collect or may have collected personal information about you from various sources. The categories of sources from which we collect personal information are:

  • Cookies and automatic collection methods. When you visit our Site, and when you open or click on emails we send you, we, and third parties we work with, may automatically collect information from your browser or device using technologies such as cookies, web beacons, pixel tags, and similar technologies. 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. Web beacons or pixel tags are small images which are embedded into our Site or emails that provide us with information about your browser or device, or whether you open or clicked on the emails we send you. These technologies enable us, or the third parties who place such technologies, to collect information such as device identifiers and online or other network activity information.

HOW WE USE THE INFORMATION WE COLLECT

We may use or may have used the information we have about you:

  • For analytics purposes, such as to understand how you use our Site, determine what browser and devices you use to visit our Site; and to evaluate and improve our Site.
  • To operate and improve our business, including to conduct research and development, and perform accounting, auditing and other internal business functions.
  • For legal and security purposes, such as to detect, prevent, and prosecute harmful, fraudulent, or illegal activity, loss prevention, identify and repair bugs on our Site, and to comply with applicable legal requirements, relevant industry standards and our policies.
  • Other short-term, transient use.

 

We also may use the information in other ways for which we provide specific notice at the time of collection.

Where required by law, we will use the personal information you provide for the above purposes if:

  • we have obtained your consent; or
  • we have a legitimate interest in doing so (including a legitimate interest in performing marketing activities, research activities, data analytics, and internal administration functions, processing and enforcing legal claims, and conducting our business in compliance with all applicable laws, relevant industry standards and our policies).

INFORMATION WE SHARE

We may share or may have shared your personal information with:

  • Service providers. We may transfer personal information to service providers who perform services on our behalf based on our instructions. 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 provide web hosting services.
  • Parties to a corporate transaction. 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 this 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 such information.
  • Other third parties. In addition, we may disclose personal 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, (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, (iv) when disclosure of your personal information is otherwise required or permitted by law, or (v) with your consent.

YOUR RIGHTS AND CHOICES

Your Privacy Rights

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 information, and have the personal information deleted, as appropriate. Subject to applicable law, you may also have the right to request the restriction of the processing of your personal information or to object to that processing on grounds relating to your particular situation, the right to withdraw your consent and to receive, in a structured, commonly used and machine-readable format, the personal information that you have provided to us where technically feasible. You may also lodge a complaint with your supervisory authority.

These rights may be limited in some circumstances by local law. We may take reasonable steps to verify your identity before granting access or making corrections. You may exercise your privacy rights be sending an email to [email protected].

COOKIES & ANALYTICS

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. We use Google Analytics cookies on our Site, including performance cookies and functional cookies to help us evaluate and analyze how visitors use the Site. You may be able to change the settings to have your browser refuse certain cookies or notify you before accepting cookies. Please note, if you choose to opt-out from certain cookies, some features of the Site may no longer work properly. The procedures for changing your settings and cookies differ from browser to browser. If necessary, use the help function on your browser or click on one of the links below to go directly to the user manual for some commonly used browsers.

Do Not Track and Advertising Across Different Websites

We currently do not change our tracking practices in response to “do-not-track” signals or other similar mechanisms. Third parties that have content or services on our Site such as a social feature, analytics service, or an advertising network partner, may obtain information about your browsing or usage habits. These third parties do not change their tracking practices in response to “do-not-track” signals from your web browser and we do not obligate these parties to honor “do-not-track” signals. To learn more about browser tracking signals and “Do Not Track,” please visit https://allaboutdnt.com/.

Analytics Services

We may use analytics services, such as Google Analytics, on our Site, our social media pages to help us evaluate and analyze how visitors use these platforms. For specific details on how Google collects and uses information on our Site please visit: How Google Uses Data.

INTERNATIONAL TRANSFERS

We may transfer the personal information we collect about you to our affiliates and third party service providers in countries other than the country in which the information was originally collected (including the United States), where necessary to fulfill the purposes described in this Privacy Policy and your personal information may be processed and stored outside of your country of residence. Those countries may not provide the same level of data protection as your country of residence. When we transfer your personal information to other countries, we will protect that information in the manner described in this Privacy Policy. We have also implemented appropriate safeguards to ensure such a level of data protection when transferring your personal information, including the conclusion of data transfer agreements incorporating the European Commission’s Standard Contractual Clauses, or using U.S. service providers certified to the EU-U.S. Privacy Shield as set forth by the U.S. Department of Commerce and the European Commission regarding the collection, use and retention of personal information transferred from the European Economic Area to the United States, or other applicable data transfer mechanisms. You may obtain a copy of these data transfer mechanisms by contacting us as indicated below.

CHILDREN’S PRIVACY

This Site is not intended for or directed to children under the age of thirteen and we do not knowingly collect personal information from children under the age of thirteen on the Site. If we become aware that a child under the age of thirteen has provided us with personal information, we will delete the information from our records.

DATA RETENTION

We keep the personal information you provide for the duration of our relationship, plus a reasonable period of time thereafter.

HOW WE PROTECT INFORMATION

We maintain reasonable 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.

Our Site may provide links to other websites for your convenience and information. These websites may operate independently from us. Linked websites 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 websites’ content, any use of the websites, or the privacy practices of the websites.

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 Site to notify you of any significant changes to our privacy practices and indicate at the top of the Privacy Policy when it was most recently updated.

HOW TO CONTACT US

If you have any questions or comments about this Privacy Policy, or the manner in which we or our service providers treat your personal information, please contact us at [email protected].

ADDITIONAL RIGHTS AND DISCLOSURES FOR CALIFORNIA RESIDENTS

Disclosures of Personal Information

We may disclose or may have disclosed your personal information to certain categories of third parties, as described below.

Category Disclosed to Third Parties
Online or network activity information We may disclose or may have disclosed this information to:

  • service providers
  • law enforcement authorities or other government officials where required or permitted by law

 

These disclosures take place for the following business or commercial purposes:

  • To audit our interactions with you to ensure compliance with applicable law and to measure the effectiveness of Site;
  • To detect, prevent, and prosecute harmful, fraudulent, or illegal activity;
  • To identify and repair bugs on our Site; and
  • To further our business goals.

 

The disclosure of personal information for which we receive valuable consideration (i.e., the receipt of some benefit other than money) is considered a “sale”. We do not sell your personal information in connection with the Site.

Your California Privacy Rights

You have the right to request, twice in a 12 month period, that we disclose to you the personal information we have collected, used, disclosed, and sold about you during the past 12 months. In addition, you have the right to request that we delete the personal information we have collected from you (subject to certain exceptions).

You can exercise your rights by sending an email to [email protected]. Before processing your request, we will take reasonable steps to verify your identity, which will include verifying that the email address from which you submit the request matches the email address we maintain on file for you. In order to ensure you are the owner of the email address, you must respond to a confirmation email that we will send to such email address. In some cases, we may ask that you provide additional information in order to verify your identity.

You may also designate an authorized agent to make a request on your behalf. The authorized agent may submit the request by sending an email to [email protected] and will be required to provide proof that they have been authorized to act on your behalf. If the authorized agent does not provide such proof, you will be required to confirm your identity and the authenticity of the request.

We will not discriminate against you on account of your exercise of your California privacy rights.