Jo Malone London Privacy Policy

Last updated: 16th March 2020

Jo Malone London and Estée Lauder Pty. Limited (ABN 63 008 444 719) (collectively, “we”, “us”, or “our”) respect your concerns about privacy and value the relationship we have with you. This Privacy Policy describes the types of personal information we collect about our customers, how we may use the information, with whom we share it, and the choices available to our customers regarding our use of the information, in compliance with the requirements of the Australian Privacy Act 1988 (Cth) (Privacy Act) and any other related laws regulating the handling or use of personal information (Privacy Laws), and any other applicable laws. Our Privacy Policy also describes the measures we take to protect the security of the information and how our customers can contact us about our privacy practices.

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INFORMATION WE COLLECT

We may obtain personal information about you from various sources. We may collect this information when you provide it at our counters or in stores, on our website, or in connection with our social networking or mobile applications, or at one of our events. Unless otherwise stated, this Privacy Policy does not address any data collection by our retail partners.  When you visit our site, our social media/ social networking pages (or their relevant platforms or corresponding mobile applications), or when you use the services or features of one of our mobile applications, we may also collect certain information about your device or usage by automated means or by using technologies such as cookies, web server logs and web beacons. 

"Personal information" is information about an identified individual or an individual who is reasonably identifiable. Personal information may also include sensitive information such as racial or ethnic origin or health information. 


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 that we may collect from you, if applicable, include:

  • Contact information (such as name, postal address, email address, and mobile or other phone number)
  • Age and date of birth
  • Gender and preferred language
  • Username and password  
  • Payment information (such as your payment method, 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 Privacy Laws
  • Contact information for friends or other people you would like us to contact with 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

If you have a Jo Malone London online store account, we will also collect your order and return request history and replenishment service selections, your reward points balance and redemption details associated with your account if applicable. If you register to be on a loyalty program list, we will also collect a record of your consent to join the loyalty program list and any subsequent opt out information and your anniversary date.

We do not collect health information about you without your consent.

For some services you may not be required to identify yourself. However, if you do not provide us with the information we request, we may not be able to contact you and may not be able to customise our services to suit you or provide you with information, products and/or services you have requested.

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, products 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 and elsewhere to your interests and history with us
  • Process and communicate with you about your orders and return requests
  • Communicate with you about, and administer your participation in, loyalty program, special events, contests, sweepstakes, programs, 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; analysing 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 as required, permitted or authorized by law or for which we provide specific notice at the time of collection. 
If you provide us with your personal information, we may use it for direct marketing purposes to offer or advertise the availability of our goods and/or services. However, we will not use your personal information for such purposes 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 (“Goods and Services”) directly to you using your personal information: 

  • Beauty and skincare products;
  • Hair care and hair styling products;
  • Hair dye;
  • Makeup;
  • 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. Please see the sections below for more information on our direct marketing communications and how to opt-out.

We, Estée Lauder Pty. Limited, being the operating company of Jo Malone London in Australia, are an affiliate of the Estée Lauder Companies (“ELC”) – a global leader which is dedicated exclusively to prestige beauty and the owner of a number of worldly renowned brands in the arena of cosmetics, beauty, fragrance industry, such as Estée Lauder, Bobbi Brown, Clinique, Jo Malone London, La Mer, M.A.C., Origins, etc. Please visit https://www.elcompanies.com/en  for further details on our company and brands. To share with you more of our multi-brands’ beauty tips and information through our connection with you, when you sign up for an account or program with us (e.g. membership account, loyalty program etc.), or when you receive services from us, in addition to any interaction that you may have with the brand that you originally have contact with, you may be invited by that brand (i.e. us) to subscribe to marketing materials of our multiple adjacent brands offered by our company as a whole. Upon your consent, the personal data you provided in the form, or the personal data you provided at the time when you consented to the said subscription, would simultaneously be used by us for that marketing purpose. Our handling of any data including data transfer issues concerned under this paragraph would remain consistent with what is provided in this Privacy Policy.

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 will, 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 Privacy Act. 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 our 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 devices 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. .To edit your cookie settings, click here:
  • 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 may also 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 our 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, a web analysis service of Google Inc. The service providers that administer these services use technologies such as cookies, web server logs and web beacons to help us analyse how visitors use our 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, compile reports on the website activities, and to provide additional services connected with the website. You may deactivate the ability of these analytic services to analyse your browsing activities on our site by adjusting the settings on your browser software, however, you may not be able to fully use all of the functions of our site if you do so. To learn more about web analytics services, and exercise your choice with respect to their collection of information on our 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.


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. 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 website and other websites. This process also helps us manage and track the effectiveness of our marketing efforts. To learn more about advertising networks and to opt out of interest-based advertising, visit the Digital Advertising Alliance at http://www.aboutads.info/choices or the Network Advertising Initiative at http://www.networkadvertising.org/choices.

We may also use third-party platforms, including platforms operated by social networks, such as Google, Facebook, 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 our 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 based on your 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 and 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-APPS 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, 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:  

  • Our affiliates within the Estée Lauder Companies umbrella of companies for the purposes described in this Privacy Policy or as otherwise specified in the notice provided at the time of collection. For additional information regarding our corporate affiliates, please see http://www.elcompanies.com/.
  • Service providers, licensees and/or joint venture partners who may be located overseas (including India, China, Singapore, South Korea, UK and US), and they may perform services on our behalf based on our instructions and send you direct marketing 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, support our returns process 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 adopt privacy practices in relation to the handling of personal data that is equivalent or even stricter level than as set out in this Privacy Policy.

In addition, we may disclose information about you without your consent (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. 

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 our 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 that information.


TEXT MESSAGING

If you so elect, you may provide your mobile phone number to Estée Lauder. By submitting your mobile phone number, you consent to receive text message alerts from Estée Lauder containing product and event information, cosmetics tips or promotions that may be sent using automated dialing systems (“Text Messages”). Your consent to receive Text Messages is not otherwise required to purchase any goods or services from us. You may not consent to receive Text Messages on behalf of someone else or provide someone else’s phone number. You agree to enter into, sign and receive your consent to receive Text Messages electronically. Print this page using your Internet-connected computer or device and web browser to retain a copy of your consent. You can contact us as set forth via the Contact Us Form to request a free copy of your consent.

You may receive approximately five texts per year. We do not charge a fee for you to receive Text Messages from us, however, your mobile service provider may charge you for sending and/or receiving text messages and air-time, as well as any other standard applicable rates charged by your mobile service provider.

Text Messages are distributed via third party mobile network providers and, therefore, we cannot control certain factors relating to message delivery or guarantee availability or performance of this service, including liability for transmission delays or message failures.

You may unsubscribe from receiving Text Messages any time by texting the word "STOP" back to the number used to send the marketing test message to your device. You may also choose not to receive Text Messages by emailing us via the Contact Us form here and specifying that this is your preference.

We may also obtain the date, time and content of your messages in the course of your use of Text Messages. We will use the information we obtain in connection with our Text Messages in accordance with this Privacy Policy.

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.

Email Opt-Out

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 Jo Malone by clicking here.


Postal Mail Opt-Out

You can ask Jo Malone 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 in the “How to Contact Us” section below.


Text Message Opt-Out

You can request that we refrain from sending you text messages by contacting us as indicated in the “How to Contact Us” section 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:

Geo-Location Information

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.



Withdrawing Consent

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 consumercare-au@gcc.jomalone.com with attention to our data protection officer. If you have a Jo Malone online store account, you may update your profile information yourself by logging into your account.

If you wish to have your personal information deleted, please let us know in the same manner as referred to above and we will take all reasonable steps to delete it unless we need to keep it for legal reasons.



DATA TRANSFERS

We may transfer the personal information we collect about you to countries other than the country in which the information was originally collected (including India, China, Singapore, Japan, South Korea, UK and US) and your personal information may be processed and stored outside your country of residence. These countries may not have the same data protection laws as the country in which you initially provided the information. However, when we transfer your information to other countries, we will protect that information as described in this Privacy Policy.



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.



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



HOW TO CONTACT US

If you have any questions, complaints or comments about this Privacy Policy, or if you would like us to update information we have about you or your preferences, please contact us by consumercare-au@gcc.jomalone.com  or telephone at 1800661062. You also may write to:

Privacy Officer
Locked Bag 1050
Rosebery 1445

We will investigate your complaint and will respond within a reasonable time.  If we fail to respond to your complaint or if you are dissatisfied with the response that you receive from us, you may have the right to make a complaint to the applicable privacy authorities.

In Australia, this is the Office of the Australian Information Commissioner (www.oaic.gov.au).



CHANGES

We will amend this policy if our practices change. Details of recent amendments and the date they were made will be detailed below.

Date

Details of change

27 October 2017

Updated 'Target Advertising' section to include targeted advertising onthird-party platforms, including social networks such as Google and Facebook.

16 March 2020

Updated "Information You Provide", "How We Use The Information", and "Reviewing, Updating and Modifying Personal Information" and "Email Opt Out" to include specifics regarding the Jo Malone London online store, the loyalty program, the product return process, the collection of location and sensitive information..


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