Privacy Policy
Last updated: 05/06/2018
Your privacy is important to us, and we understand how important it is to you. Our aim is to be as clear and open as possible about what we do and why we do it.
We've set out all the details below.
Please take the time to read and understand this policy.
To help you, we've included some links to other websites. It's worth remembering though that other people, not us, control these websites. We're not responsible for them.
Seventh August IT Services Pvt. Ltd. (“Company”) is the operator and licensee of www.artoreal.com
(“Website”) And the Company can be contacted by clicking Contact Us.
a) Direct interactions
You may give us your Identity, Contact, Special Category and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes sharing of personal data for the following purpose
b) Automated technologies or interactions.
Log Files. Log information is data about your use of the Service, such as IP address, browser type, referring/exit pages, operating system, date/time stamps, and related data, which is stored in log files.
Cookies. A cookie is a small data file transferred to your computer (or other device) when it is used to access our Service. Cookies may be used for many purposes, including to enable certain features of our Service and remember your preferences, your equipment, browsing actions and patterns, to better understand how you interact with our Service, to provide you advertising on and off the Service, and to monitor usage by visitors and online traffic routing. You may be able to instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the online services you visit. If you do not accept cookies, however, you may not be able to use all portions of our Service or all functionality of our Service. Please see our cookie policy for further details.
c) Third parties or publicly available sources.
We may receive aggregated personal data about you from various third parties as set out below:
What sort of personal data do we collect?
We may collect, store, and use the following categories of personal information about you:
a) Identity Data
b) Contact Data
c) Financial Data
d) Transaction Data
Details about payments to and from you and other details of products and services you have purchased from us. These include:
e) Technical Data
f) Profile Data
g) Usage Data
h) Marketing and Communications Data
Your preferences in receiving marketing from us, our third parties, and your communication preferences.
i) Aggregated Data (sometimes referred to a pseudonymised data)
We also collect, use and share Aggregated Data (sometimes referred to a pseudonymised 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 website 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.
j) Special Category Data
We do not collect, store and use the following “special categories” of more sensitive personal information regarding you.
We will only use your personal information when the law allows us to. We will use your personal information in the following circumstances:
a) Legitimate Interest
We may also use your personal information in the following situations, which are likely to be rare:
b) Purpose/ activity, type of data and lawful basis for processing
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 contact us 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.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
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 |
(a) Registering or Performance of a contract with you (b) Your consent (c) Necessary for our legitimate interest to set up and manage your account |
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to fulfil your order or 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) Responding to your queries and comments, social media posts and questions. |
(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 products/services) (d) Your consent |
To administer and protect our business and this website (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 deliver relevant website 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 products/services, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics gathered from our website to improve our website, products/services, marketing, customer relationships and experiences |
(a) Technical (b) Usage (c) Aggregated Data |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website 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) Aggregated Data |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
To power our security measures and services in order to protect you and our business |
(a) Identity (b) Technical (c) Usage
|
Necessary for our legitimate interest so you can safely access our website and mobile apps. It also lets us do things such as recognise your username and password, as well as reset them if you happen to forget what they are. |
c) Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
d) Promotionaloffersfromus
If you have expressly opted-in to receive marketing from us 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 (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
e) Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside artOreal for marketing purposes.
f) Opting out
You can ask us or third parties to stop sending you marketing messages at any time by clicking Contact Us.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service subscription / purchase, product/service experience or other transactions.
g) Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
On occasion we may have to share your personal data with the parties set out below for the purposes set out.
a) Internal Third Parties
Companies, brands and businesses within our group. For example, we’ll share information from our online business with www.tumbhi.com and there are similar arrangements between our other online businesses. This is because we hope to have a relationship with you across all our different brands and businesses, if not now, then sometime in the future and we want to be able to provide you with the same value-for-money, high quality experience whenever and however you sell / shop with us. It’s also the only way we can provide you with the best benefits.
b) External Third Parties
c) International Transfers
We share your personal data within the artoreal Group on need to know basis with confidential obligation mentioned here in. This may involve transferring your data outside the European Economic Area ( EEA).
Some of our external third parties are 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 securely 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 how we transfer your personal data out of the EEA.
A lot of the information we receive reaches us electronically, originating from your devices, and is then transmitted by your relevant telecoms network provider.
Where it's within our control, we put measures in place to ensure this 'in flight' data is as secure as it possibly can be.
Once it arrives at artoreal, you can be sure we take the security of your information very seriously.
We use appropriate procedures and technical security measures (including strict encryption, anonymisation and archiving techniques) to safeguard your information across all our computer systems, networks, websites, mobile apps and offices.
Sensitive data like, Passwords are protected for both data in transit and data at rest by data encryption. In addition to encryption, we have implemented robust network security controls to help protect data in transit. Network security solutions like firewalls and / or network access control to secure the networks used to transmit data against malware attacks or intrusions.
We use secure means to communicate with you where appropriate, such as 'https' and other security and encryption protocols.
If you have any concerns about the security of your own personal computers and mobile devices, we suggest you read the advice of ‘Get Safe Online’, which can be accessed here.
To make sure we meet our legal data protection and privacy obligations, we only hold on to your information for as long as we actually need it for the purposes we acquired it for in the first place.
In most cases, this means we will keep your information for as long as you continue to shop with us or use our services, and for a period of time afterwards if you stop doing so just in case you begin shopping with us again.
After that we will either delete it or anonymise it so that it cannot be linked back to you.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 5 years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure 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.
a) Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes by keeping your details up to date on your artoreal online account.
b) Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
c) Fees for excessive or unreasonable requests
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
d) 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
The artOreal Data Protection Officer (DPO) oversees compliance with this privacy policy. If you have any questions or concerns about this Privacy Policy or how we handle your personal information, please contact the DPO at privacy@artoreal.com.
We reserve the right to update this Privacy Policy at any time, and we will provide you with a new Privacy Policy when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this Privacy Policy, please contact the DPO at privacy@artoreal.com.