Last Modified: 1 July 2018
Jemella Limited and its subsidiaries now form part of the Coty Inc. group of companies.
Your privacy is important to Coty Inc. and its affiliates and subsidiaries ("Coty", "us", "our") and we are committed to protecting your personal information. This Privacy Notice ("Notice") relates to our use of your personal information when you:
o Interact with us through social media or adverts and content on third party websites (collectively “Coty Content");
o Use our:
- Websites, microsites, or mobile applications;
- Services delivered by via voice activated devices and/or new technologies, such as virtual reality and augmented reality;
displaying this Notice (collectively, "Coty Sites");
o Otherwise engage with us, for example by contacting Customer Services or consumer affairs, attending an education event, tradeshow or other Coty event.
The relevant Coty entity that is responsible for your personal information will be the Coty entity that you provided your personal information to; however as we may share your personal information within our group, other Coty entities may also use your information in accordance with this Notice.
For further information about the Coty entities who act as a controllers of your personal information, please click here: ("Controller List"). Our associated brands can be found here (the “Coty Brands"). Activities of any company (including some Coty Brands) not listed in the Controller List will not be governed by this Notice. For those Coty Brands, you should refer to that third party's privacy notice for more information about how it uses your personal information.
If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided in section "How do I contact Coty?" of this Notice.
We encourage you to take the time to review this Notice in full to make sure you are fully informed. However, if you only want to access a particular section of this Notice, then you can click on the relevant link below to jump to that section:
1. Who is Coty?
Coty is a world leading beauty company, making cosmetic, skincare, fragrances, hair color and styling brands. Our three divisions – Luxury, Professional Beauty and Consumer Beauty – are home to iconic global brands and much loved regional brands. Luxury is focused on prestige fragrances and skincare; Professional Beauty is focused on servicing salon owners and professionals in both hair and nail; and Consumer Beauty is focused on mass color cosmetics, mass retail hair coloring and styling products, body care and mass fragrances.
Our purpose at Coty is to Celebrate and Liberate the Diversity of Your Beauty. We believe the beauty of humanity lies in the individuality of its people; that beauty is at is best when authentic; and beauty should make you feel happy, never sad. As a challenger in beauty, Coty is focused on bringing you new digital solutions to celebrate and liberate the diversity of your beauty in fun, convenient and informative ways, such as voice-activated technology and mixed reality.
2. What information does Coty collect about me?
The personal information that we may collect about you broadly falls into the following categories:
o Information that you provide directly
When you engage with Coty, either online or in person, we may ask you to provide us with personal information about you. For example, we may ask you to provide us with your contact details to register an account with us, to sign up to receive our newsletters or information about our products or events; and/or to submit enquiries to us. You may also provide us with your personal information in other ways, such as if you contact us in relation to employment opportunities; purchase products or request free samples from us; communicate with us through social media or our customer services teams; join a loyalty scheme or reward program, participate in our promotions, or interact with us at tradeshows or our other events. The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point when we ask you to provide it; however we may collect:
- Identification information, for example your first name, last name, email address, postal address, date of birth, phone number, gender, country of residence, lifestyle/interests, appearance, style, login name, password, answers to security questions;
- Transaction information, for example details regarding your transactions with us, including information about the purchases you made and the date and time that you made the purchase;
- Images and photographs, for example if you submit a picture to a competition, the Coty Sites or to social media and tag Coty or a Coty Brand, or when you engage with Coty via technologies such as AR, face evaluation or other tools;
- Health Information, with your explicit consent, for example information related to product usage and medical history (such as heart rate, skin condition and other features) which may be provided as part of voluntary consumer research, product development and trials; and/or
- Your opinions or other information, for example if you review the products you have purchased from us, provide information about products and/or cosmetic concerns, and the brands and products you use or if you provide us with your CV when exploring your employment prospects with us.
o Information that we collect automatically
When you visit the Coty Sites, engage with Coty Content or with us digitally, we may collect certain information automatically from your computer, tablet or mobile phone (a “Device"). In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.
Specifically, the information we collect from you automatically may include information like your IP address, Device type (i.e. make and model), unique device identification numbers, browser-type, time zone settings, broad geographic location (e.g. country or city-level location) and other technical information. With your consent, some of the Coty Sites may also collect your precise location information from your Device to provide location based services. You may change your preferences at any time by adjusting the settings on your Device.
We may also collect information about how your Device has interacted with us, including the pages accessed and links clicked, how you navigate to and from the Coty Sites and Coty Content (such as how you scroll over the Coty Sites and Coty Content, which parts you click and how long you spend on each page), your preferences, the products and/or services that you have viewed or searched for, crashes and download errors and response times.
o Information that we obtain from third party sources
From time to time, we may receive information about you from third party sources, but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclosure your personal information to us.
The types of information we collect from third parties includes:
- Our retailers, distributors and third party brand partners, for example our retailers, distributors and third party brand partners may pass information to us including your first name, last name, email address, postal address, phone number, gender, browsing patterns, geo-location and device identifiers, click through and other cookie data, demographic information including information about your appearance (including hair color, hair characteristics; and hair-care routine) and information in relation to products purchased at their stores (whether on the high-street or online through their own website or a dedicated microsite) and services requested using their websites and/or applications.
- Our technology partners and market research organizations, for example where permitted by applicable data protection law our preferred technology partners may share information with us, including your browsing patterns, geo-location and device identifiers.
3. How does Coty use my information?
We will use your personal information for the purposes set out in this Notice, which will include:
o To provide you with the products and services that you have requested, to administer our relationship with you and to carry out our obligations arising from the relationship between you and us, including internal accounting and administration purposes, to process payment for purchases or other services and to create and manage your account.
o To verify your identity, for example we may use your date of birth to determine that you are old enough to use our services, or your email address to determine if you already have an account with the relevant Coty Site.
o To provide a personalized service, for example we use your information to provide you with personalized recommendations for our products that we think you might like, tailor Coty Content to better suit your interests or, at your request and where available, to offer personalized and customized products . We will also use your personal information across the Coty Sites to provide a seamless user experience.
o For analytics purposes, for example we may analyze your information including your location, products and/or services requested, age, time zone, IP address and URL visited, against our wider customer base for internal business purposes, such as generating statistics and developing marketing plans, to improve our services and products, the Coty Sites and Coty Content. We may also aggregate and de-identify your information to create customer segments and share with our licensees and partners.
o To provide you with marketing communications that you might be interested in, for example, if you choose to receive marketing communications from us, we may use your information to keep you up to date with our latest products, services, surveys, announcements, upcoming events, sweepstakes, contests and other promotions and competitions via our newsletters, emails, or other communications. If you no longer wish to receive these marketing communications, details of how to opt out are described in the section “How do I stop receiving marketing communications?"
o To provide the best service to our customers and consumers, for example, we may use your personal information to process and respond to your questions and/or inquiries
o For site optimization and management, for example we may use your personal information provided to us to:
- administer the Coty Sites, Coty Content and our other digital offerings, including the services and products offered through those Coty Sites;
- ensure the security of our networks and of your information;
- customize your future visits to the Coty Sites and our other digital offerings based on your interests to ensure the most user-friendly online navigation experience;
- improve the Coty Sites and our other digital offerings (including to fix operational problems such as pages crashing and software bugs); and
- provide services to our partners such as tools, analyses, data and insights to see how their website or mobile applications are used.
o For product development and business development purposes, for example we will use information we collect from you to improve our products and develop new products.
o For fraud prevention and detection purposes and to protect and defend the rights and property of Coty, our employees and our business partners.
o For employment application purposes, for example, if you contact us in relation to your employment prospects we will use your personal information to consider you for current and future employment opportunities and to contact you with respect to employment opportunities at Coty that you have expressed interest in.
4. On what basis can Coty use my information in this way?
We are required to satisfy one or more of the reasons set out by applicable data privacy law before we can collect and use your personal information.
Generally, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally rely on the following reasons to collect and use your personal information:
What are the legal grounds?
What are they?
Performance of a contract
Using your information may be necessary for us to perform our obligations under a contract with you or with a view to entering into such a contract. For example, where you have: (i) requested services and/or products from us, we will need to use your information to provide those services and/or products that you have requested; or (ii) approached us in relation to employment opportunities, the collection and use of your personal information is necessary to enable us to offer you the job role, process your acceptance of the offer, on-board you as an employee and fulfil our obligations as an employer.
Compliance with our legal obligations
The collection and use of your personal information may be necessary to enable us to meet our legal obligations. For example, if you are a business customer we need to process your information to verify your identity and undertake necessary due diligence checks.
Pursuing our legitimate interests
Where such processing is not overridden by your rights, we are permitted to use your personal information to pursue our legitimate interests, for example to operate the Coty Sites and our other digital offerings, to improve our products, the Coty Sites and our other digital offerings, to undertake marketing, or otherwise to help us achieve our purpose toCelebrate and Liberate the Diversity of Your Beauty. We may have other legitimate interests and if appropriate we will make this clear to you at the relevant time.
In some limited circumstances, we may rely on your consent to collect and use your personal information. For example, we may rely on consent: (i) where you have approached us in relation to employment opportunities and have provided us with sensitive personal information, such as information in relation to your racial and ethnic origin, sexual orientation, religion, physical and mental health, disabilities or trade union membership; or (ii) in relation to the sending of e-marketing or communication from different brands within the Coty group.
If we rely on consent, this will be made clear to you at the time we request your information. You can withdraw your consent at any point by using the mechanism provided at the time, or by contacting us using the contact details provided in the section “How do I contact Coty?” of this Notice.
In some instances, we may need to use your personal information to protect your vital interests or those of another person.
You may not always be required to provide the personal information that we have requested. However, if you choose not to provide certain information, you may not be able to take advantage of some of our services. Any information that is so required is clearly marked as mandatory. If you would prefer that we not collect certain personal information from you, please do not provide us with any such information, or opt out of providing this information where applicable.
If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), these interests will normally be as set out in this Notice; however if this changes we will make clear to you at the relevant time what those legitimate interests are.
If you have any questions or need further information concerning the legal basis on which we collect and use your personal information, please contact our Data Protection Team. Details for how to contact our Data Protection Team can be found in the section “How do I contact Coty?"
7. What are my data protection rights?
Subject to applicable data protection law, you may also have the following rights:
o The right to request access to personal information, which enables you to receive confirmation as to whether or not we are processing your personal information and access to such personal information
o The right to change and/or correct inaccurate personal information or to request that we delete your personal information in certain circumstances
o The right to block or suppress the processing your personal information
o The right to object to our processing of your personal information (including any processing for direct marketing purposes). More information on how to stop receiving direct marketing can be found in the section marked, “How do I stop receiving marketing communications?"
o The right to request portability of your personal information
o The right to withdraw your consent, if applicable. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent
o Under California law, if you are a resident of California, you may request and obtain from us once a year, free of charge, information regarding our disclosure (if any) of your personal information to third parties for marketing purposes in the preceding calendar year.
You can exercise these rights by contacting us using the information provided in the section “How do I contact Coty?" of this Notice. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws and we may require reasonable documentation to verify your identity prior to granting your request.
If you have any questions or concerns about how we use your personal information, please do not hesitate to let us know. You also have the right to lodge any complaints with a relevant supervisory authority.
8. How do I stop receiving marketing communications?
We will only send you marketing communications if you have agreed to this, or if we are otherwise permitted by law. If at any time you decide that you no longer wish to receive marketing communications from us, you may opt out by clicking on the relevant ‘unsubscribe’ link in the email you receive, by sending us an email, or by contacting us using the contact details in section "How do I contact Coty?" of this Notice. Please Note, whilst we will honor your request to stop receiving marketing communications, we will continue to send you service-related communications such as emails confirming purchases through the Coty Sites and keep your information for record keeping purposes.
9. For how long does Coty keep my information?
We will retain your information where we have an ongoing legitimate business need to do so (for example, to provide you with access to the Coty Sites or other digital offerings, to provide you with a product you have purchased, or to comply with applicable legal, tax, or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
10. Does Coty transfer my information to other countries?
As an international entity, in order to provide our services we may need to transfer and process your personal information internationally (including to destinations outside the European Economic Area (the “EEA") and the UK), notably throughout the Coty Group and to the jurisdictions in which those entities are based listed on our website. This means that when we process your personal information we may process it in any of these countries.
As a result, your information may be transferred to and/or processed in countries which may not guarantee the same level of protection for personal information as the country in which you reside. However, we have taken appropriate safeguards to ensure that your personal information will remain protected in accordance with this Notice. This includes implementing the European Commission's Standard Contractual Clauses for transfers of your personal information between our group companies, which require all group companies to protect personal information that they process from the EEA in accordance with European Union data protection law.
Further information can be provided on request: please contact us using the details found in the section “How do I contact Coty?" We have also implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.
11. Is my information secure?
We understand that you care how your personal information is used and/or shared with others, and we value your trust and seek to safeguard your personal information.
We implement appropriate technical and organizational security measures, including physical, administrative and technical safeguards to protect your personal information from unauthorized access, use and disclosure. To ensure the security of your personal information, we communicate our privacy and security guidelines to all Coty employees and enforce privacy safeguards within our company.
The measures we use to protect your personal information are designed to provide a level of security appropriate to the risk of processing your personal information. However, please be aware that no electronic transmission of information can be entirely secure. We cannot guarantee that the security measures that we have in place to safeguard personal information will never be defeated or fail, or that those measures will always be sufficient or effective.
12. What if I access a website through a Coty Site?
As described above, the Coty Sites may contain links to and from other third-party websites and services (collectively, “Third Party Sites") that are not controlled and operated by us.
14. I have entered a contest, promotion or survey – how do I find out more about that?
Coty and its preferred third party service providers or business partners may offer sweepstakes, contests, promotions and surveys (each, a “Promotion") through a Coty Site.
To learn more about the terms and conditions that apply to Promotions being run by Coty, please refer to our Promotion Terms and Conditions .
15. How old do I have to be to use the Coty Sites or other Coty digital offerings?
You must be aged 13 or over to use the Coty Sites and our other digital offerings.
We take your privacy very seriously and we understand the importance of taking extra precautions to protect the privacy and safety of children who use Coty’s products and services. We do not solicit or knowingly collect personal information from children aged 13 and under. If we are made aware that we have received such information, or any information in violation of our policy, we will use reasonable efforts to locate and remove that information from our records.
16. I am a Salon Owner – is there anything else I need to know?
Specific provisions apply to Salon Owners that use our Coty Sites and our other digital offerings– these are described below.
Each time you submit information relating to a ‘new client’, ‘member of staff’ or other personal data, please make sure that the relevant individual: (i) is over the age of 13; (ii) is aware that you will be sharing their details with us and our processing in accordance with this Notice; and (iii) has, if applicable, consented to receiving marketing communications from us and our affiliates.
You may only share these details with us when using a Coty Site and/or our other digital offerings where you have made those individuals aware of our Notice and how we will use their personal information. If we become aware that you have submitted personal information to a Coty Site and;/or any of our other digital offerings without permission, we will delete the information from our records
17. Does this Notice ever change?
We may update or modify this Notice from time to time in response to changing legal, technical or business developments. We will obtain your consent to any material Notice changes if and where this is required by applicable data protection laws. The date of the most recent version of this Notice will appear at the top of the page.
When we update our Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. For example, we will notify you of any changes to this Notice by posting a new Notice and updating the “last modified" date at the top of this page or by sending the new Notice to you via email, where appropriate.
18. How do I contact Coty?
If you have any questions regarding our practices or how we handle your information, please contact our Data Protection Team by sending an email to firstname.lastname@example.org or by post to the Data Protection Team, Commercial Legal Department, Coty Inc., 20 Eastbourne Terrace, London, W2 6LE, United Kingdom.
Contact details for each of the Coty entities can be found here:
Thank you for taking the time to read this Notice.
© Coty 2018