FOR INDIVIDUAL, BUSINESS CUSTOMERS, VENDORS, BUSINESS PARTNERS
OUR PRIVACY PROMISE
- We respect your privacy and your choices.
- We make sure that privacy and security are embedded in everything we do.
- We do not send you marketing communications unless you have asked us to. You can change your mind at any time.
- We never offer or sell your data.
- We are committed to keeping your data safe and secure. This includes only working with trusted partners.
- We are committed to being open and transparent about how we use your data.
- We do not use your data in ways that we have not told you about.
- We respect your rights, and always try to accommodate your requests as far as is possible, in line with our own legal and operational responsibilities.
For more information about our privacy practices, below we set out what types of personal data we might collect or hold about you, how we use it, who we share it with, how we protect it and keep it secure, and your rights around your personal data.
Note that all of the information set out below may not apply to you. We have explained below an overview of all possible situations in which we could interact together, and one or more of these may apply to you depending on how you have interacted with us. For example, if you have not provided us with a photo for your account, then these details will not apply to you.
- Who are we?
- What is personal data?
- What data do we collect from you and how do use it?
- How do we collect or receive your data?
- Automated Decision Making
- Who may access your personal data?
- Where we store your personal data?
- How long do we keep your personal data?
- Is my Personal data secure?
- Links to third party sites and social login
- Social media and user generated content
- Your rights and choices
WHO WE ARE
L’Oréal operates in 140 countries around the world and represents several different brands and products. For details on the L’Oréal Group, please see http://www.loreal.com/group.
L’Oréal Thailand is responsible for the personal data that you share with us. When we say “L’Oréal”, “us”, “our” or “we”, this is who we are referring to. L’Oréal is the “data controller” for the purposes of applicable data protection laws.
L’OREAL THAILAND LIMITED
No. 179 Bangkok City Tower, 6th, 8th, 9th and 21st Floor, South Sathorn Road,
Tungmahamek, Sathorn Bangkok 10120 Thailand
WHAT IS PERSONAL DATA?
“Personal data” means any information or pieces of information that could identify you either directly (e.g. your name) or indirectly (e.g. through pseudonymized data such as a unique ID number). This means that personal data includes things like email/home addresses/mobile phone, date of birth, usernames, profile pictures, personal preferences and shopping habits, user generated content, financial information, and welfare information. It could also include unique numerical identifiers like your computer’s IP address or your mobile device’s MAC address, as well as cookies.
WHAT PERSONAL DATA DO WE COLLECT FROM YOU?
The categories of your “Personal Data” that we collect, use or disclose (collectively “process” or “processing”), subject to the applicable law, including but not limited to:
- Personal details: Name and last name, gender, date of birth, marital status, personal identification number, passport number, other identification number issued by the government including Personal Data that is present on the document issued by the government, corporate documents issued by authorities (in case vendor/business partner is juristic person), tax identification number, nationality, photograph appeared on identification card, passport or driving license, signatures, information the Company received from the questions where you can identify your identity (e.g., password, answer in resetting the password, PINs, biometric data for a facial and voice recognition, photograph, CCTV image/footage;
- Financial details: The details of your bank account, billing address, credit card numbers and cardholder’s name and details;
- Contact details: Address, telephone number, email address and social media profile details;
- Electronic data: IP addresses, cookies, activity logs, online identifiers, unique device identifiers and geolocation data
- Sensitive personal data:
- Religious; and
- Criminal record.
During a processing of your Personal Data, we may also collect some sensitive Personal Data about you to enable you to be the customer, vendor or partner. However, we will not collect, use and/or disclose this type of data without your consent unless the law allows us to do so.
HOW DO WE COLLECT OR RECEIVE YOUR PERSONAL DATA?
For individual & business customers:
We might collect or receive personal data from you via our websites, forms, apps, devices, L’Oréal products or brand pages on social media, through your direct interactions with your account managers or customer care teams, or otherwise. Sometimes you give this to us directly (e.g. when you create an account, when you contact us, when you purchase from our websites/apps or in our stores), sometimes we collect it (e.g. using cookies to understand how you use our websites) or sometimes we receive your personal data from other third parties, including other L’Oréal Group entities.
When we collect personal data, we will indicate which types of personal data are mandatory via asterisks. Some of the personal data we request from you are either necessary for us to:
- Perform our contract with you (e.g. to create your account, or deliver the goods you have purchased on our websites/apps);
- Provide you with a service you have asked for ;
- Comply with legal requirements (e.g. invoicing).
If you do not provide the personal data marked with an asterisk, this may affect the goods and services that we can provide.
For vendors & business partners:
We collect and use many kinds of the Personal Data, depending on circumstances relating to a procurement of products and/or services.
We collect the Personal Data about you from a variety of sources, including but not limited to: -
- From you directly as part of the process of becoming our vendor/business partner;
- From third parties as part of the process of becoming vendor/business partner e.g., credit checks, trade references, our customers, your customers, law enforcement authorities, etc.;
- When you talk to us, including recorded calls, posts, e-mails, notes and other means;
- When you use our websites, applications or other online channel;
- Insurance claims or other documents;
- When you manifestly publish your Personal Data, including via social media, we may collect your Personal Data from your social media profile(s) to the extent that you choose to make your profile publicly visible;
HOW DO WE USE IT?
In the table below, we explain:
- During which interactions you may provide and we may collect your data: This column explains what activity or scenario you are involved in when we use or collect your personal data. For example, whether you are making a purchase, signing up to a newsletter, or browsing a website.
- What personal data we may receive from you directly or resulting from your interactions with us: This column explains what types of personal data we may collect when you take part in a particular activity.
- How and why we use your personal data: This column explains what we do with your personal data, and the purposes for collecting and using it.
- What is our legal basis for using your personal data: Whenever we use your personal data, we will have a legal basis to do this. For example, you have asked us to provide a service, you have given us your consent, or we have a legitimate interest in using your personal data.
The legal basis for the processing of your personal data can be:
- Your consent.
- The performance of a contract – This applies where you provide us with your personal data in order for us to provide you with a service (e.g. you ask us to create a customer account for you or you wish to purchase a product and we can manage the associated logistics).
- Our legitimate interest, which can be:
- Improvement of our products and services: more specifically, our business interests to help us better understand your needs and expectations and therefore improve our services, websites/apps, devices, products and brands for our customers’ benefit.
- Fraud prevention: to ensure payment is complete and free from fraud and misappropriation.
- Securing our tools: to keep tools used by you (our websites/apps, devices) safe and secure and to ensure they are working properly and are continually improving.
- Legal grounds – This is where we need to keep your personal data for legal reasons (e.g. when you make a purchase we need to keep your transaction information to comply with our tax and financial reporting obligations).
Information Overview On Your Interactions With Us And Their Consequences On Your Personal Data
Automated Decision Making
For purposes of securing transactions placed through our websites/apps/devices against fraud and misappropriation, we use third party provider’s solution(s). The method of fraud detection is based on, for example, simple comparisons, association, clustering, prediction and outlier detections using intelligent agents, data fusion techniques and various data mining techniques.
This fraud detection process may be completely automated or may involve human intervention where a person takes the final decision. In any case, we take all reasonable precautions and safeguards to limit access to your data.
As a result of automatic fraud detection, you may (i) experience delay in the processing of your order/request whilst your transaction is being reviewed by us; and (ii) be limited or excluded from the benefit of a service if a risk of fraud is identified. You have the right to access information on which we base our decision. Please see “Your Rights and Choices” section below.
When we send or display personalised communications or content, we may use some techniques qualified as “profiling” (i.e. any form of automated processing of personal data consisting of using those data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s personal preferences, interests, economic situation, behaviour, location, health, reliability, or movements). This means that we may collect personal data about you in the different scenarios mentioned in the table above. We centralize this data and analyse it to evaluate and predict your personal preferences and/or interests.
Based on our analysis, we send or display communications and/or content tailored to your interests/needs.
You have the right to object to the use of your data for “profiling” in certain circumstances. Please see “Your Rights and Choices” section below.
For vendors & business partners;
When we rely on the legitimate interests as the lawful basis for processing the Personal Data, we have considered whether or not your rights are overridden by our interests and have concluded that they are not.
In case you refuse to give the Company your Personal Data
Under the circumstance that it is necessary for the Company to collect your Personal Data in accordance with the law or under the contract terms between you and the Company and you decline to such collection, the Company may not be able to meet the obligations that have been agreed with you, or to enter into a contract with you. In this given circumstance, the Company may refuse to procure the products and/or services from you. In any case, the Company will notify you while the Company is collecting your Personal Data.
Who may access your Personal data?
For individual & business customers:
We may share your personal data within L’Oréal Group to comply with our legal obligations, to prevent fraud and/or to secure our tools, to improve our products and services or after having obtained your consent to do so.
Depending on the purposes for which they were collected, and only on a need-to-know basis some of your personal data may be accessed by L’Oréal Group entities worldwide, where possible in a pseudonimized way (not allowing direct identification), and where necessary to provide you with requested services.
We may also share your personal data in a pseudonimized way (not allowing direct identification) with L’Oréal Research & Innovation scientists, including those located outside of your country, for research and innovation purposes.
Where permitted, we may also share some of your personal data including those collected through Cookies between our brands to harmonize and update the information you share with us, to perform statistics based on your characteristics and to tailor our communications.
We may share your personal data for marketing purposes with third party or entities of the L’Oréal Group.
We only share your personal data with third parties for direct marketing purposes with your consent. In this context, your data is processed by such third party, acting as a data controller, and its own terms and conditions and privacy notice apply. You should carefully check their documentation before consenting to the disclosure of your information to that third party.
Your personal data may also be processed on our behalf by our trusted third-party providers.
We rely on trusted third parties to perform a range of business operations on our behalf. We only provide them with the information they need to perform the service, and we require that they do not use your personal data for any other purpose. We always use our best efforts to ensure that all third parties we work with keep your personal data secure. For instance, we may entrust services that require the processing of your personal data to:
- Third parties that assist and help us in providing digital and e-commerce services such as social listening, store locator, loyalty programs, identity management, reviewing social media and public profiles, ratings and reviews, CRM, web analytics and search engine, user generated content curation tools;
- Advertising, marketing, digital and social media agencies to help us to deliver advertising, marketing, and campaigns, to analyse their effectiveness, and to manage your contact and questions and our relationships;
- Third parties required to deliver a product to you e.g. postal/delivery services;
- Third parties that assist and help us in providing IT services, such as platform providers, hosting services, maintenance and support on our databases as well as on our software and applications that may contain data about you (such services could sometimes imply access to your data to perform the required tasks);
- Payment service providers and credit reference agencies for the purpose of assessing your credit score and verifying your details where this is a condition of entering into a contract with you;
- Third parties that assist us for customer care and cosmetovigilance purposes;
- Third parties that assist us in providing training, seminars, and events, such as training providers travel agencies, and event management companies; and/or
- Third parties that provide us with consulting services in the field of market research and analytics, collect feedback and conduct market surveys on our products, services and otherwise for customer relationship management purposes.
The legal basis for this sharing is our legitimate interests – (i) to improve our products and services; (ii) better engage with you; (iii) prevent fraud; (iv) secure our tools and design new features; (v) use appropriate suppliers; and (vi) ensuring your values align with that of L’Oréal’s.
We may also disclose your personal data to third parties:
- If we have your consent to do so.
- Or if we are permitted to do so by law
We may disclose your personal data to our partners:
- In the event the service you subscribe to was co-created by L’Oréal and a partner (for example, a co- branded app). In such case, L’Oréal and the partner process your personal data each for their own purposes and as such your data is processed:
- When we use Google advertising services on our websites/apps, Google will access and use your personal data. If you wish to learn more on how Google uses your personal data in this context, please consult their Google Privacy & Terms, which govern these services and data processing.
Information that Facebook collects and share with us
All Facebook features and services available on our website/app are governed by the Facebook Data Policy, in which you can get more info about your privacy rights and settings options. By using this website/app, you may:
- Sign-up with your Facebook login. If you do so, you consent to share some of your public profile information with us;
- Use the Facebook social plug-ins, such as “like” or “share” our content on the Facebook platform;
- Accept cookies from this website/app (also identified as “Facebook Pixel”) that will help us understand your activities, including information about your device, how you use our services, the purchase you make and the ads you see, whether or not you have a Facebook account or are logged into Facebook. When you are using those Facebook features, we collect data that help us to:
- Show you adds you might be interested in on Facebook (or Instagram, Messenger or any other Facebook services);
- Measure and analyze the effectiveness of our website/app and ads
We may also use the personal data you gave us on this website/app (such as your name and surname, email, address, gender and phone number) to identify you in Facebook (or Instagram, Messenger or any other Facebook services) in order to show you ads that are even more relevant for you. While doing this, Facebook will not share your personal data and will delete the data promptly after the match process is complete.
We do not offer or sell your personal data.
For vendors & business partners:
We may share your Personal Data with others where it is lawful to do so, including where: -
- it is necessary to comply with provisions of contract;
- we/they have a public or legal duty to do so (e.g., assist in a detection and prevention of fraud, tax evasion and financial crime, etc.);
- we/they need to in connection with a regulatory reporting, litigation, asserting or defending legal rights and interests;
- we/they have legitimate business reasons to do so (e.g., manage risk, internal report, assess data analysis, verify identity, etc.);
- we/they request for your permission to share it, and you agree.
We may also need to share your Personal Data for these purposes with others, including but not limited to: -
- other group companies and any sub-contractors, agents or service providers who work for us or provide the services to us or other group companies, including their employees, sub-contractors, service providers, directors and officers;
- any appointed persons to take care your benefits;
- people you make the payment to and receive the payment from;
- your intermediaries, correspondent and agent;
- financial institutions, and payment service providers;
- any people or companies where required in connection with a potential or actual corporate restructuring, merger, acquisition or takeover, including any transfer or potential transfer of any of our rights or duties under our agreement with you;
- law enforcement, government, courts, dispute resolution bodies, our regulators, auditors and any parties appointed or requested by our regulators to carry out investigations or audits of our activities;
- other parties involved in any disputes, including disputed transactions;
- fraud prevention agencies who will also use it to detect and prevent fraud and other financial crime and to verify your identity;
- anyone who provides instructions or operates any of your accounts, products or services on your behalf, e.g., Power of Attorney, lawyers, etc.; and/or
- anybody else that we have been instructed to share your Personal Data with by you
Except as described in this Privacy Notice, we will not process your Personal Data for any purposes other than the purposes as described to you in this Privacy Notice. Should we intend to process additional Personal Data which are not described in this Privacy Notice, we will notify you and obtain your consent prior to the processing, except in case where the law allows us to do so without your consent. You will also have an opportunity to consent or decline to such processing of your Personal Data.
We do not offer or sell your personal data.
Where We Store Your Personal data
The data that we collect from you may be transferred to, accessed from, and stored at a destination outside Thailand. It may also be processed by staff members operating outside Thailand who work for us or for one of our service providers.
L’Oréal transfers personal data outside Thailand only in a secure and lawful way. As some countries may not have laws governing the use and transfer of personal data, we take steps to make sure that third parties adhere to the commitments set out in this Policy. These steps may include reviewing third parties’ privacy and security standards and/or entering into appropriate contracts as L’Oreal deems compliant to the standard of the Personal Data Protection Act of Thailand B.E. 2562 (2019) and its sub-regulations thereof.
For further information, please contact us as per the “Contact” section below.
How Long Do We Keep Your Personal data
For individual & business customers:
We only keep your personal data for as long as we need it for the purpose for which we hold your personal data, to meet your needs, or to comply with our legal obligations.
To determine the data retention period of your data, we use the following criteria:
- Where you purchase products and services, we keep your personal data for the duration of our contractual relationship;
- Where you participate in a promotional offer, we keep your personal data for the duration of the promotional offer;
- Where you contact us for an enquiry, we keep your personal data for the duration needed for the processing of your enquiry;
- Where you create an account, we keep your personal data until you require us to delete it or after a period of inactivity (no active interaction with brands) defined in accordance with Vietnamese regulations;
- Where you have consented to direct marketing, we keep your personal data until you unsubscribe or require us to delete it or after a period of inactivity (no active interaction with brands) defined in accordance with Vietnamese regulations;
- Where cookies are placed on your computer, we keep them for as long as necessary to achieve their purposes (e.g. for the duration of a session for shopping cart cookies or session ID cookies) and for a period defined in accordance with Vietnamese regulations.
We may retain some personal data to comply with our legal or regulatory obligations, as well as to allow us to manage our rights (for example to assert our claims in Courts) or for statistical or historical purposes.
When we no longer need to use your personal data, it is removed from our systems and records or anonymised so that you can no longer be identified from it.
For vendors & business partners:
We retain your Personal Data for as long as it is necessary to carry out the purposes for which it was collected that is for business reasons or compliance with the applicable laws.
We keep your Personal data for the duration of our contractual relationship and for 10 years after you stop being our vendor. This is for the benefit of the Company in the execution of any contractual dispute that may occur during the specified period. Unless otherwise required in the event of regulatory or technical reasons, we may keep your Personal Data for longer than 10 years. If we do not need to retain the Personal Data for longer than it is legally required or necessary, we will destroy, delete or anonymize it.
Is Your Personal data Secure?
We are committed to keeping your personal data secure, and taking all reasonable precautions to do so. We contractually require that trusted third parties who handle your personal data for us do the same.
We always do our best to protect your personal data and once we have received your personal data, we use strict procedures and security features to try to prevent unauthorised access. As the transmission of information via the internet is not completely secure, we cannot guarantee the security of your data transmitted to our site. As such, any transmission is at your own risk.
Links to Third Party Sites and Social Login
Our websites and Apps may from time to time contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we are not responsible or liable for these policies. Please check these policies before you submit any personal data to these websites.
Social Media and User Generated Content
Some of our websites and Apps allow users to submit their own content. Please remember that any content submitted to one of our social media platforms can be viewed by the public, so you should be cautious about providing certain personal data e.g. financial information or address details. We are not responsible for any actions taken by other individuals if you post personal data on one of our social media platforms and we recommend that you do not share such information.
YOUR RIGHTS AND CHOICES
L’Oréal respects your right to privacy: it is important that you are able to control your personal data. You have the following rights:
To deal with your request, we may require proof of your identity.
If you have any questions or concerns about how we treat and use your personal data, or would like to exercise any of your rights above, please contact us at [email protected] or by writing to us at No. 179 Bangkok City Tower, 6th, 8th, 9th and 21st Floor, South Sathorn Road, Tungmahamek, Sathorn Bangkok 10120 Thailand