I. WHAT IS A PERSONAL DATA?

Personal data is any information about an identified physical person or a physical person that may be directly or indirectly identified via an identification number or one or more elements particular to them, such as their last name, first name, date of birth, customer number, order number, photo, etc.

II. WHEN CAN WE COLLECT YOUR PERSONAL DATA?

III. WHAT PERSONAL DATA MAY WE COLLECT?

1. As part of the services we provide, we may need to collect certain data directly from you using electronic forms on our website, mobile apps or in selected stores, or in paper form, for a range of purposes (see IV for a list of processing purposes).

Information we might collect includes:

• your identity;
• your contact details (e.g. email adress);
• your personal preferences in relation to the products we sell or to our website (language);
• information relating to your orders, their tracking and your purchase invoices;
• information you may share when you interact with our chat;
• information you may provide to our customer service;
• specific health data if you notify us of any undesirable side-effects concerning any of our products;
• your bank details if you place an order via our website;
• Your photos/images seen by MAKE UP FOR EVER while using your experiments via the Virtual Try-On tool : Morpho Beauty, Shade Finder, Try On. (No photos or images are kept in relation to the Virtual Try-On tool when you conclude the session). In addition, when you are using Morpho beauty, your email address and beauty routine, according to your choice, may be collected for the time of sending you your experience;
• your publications/mentions relating to our products on social networks.

 

• In case of subscription to our Pro Program:
  • • An identity document;
    • One of the following documents:
      • KBIS extract less than 3 months old;
      • INSEE registration notice less than 3 months old;
      • employment contract;
      • payslip; intermittence stamp;
      • professional licence.

 

• Especially for MAKE UP FOR EVER Academy:
  • • your social security number;
    • your employment status (status, contact, etc.) if applicable;
    • your residence permit, if applicable;
    • your bank details;
    • your photograph, particularly for the purpose of printing your badge;
    • your personnel number;
    • your CV, including your diplomas and previous experience;
    • your absence requests, dates of leave and sick leave;
    • your connection logs on the various computer and electronic tools at your disposal;
    • any other information you may provide.

Personal data essential to MAKE UP FOR EVER is marked with an asterisk on all personal data collection forms on our website, in electronic form at some of our counters and stores, as well as off-line in paper form. If you do not fill in these compulsory fields, MAKE UP FOR EVER will probably be unable to respond to your request and/or provide you with the requested services. Other information is optional and enables us to get to know you better and improve our communications and services with respect to you.

2. We may also collect certain data generated by your purchases of products or services, online or in stores, particularly information regarding the amount and type of your purchases.

3. Lastly, we may collect information regarding the use of our website, especially with respect to your browsing (pages visited, links clicked, etc). Some of this information may be collected using cookies placed in your web browser when you browse our website. For more information about cookies, consult our Cookie Policy here.

 

IV. FOR WHAT PURPOSES ARE YOUR PERSONAL DATA COLLECTED AND USED?

MAKE UP FOR EVER processes your data to:

• enable you to create a customer account on our website, our applications but also in our counters and shops;
• manage your access to your customer account on the Internet or on our applications;
• process and manage your online orders and their delivery;
• record purchases made at our corners or in our stores;
• secure online transactions, prevent fraud, payment incidents and manage debt collection (see our General Terms and Conditions for more details);
• hen you interact with our chat, to answer your request;
• manage customer relations with respect to any requests for information or complaints you may send us via our website, customer service or social network pages;
• manage our Pro Program;
• trace and manage any alerts you may send us as part of our cosmetic vigilance obligations;
• manage and optimise your customer experience by improving our knowledge of our customers;
• propose appropriate, tailored services, particularly when we enhance our products and services;
• conduct statistical analyses to develop management, measuring and reporting tools in order to adjust and improve our sales, marketing and product manufacturing;
• analyse your preferences and habits, anticipate your needs based on your customer profile and your posts/remarks about our products on social networks;
• analyse our Maison’s performance on social networks in order to produce statistical analyses (studies of results by market, Maison influence and analysis of campaigns implemented);
• promote our Maison;
• make it easier for you to see what the product you have chosen would look like on you (when using the Virtual Try-On tool : Shade Finder, Try On);
• allow you to benefit from a beauty consultation with cosmetic product recommendations, plus make it easier for you to see what recommended products would look like on you (when using the Virtual Try-On tool : Morpho Beauty);
• the sending of a generic newsletter: you have the right to object if you no longer wish to receive it;

• subject to your free, specific, informed and unambiguous consent:, send you personalised information according to the communication preferences you have indicated to us and your consumer profile (link here to channel preference manager if you have a customer account, otherwise you can contact our customer service (see section "What are your rights and how to exercise them") and to use third- party services to personalise your profile;
• manage your participation in the events for which you register.
• In the context of the MAKE UP FOR EVER Academy training course:
• manage your participation in the training;
• manage your administrative file in execution of the training agreement, including in particular the management of training sessions, payment, sick leave, mutual insurance, etc…:

• la Keep all compulsory documentation relating to trainees (keep compulsory books and registers), carry out employment-related formalities (compulsory social declarations, in particular);

• identify and authentify trainees, manage authorisations and clearances and the traceability of the use of the MAKE UP FOR EVER Information System (equipment made available, systems, collaborative tools, internet access, collaborative applications, etc.), under the conditions of the INFORMATION SYSTEM SECURITY CHARTER ;

• manage organisational charts, directories, internal communication and intranets, as well as conduct surveys and statistical studies, in order to allow MAKE UP FOR EVER Academy to ensure the organisation or training courses, to facilitate internal communication and collaborative work, and to evaluate the expectations of trainees;
• the sending of a generic newsletter: you have the right to object if you no longer wish to receive it;
• subject to your free, specific, informed and unambiguous consent, send you personalised information according to the communication preferences you have indicated to us and your consumer profile by email and to use third party services to personalise your profile.

 

V. WHAT ARE THE LEGAL GROUNDS FOR THE PROCESSING OF YOUR DATA?

MAKE UP FOR EVER processes your personal information:

• to perform the contract agreed between yourself and MAKE UP FOR EVER, to manage your access to your customer account and to process and track your orders; 
• our legitimate interest: for example, to improve our products and services, to defend ourselves, to secure our tools or to refine our customer knowledge via the tools of our third party partners and in particular to :

- to define the personalised profile of our customers based on their interests and to offer them relevant offers from our brand on other websites;

- identify audiences that are similar to our target audience (in order to deliver our offers to audiences of people who have similarities to our customers' profiles).

• when you have given your consent for the processing of your data, especially for the purposes of managing our personalized sales prospection, and of your browsing data via cookies, etc.
• within the framework of compliance with our legal obligations, particularly fiscal obligations (conserving purchase invoices) and cosmetic vigilance with regard to Regulation (EU) 1223/2009 of 30 November 2009 on cosmetic products;
• for the execution of the contract, within the framework of the MAKE UP FOR EVER Academy training course.

 

VI. WHAT ARE THE RECIPIENTS OF YOUR PERSONAL DATA?

Your personal data is processed by the personnel of MAKE UP FOR EVER. We ensure that only authorised persons within MAKE UP FOR EVER have access to your personal data when this is necessary for the purpose of managing our commercial relations or meeting legal obligations.

We may also share your personal data with:

• other subsidiaries of MAKE UP FOR EVER in Europe or abroad, and to our parent company MAKE UP FOR EVER;
• other entities of the LVMH Group, with some of these entities acting as data processors;
• subcontractors, such as:
  • site hosting and maintenance service providers and the providers of our electronic personal data collection solutions at counters and in stores;
  • payment service providers;
  • anti-fraud service providers;
  • logistic service providers;
  • marketing solution service providers;
  • Third parties wishing to know your interests so that they can build similar audiences and target prospects corresponding to your profile. In the context of this specific processing, these partners may re-use the personal data made available to them to carry out autonomous and distinct targeting for commercial prospecting purposes, for which they are responsible, and are responsible for their legal and regulatory obligations.

    Please note that in the context of re-use, these partners act as data controllers.  You should therefore refer to their own privacy policies. We illustrate some examples below :

    • Facebook (Privacy policy accessible here)
    • Google (Privacy policy accessible here)
    • Instagram (Privacy policy accessible here)
  • sales prospection and social network communication service providers;
  • providers of statistical analysis of our performance on social networks;
  • customer service providers;
  • service providers for managing cosmetic vigilance alerts;
  • event organisation service providers.

Lastly , MAKE UP FOR EVERmay need to share your personal data with third parties to meet its legal, regulatory or treaty obligations, or to respond to requests from authorised legal authorities.

VII. HOW DO WE ENSURE THE CONFIDENTIALITY OF YOUR DATA?

We ask our partners and group companies to maintain a similar level of protection as we provide for your personal data.

We apply the necessary precautions to guarantee the confidentiality and security of your data.

We prevent your data from being distorted, damaged, destroyed or accessed by unauthorised third parties.

Your bank details are not transmitted in clear text on the MAKE UP FOR EVER servers. Payments are made via a secure payment platform, combined with control measures to ensure the security of purchases made on www.makeupforever.com and to fight against fraud.

The contact details of your Payment Card communicated at the time of your order never pass in clear on the network: they are encrypted thanks to the SSL (Secure Socket Layer) protocol.

 

VIII. TRANSFERRING DATA ABROAD

Some recipients of your personal data may be located abroad, including outside of the European Economic Area.

All data transfers outside of the European Economic Area are subject to appropriate guarantees, especially contractual, technical and organisational guarantees, that comply with applicable regulations relating to the protection of personal data.

 

IX. HOW LONG DO WE KEEP YOUR DATA?

The legal retention periods defined by MAKE UP FOR EVER respect the recommendations of the National Commission for Data Processing and Liberties (CNIL) and/or the legal obligations to which MAKE UP FOR EVER is subject.

We keep your personal data only as long as necessary to fulfil the purpose, to meet your needs, or to meet our legal obligations.

 

In general, your personal data are kept in our database:

• Customer (i.e.:with a MAKE UP FOR EVER customer profile) :
  Duration: 5 years from the date of the first purchase or account creation
  Specificity: This period will be renewed each time you interact with MAKE UP FOR EVER for example a purchase or an update of your profile) or your consent to continue to interact at the end of this period
• Prospect (i.e. you have never purchased a MAKE UP FOR EVER product but you subscribed to our communications)
  Duration: 3 years from the date of data collection.
  Specificity: This period will be renewed each time you interact with MAKE UP FOR EVER (e.g. participation in an event) or your consent to continue to interact at the end of this period.
• Guest' customer (i.e.: not having a customer account)
  Duration: 5 years from the date of first purchase
  Specificity: This period will be renewed each time you interact with MAKE UP FOR EVER (e.g. a purchase).
• Customer relations department (i.e.: complaints or information)
  Duration: duration of the processing of the request plus 5 years. For requests to exercise rights, the duration of the management of the request plus 6 years
• For cosmetovigilance data, for the duration of the cosmetovigilance case, then 10 years of archiving
• When you interact with our chat, data relating to a complaint will be retained for a period of 5 years by Customer Services, all other data will be deleted at the end of the conversation.
• When you are using Virtual Try-On tool (Morpho Beauty, Shade Finder, Try On): as stated above, when you choose to use our Virtual Try-On tool, no photos or images are retained or stored beyond the end of the session
• If you are in contact with public relations services: for a period not exceeding 10 years from your first contact; this period will be renewed each time you interact with MAKE UP FOR EVER (e.g. a request for information about MAKE UP FOR EVER)
• If you are a "candidate" (i.e. you apply for a position offered by MAKE UP FOR EVER or for the training provided by MAKE UP FOR EVER Academy): 2 years from your application

When we no longer need to use your personal data, they are deleted from our systems and records or made anonymous so that you can no longer be identified.

In the context of the MAKE UP FOR EVER Academy training:

Generally speaking, except in the specific case specified below, your personal data will be kept and processed by MAKE UP FOR EVER Academy for the duration of the training, then for a period of 2 years from the start of your training and will then be archived for the applicable prescription periods, with the exception of sensitive data collected.

 

X. WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?

Under current regulations, particularly the GDPR, you have the right to access and correct your personal data, request erasure, object to processing on legitimate grounds and obtain limitation or portability, insofar as this is applicable.

In particular, the GDPR provides the following rights:

• Right to information: you have the right to obtain clear, transparent and understandable information about how we use your personal data and about your rights. You will find all of this information in this Statement
• Right of access: you have the right to access the personal data that MAKE UP FOR EVER holds about you
• Right of rectification: you have the right to have your personal data rectified if it is inaccurate or obsolete and / or to supplement it if it is incomplete
• Right to erasure / right to be forgotten: you have the right to have your data erased or deleted. However, this right may be limited by a legal reason or our legitimate interest in keeping your personal data
• Right of opposition: you can at any time request to no longer receive our communications relating to our offers, news and events. You can in particular use the hypertext link provided for this purpose in each email or communication that we send to you. You can also request to receive non-personalized communications about our products and services
• Right to withdraw consent at any time for data processing based on consent: you can withdraw your consent relating to our processing of your data when this processing is based on consent
• Right to data portability: you have the right to move, copy or transfer data from our database to another. This right only applies to the data you have provided, and provided that the processing is based on a contract or your consent and carried out using automated processes

You also have the right to issue general or specific directives concerning the preservation, erasure and communication of your data post-mortem.

 

You can exercise these rights directly with MAKE UP FOR EVER by sending an email to dpo@makeupforever.com or a non-registered letter by post to 5/7 rue du commandant Pilot, 92200 Neuilly sur Seine including a document proving your identity.

 

As part of the MAKE UP FOR EVER Academy course, you can also exercise your rights at dpo_academy@makeupforever.fr

 

You may at any time request to no longer receive communications from us regarding our offers, news and events by using the hypertext link provided for this purpose in each email we send you. You can also contact us by telephone by calling 01 41 43 13 19 (toll free) from 9am to 7pm, 5 days a week or by post to Customer Services and E-commerce, 5/7 rue du commandant Pilot, 92200 Neuilly sur Seine.

You also have the right to file a complaint with your local Data Protection Authority (European Data Protection Board: https://edpb.europa.eu/about-edpb/board/members_en) or the Commission Nationale Informatique et Libertés (CNIL), 3 place de Fontenoy TSA 80715 - 75334 Paris Cedex 07 - www.cnil.fr

 

CONTACT DETAILS OF THE DATA PROTECTION OFFICER (DPO)

For all questions relating to the collection and processing of your data by MAKE UP FOR EVER, you can contact the MAKE UP FOR EVER Data Protection Officer at dpo@makeupforever.com and MAKE UP FOR EVER Academy at dpo_academy@makeupforever.fr.

 

 

 

Last update : 29/07/2022