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Privacy Policy

Effective Date: October 15th, 2024

This Privacy Policy was updated on October 15th, 2024.

1 - Introduction

Clarins USA, Inc. and its affiliates in the United States (collectively, “Clarins”, “us”, “our” or “we”) are committed to protecting the privacy of your personal information. This Privacy Policy describes what information we collect about you, what we do with that information, your choices with respect to our processing of your personal information, and our information privacy practices. We urge you to read this Privacy Policy in its entirety before providing your personal information to us.

This Privacy Policy applies to Clarins, its affiliates operating in the United States, and websites or applications that link to this Privacy Policy (collectively, “Clarins’ Websites” or “Site”). This Privacy Policy also applies to our collection and use of your personal information on the Site and at our stores for marketing communications, campaigns and programs, and to process your purchase of product or services from us. Unless otherwise specifically noted in this Privacy Policy or a State-specific privacy notice, these terms do not apply to individuals acting as employees, job applicants, or contractors.

This Privacy Policy is incorporated into our Terms and Conditions, available here, which also apply when you use Clarins’ Sites and purchase products and services from us.

2 - Types of Information Collected and Processed

Personal Information We Collect and Process

Personal information or personal data means any information that is linked (or reasonably linkable) to an identified or identifiable natural person. It does not include publicly-available information or de-identified information.

We collect and process the following categories of personal information:

Personal identifiers, such as your first and last name, address, telephone number, birth date, gender, email address, profile information, and social media profile;
Commercial information, such as your purchase history;
Biometric information, such as your facial geometry, to provide you with certain goods and services (see the “Notice of Clarins’ Biometric Data Practices” section of this Privacy Policy for more information);
Internet or other electronic network activity information, including browsing and search history, where such information is linked to you; and
Inferences drawn from other personal information.

Other Information We Collect

We also collect information that does not identify you personally. It can include Internet protocol (IP) address if that IP address does not identify an individual or household, internet service provider, site access times, referring websites, and web pages within the Clarins’ Websites visited and general location information (e.g., city, state) based on IP addresses. We sometimes refer to this information as “Non-Identifying Information.” We collect Non-Identifying Information in many ways including through automated logging of activity on the Clarins’ Websites. Non-Identifying Information is not linked to you or used to identify a specific person.

Note that we may link non-personal information to personal information in order to provide you with better recommendations, help authenticate you or other data or information you may provide, prevent fraud, and ensure that Clarins’ Sites meet your needs. When we link non-personal information to personal information, such information becomes “personal information” for purposes of this Privacy Policy.

Although it may appear that we collect financial information from you on the Site or in providing services that you request, it is actually collected and processed through a third party service provider (“Payment Processor”) that processes payments for us. The Payment Processor may collect financial information such as banking information or credit card number, name, CVV code or date of expiration, from you on the Service. We do not store or maintain your financial information.

3 - When We Collect Personal Information

We collect personal information from or about you when you voluntarily provide us with this information or when you visit the Site or contact our Customer Care. However, if you choose not to provide the information we request, you may be unable to fully enjoy Clarins’ Sites and services, make a purchase, or complete a transaction.

We collect your personal information when you:

Place an order through Clarins’ Sites or in our stores;
Book a spa appointment;
Create an account on Clarins’ Sites;
Contact us through Customer Care including phone, email, chat & chat bot;
Enter a sweepstakes or contest, take a survey, sign up for a loyalty program or subscribe to a newsletter, rate or review our products and/or services, chat with other visitors in real time, contact us with a comment or question, sign up either online or in store to receive emails or marketing communications about our products or services, check your eligibility for and/or participate in our referral program (Refer a Friend) as a referred friend; or
Visit one of our pages on a third party social networking platform such as Facebook, YouTube, Instagram, Twitter or Pinterest.

If you give us personal information of another person, you represent that you have the authorization from that person to provide such information.

Telephone calls to our Customer Care may be monitored and/or recorded by us for quality assurance and training purposes. By contacting Clarins Customer Care by telephone, you consent to the recording.

Clarins works with third party vendors in operating the website, including the chat functions available on the website. When you use any of our chat functions including chat bot, third parties may have or be provided access to information about you or the contents of the chat session either in real time or by way of a recording. By using our chat functions, you consent to any such access and the use and disclosure of such information by Clarins and the vendors.

4 - Why We Collect and Process Personal Information

We collect and process personal information to serve you better and to provide you with a customized experience while using Clarins’ Sites and visiting our stores. To the extent permitted by law, we collect and process your personal information for the following business and commercial purposes:

To administer Clarins’ Websites, perform analytics, anticipate and resolve problems with these sites, store contacts you enter, and improve the quality of service;
To request feedback and develop, customize, and improve Clarins’ Sites, our products, and publications;
To process your order, complete a transaction, and perform after-sales services;
To schedule, confirm, reschedule, or cancel your spa appointment and to send you appointment reminders;
To keep track of any purchase made by you and/or notify you of any product or service we believe may be of interest to you;
To contact or alert you about Clarins’ Sites, or any products, activities, special events, or offers from us or our partners; and/or to contact or alert you for other marketing, informational, product development, or promotional purposes;
To conduct Customer Relationship Management (CRM) (including our loyalty program, our referral program, newsletters, promotions, ratings and reviews, chat, product testing, and surveys);
To conduct marketing analysis;
To connect you to external third party applications, such as when you create an account using an external application;
To prevent and detect fraud;
To contact you about your use of Clarins’ Sites, or to otherwise respond to your emails, submissions, comments, requests or complaints, including customer support inquiries and questions about our products or services;
To link your personal information to your non-personal information or demographic information in order to provide you with recommendations for products or services based on your interests, purchase history, age, or location;
To combine the personal information you provide us with other information (such as demographic and past purchase information) from our records and from other sources, such as address update services, to use for future marketing initiatives and to help us improve Clarins’ Sites and your overall shopping experience;
For other purposes about which we notify you or as required by law at the point of collection.

5 - Personal Information We Disclose To Third Parties

Personal Information Category	Categories of Third-Party Recipients
Identifiers.	Affiliates, parents, and subsidiary organizations of Clarins; business partners; advertisers and advertising networks; social media companies; internet cookie information recipients, such as analytics and behavioral advertising services.
Commercial information.	Affiliates, parents, and subsidiary organizations of Clarins; business partners; advertisers, and advertising networks.
Internet or other similar network activity.	Affiliates, parents, and subsidiary organizations of Clarins; business partners; service providers; advertisers and advertising networks; social media companies; internet cookie information recipients, such as analytics and behavioral advertising service.
Inferences drawn from other Personal Information.	Business partners; advertisers and advertising networks.

6 - Why We Disclose Personal Information To Third Parties

We disclose personal information to third parties for the following business and commercial purposes:

Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf.
Short-term, transient use, including non-personalized advertising shown as part of your current interaction with us.
Providing advertising and marketing services to you.
Helping to ensure data security and integrity.
Debugging to identify and repair errors that impair existing intended website functionality.
Internal research for technological development and demonstration.
Performing the services or providing the goods reasonably expected by an average consumer who requests those goods or services.
Verifying and validating your identity or otherwise preventing, investigating, or providing notice of fraud, unlawful or criminal activity, or unauthorized access to or use of personal information, and our website or data systems.
Personalizing your experience with our services with content and offers that are tailored to you, including special offers from other companies.
Providing you with newsletters, articles, product or service alerts, new product or service announcements, savings awards, event invitations, and other information.
Including you in market research, surveys, promotions, sweepstakes, and contests.
Improving our services, such as the way offers are made, based on the purchasing decisions of our customers, and improving the interactions visitors have with our services.
Alerting you about a product safety announcement or recall or correction of an offer, promotion, or advertisement.
Keeping a record of our interactions with you if you place an order or otherwise deal with our representatives over the telephone or online.
Enabling you to interact with content service providers, whether by linking to their sites, viewing their content within our online environment, or by viewing our content within their online environment.
Performing services on our behalf.
Providing advertising and marketing services to you.
Managing employees’, applicants’, and contractors’ relationship with us.
Creating aggregated, pseudonymized, or anonymized information for analytical and statistical purposes.
Complying with our legal obligations, including complying with law enforcement or governmental authority requests, participating in judicial proceedings, responding to requests from third parties based on their legal rights, and investigating fraudulent activity.
Enforcing and defending our legal rights and those of our employees, affiliates, and agents.

7 - Data Collection Technologies We Use

Cookies and Web Tracking Techniques

We use “cookies” on Clarins’ Sites to help us analyze web traffic and evaluate and improve the content and functions of Clarins’ Sites. A cookie is a small text file that is sent by a website, accepted by a web browser, and then placed onto your computer’s hard drive. Cookies help us analyze use of our Sites and better aggregate useful information when users provide feedback about our Sites or products. You can set your browser to refuse cookies from our Sites. This will provide you with more control over the acceptance of cookies on your device. However, it is possible that some portions of our Sites will not function properly or may perform more slowly if you choose to reject cookies. By using our Sites and not disabling cookies, you consent to receiving these cookies and our collection of data through the use of these cookies.

Third Party Advertisers

We may use advertisers, third party ad networks, and other advertising companies to serve advertisements on Clarins’ Sites. These advertising companies may also gather information about your visit to Clarins’ Sites (such as through cookies, web beacons, and other technologies) to enable such advertising companies to market products or services to you and to monitor which ads have been served to your browser and which webpages you were viewing when such ads were delivered. For more information about Internet-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit: www.networkadvertising.org/managing/opt_out.asp and www.aboutads.info/choices.

PLEASE NOTE THAT THIS PRIVACY POLICY DOES NOT COVER THE COLLECTION AND USE OF INFORMATION BY SUCH ADVERTISING COMPANIES.

Google Analytics

We use a tool called “Google Analytics” to collect information about use of Clarins’ Sites. Google Analytics collects information such as how often users visit our sites, what pages they visit when they visit, and what other sites they used before coming to our Sites. We use the information we get from Google Analytics only to improve Clarins’ Sites. Google Analytics collects only the IP address assigned to you on the date you visit Clarins’ Sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with other personal information. Although Google Analytics places a permanent cookie on your web browser to identify you as a unique user the next time you visit Clarins’ Sites, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to Clarins’ Sites is restricted by the Google Analytics Terms of Use (www.google.com/analytics/tos.html) and the Google Privacy Policy (www.google.com/privacypolicy.html). You can prevent Google Analytics from recognizing you on return visits to Clarins’ Sites by disabling cookies on your browser. For more information about how Google uses data when you use Clarins’ Sites, you can visit: www.google.com/policies/privacy/partners.

Plug-Ins

Our Site uses social plugins (“plugins”) from social networks such as Facebook, Twitter, YouTube, and Instagram. These plugins are indicated by the social networks’ respective logos on Clarins’ Websites and are used to establish a direct connection with the servers of these social networks.

Integration of the plugin allows the social media networks to receive the information that you have loaded onto the corresponding page of the Site. If you are logged in with Facebook, for example, it will be able to assign your visit to your account. An exchange of this information already takes place when you visit our Site, regardless of whether you interact with the plugin. If you interact with the plugins, the corresponding information is sent directly to the social network by your browser and saved there. You can find information about how the data is used by the social networks, your rights, and optional settings to protect your privacy on the social networks’ websites.

If you do not want social networks to gather data about you via our Site, you must log out on the social network domain before visiting the Site. To prevent information being exchanged with the social networks during your visit to our Site, you can opt out of cookies through your browser settings and other tools.

8 - Information on Public Areas of Clarins’ Sites

Any information you submit in a public area of Clarins’ Sites – such as on a social media page, user comments, comments on Clarins’ blogs, reviews or comments on any ratings and reviews feature, questions or answer on a question and answer application or any other public forum – will not be treated as confidential and may be publicly disclosed. This applies to personal information, so please consider your public postings before doing so. Additionally, information posted on social media pages will be subject to the terms governing those pages and websites.

9 - Protecting Kids’ Privacy

Clarins’ Sites are not intended for children. We do not knowingly collect personal information from children, and Clarins’ Sites are not designed to attract children. If you believe we have collected personal information about your child under the age of 13, please contact us using the contact information in Section 22.

10 - Protecting Your Security

Clarins’ Sites employ security measures in accordance with industry standards to protect the security of your personal information both online and offline. For example, your personal information is stored on computer servers in a controlled environment that is reasonably protected from unauthorized use or disclosure. Only you can access your account information using the password you chose when you created the account. It is your responsibility to maintain the security and confidentiality of your password. You should always sign off your account and close your browser when you are finished using your account.

11 - Your Rights and Choices Regarding Your Personal Information

You can exercise the following rights and choices with respect to your personal information either through your online account or by sending us a Consumer Request using the contact information in Section 22 below:

You can ask us to confirm whether we are processing your personal information, and to access (get a copy of) your personal information. If you are a resident of certain States (for example, Utah and Virginia), applicable law limits access rights to personal information that you provided to us. We will provide copies in a portable and—to the extent practicable—readily usable format. For personal information processed automatically, we will provide copies in a formal that allows you to transmit the data to someone else without hindrance. If you are a resident of certain States (for example, Colorado), applicable law limits the number of times per year that you may exercise an access request;
You can ask us to correct inaccuracies in your personal information, which includes having incomplete personal information completed;
You can ask us to stop sending you electronic marketing communications, including by following the procedures described in the Opting Out Section 13 below;
You can ask us to delete your personal information, subject to our obligation or ability to retain your personal information under applicable law. If you are a resident of certain States (for example, Utah), applicable law limits deletion rights to personal information that you provided to us;
If our use or disclosure of your personal information is based on consent, you can withdraw your consent at any time, except to the extent we have already used or disclosed personal information in reliance on your consent. If you withdraw consent, we may not be able to provide certain products or services to you.

We will respond to your request within forty-five (45) days of receiving it, unless applicable law requires a response within a shorter time. If you are a resident of certain States (for example, Colorado, Connecticut, Utah, and Virginia), we may be able to notify you that we need up to forty-five (45) more days to respond.

In most cases, we will honor your request. If applicable law allows us to refuse or limit your request, we will notify you within the time period above and, if and to the extent required by applicable law, make an appeal process available to you.

You may exercise these rights and choices by making a Consumer Request, as described below.

12 – Sale of Personal Information, and Processing Personal Information for Targeted Advertising; Opting-Out

We do not sell personal information as the term “sell” is commonly understood to mean in exchange for money. However, we do process personal information for targeted advertising, including disclosing it to unaffiliated third parties (sometimes called “Sharing”), through the use of advertising and analytics cookies on our Site. This may considered a “sale” of personal information under certain States’ laws (for example, Colorado and Connecticut) that define the “sale” of personal information to include providing it to third parties in exchange for valuable consideration other than money. Any such “sale” is limited to our use of third-party advertising and analytics cookies, their use in providing behavioral advertising, and their use in understanding how people use and interact with our services.

You have the right, at any time, to tell us not to process your personal information for targeted advertising. You may exercise this right by doing any of the following: (i) clicking the link below, (ii) adjusting your cookie preferences, (iii) configuring your browser to send us a privacy signal, or (iv) making a Consumer Request, all as described in more detail below.

Selling/Sharing Link

Click here to opt-out: Do Not Sell or Share My Personal Information

Adjusting Your Cookie Preferences

You may also opt-out of our processing your personal information for targeted advertising by setting your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you do not consent to our use of cookies or if you select this setting, you may be unable to access certain parts of our Site, applications, or other websites. You can find more information about cookies at http://www.allaboutcookies.org and http://youronlinechoices.eu.

Browser Privacy Control Signals

You may also exercise your right to opt-out of our processing your personal information for targeted advertising by setting the privacy control signal on your browser, if your browser supports it. We currently recognize and support the following privacy signals sent by browsers:

Global privacy control (for more information on how to configure your browser to send this signal, please see https://globalprivacycontrol.org/).

When we receive one of these privacy control signals, we will opt you out of any processing of your personal information for targeted advertising when you interact with our services through that browser and on that mobile device. We are only able to propagate your choice to opt-out to your account if you are currently logged in when we receive the privacy control signal from your browser. When we are able to propagate your choice to your account, you will be opted out on all browsers and devices on which you are logged in, and for both online and offline processing for targeted advertising.

Consumer Requests

You may also exercise your right to opt-out of our processing your personal information for targeted advertising more broadly, by submitting a Consumer Request as described below.

13 - Opting Out of Commercial Emails, and Unsolicited Mail or Telephone Advertising and Marketing Communications

If you would like to opt out of receiving commercial emails from us, please follow the unsubscribe instructions located at the bottom of each email, or call (866) 325-2746.

If you would like to opt out of receiving unsolicited mail or telephone advertising or marketing communications from us, please send your request, including your name, email address, street address, city, state, and zip code, via email to Help-USA@Clarins.com (please use the subject line: Privacy Opt-Out Request), or call us at (866) 325-2746.

We will process your properly transmitted request within the time period required by law, but you may, in the meantime, receive previously scheduled communications from us. Once you have opted out, you do not need to do so again.

14 - Our Referral Program (Refer a Friend)

Our referral program allows Clarins’ customers to invite members of their personal network to share the Clarins experience through the Refer a Friend program. This begins when your referring friend (“Friend”) sends a referral link to you via their personal social media, email, text, or other means. If you choose to open the referral link, you will be directed to our Refer a Friend page where we will ask for your first and last name and email address to check your program eligibility, i.e., no previous Clarins.com purchase history. If you are eligible, we will email you a promotional code for use on your first online purchase. When you place your first order, your Friend will also receive a promotional code for their next online purchase.

We will let your Friend know that you have clicked on the referral link by displaying your first name and a truncated version of the email address you provide on the “Refer a Friend” section of the Friend’s “My Account” of our Site, along with your first-order status (“Placed order” or “Waiting for an order”). This information will only be available to us, and to individuals with your Friend’s account login information.

If you are eligible for the Refer a Friend program, we will use, disclose, and otherwise process the personal information you provide as described in this Privacy Notice and our Terms & Conditions. This will include sending you periodic emails with information about Clarins such as new product launches, personalized offers, and product previews. You may opt out of receiving commercial emails as described in this Privacy Notice.

15 - Changing, Updating, or Deleting Personal Information in Your Account

You can update, change, or delete certain personal information (such as your email address, mailing address, and payment method) on Clarins’ Websites by clicking “My Account” in the menu at the top of each page.

If the information you wish to update, change, or delete is not included in the “My Account” page, you can request an update, change, or deletion by emailing Help-USA@Clarins.com.

16 - International Transfer of Information

If you choose to provide us with personal information, we may transfer that information to our affiliates or to other third parties across borders, and from your country or jurisdiction to other countries or jurisdictions around the world. If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your personal information to the United States, which does not have the same data protection laws as the EU. By providing your personal information you consent to: (i) the use of your personal information for the purposes identified above in accordance with this Privacy Policy, and (ii) the transfer of your personal information to the United States as indicated above.

17 - Changes to our Privacy Policy

We reserve the right to modify this Privacy Policy at any time. We will post the revised policy here, which will be effective as soon as it is posted. We suggest you periodically review this Privacy Policy for any changes. Your continued use of Clarins’ Sites subject to this Privacy Policy will signify your acceptance of Privacy Policy changes.

18 - Governing Law

Where permitted by applicable law, this Privacy Policy shall be governed by and construed in accordance with the laws of the State of New York, excluding its conflicts-of-law principles and you expressly agree that exclusive jurisdiction for any claim or dispute with Clarins or relating in any way to your use of Clarins’ Sites lies in the state and/or federal courts sitting in the Southern District of New York. With respect to any such claims, you further agree and expressly consent to the exercise of personal jurisdiction in the state and/or federal courts sitting in the Southern District of New York in connection with any such dispute, including any claim involving Clarins, the Clarins’ Sites, our affiliates, subsidiaries, employees, contractors, officers, directors, telecommunications providers, and/or content providers.

19 - Notice of Clarins’ Biometric Data Practices

In order to allow the Clarins’ Virtual Try On program to function properly, we may need to collect, capture, use, and store pictures of you, which may show your facial geometry. Some laws may label pictures of you and your facial geometry as “biometric identifiers”, “biometric information”, “biometric data”, or any number of similar terms referring to details about your physical appearance, or body, that can be used to identify you, which we will refer to here as “Biometrics”.

We may collect or capture your Biometrics based on an image that you upload, or that is captured from a webcam or similar device. If collected, your Biometrics may be used to create a digital representation of your face so that you may apply any number of our products to the digital representation and gain a better understanding of how our products will look on you in real life before buying them.

If collected, we may store your Biometrics until you complete the session, at which point, we will permanently delete your Biometrics.

Clarins does not disclose your Biometrics to any third parties.

Please feel free to email us with any question at Help-USA@Clarins.com.

20 - Do Not Track Disclosures

Clarins does not support Do Not Track browser settings and does not currently participate in any “Do Not Track” frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your personal information or cookie data.

21 - Your California Privacy Rights

If you are a resident of California, you have the additional rights described in the California Privacy Addendum.

22 – Consumer Requests/Contact Us

For further information on our Privacy Policy, or questions on information that we may have collected from you, or to make a Consumer Request to exercise your rights and choices set forth in this Privacy Policy, please contact Clarins using any of the following methods:

Mail:
Clarins USA, Inc.
Customer Care
15 Olympic Drive
Orangeburg, NY 10962

Email:
Help-USA@Clarins.com

Telephone:
(866) 325-2746

If you do not make your Consumer Request in the ways described above, we may either treat your request as if it had been made in one of the ways above or provide you with information on how to submit the request or to remedy any deficiencies with your request.

Only you, or—where permitted by law—your authorized agent, may make a Consumer Request related to your personal information.

All Consumer Requests must:

Provide enough information to allow us to reasonably verify you are the person about whom we collected personal information, or the authorized agent of such a person. This may include verifying personal information that we may already have about you, such as your name, email address, telephone number, and other similar information.
Describe your request with enough detail to allow us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm what personal information relates to you or the individual for whom you are making the request as their authorized agent.

Making a Consumer Request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a Consumer Request to verify the requestor’s identity or authority to make the request.

23 – SMS

You may consent to receive recurring advertising and promotional auto-dialed text messages from us or on our behalf (“Text Messages”). When you sign up to receive Text Messages, we will send you information about promotional offers and more. These messages may use personal information automatically collected based on your actions while on our sites and may prompt text messaging such as cart abandon messages (IE Cookies). When you send and receive Text Messages, we receive and store the personal information you provide, including your telephone number, the content of the message, and when you read the message. You may opt out of receiving Text Messages at any time by replying “STOP” to a Text Messages. For more information about Text Messages, see our Terms and Conditions.

All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Privacy Addendum for California Residents

Effective Date: November 7, 2023

This Privacy Addendum was updated on November 7, 2023

1 – Introduction

This Privacy Addendum for California Residents (the “California Privacy Addendum”) supplements the information contained in Clarins’ Privacy Policy and describes our collection and use of Personal Information (as defined below). This California Privacy Addendum applies only to California Consumers (natural persons who reside in the State of California) (“Consumers” or “you”). In accordance with the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), if you are a resident of California, you have the rights described below. Any terms defined in the CCPA have the same meaning when used in this Addendum.

2 - Scope of this California Privacy Addendum

This California Privacy Addendum applies to information that we collect that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“Personal Information”). However, Personal Information does not include, and this California Privacy Addendum does not apply to: (a) publicly available information; (b) lawfully obtained, truthful information that is a matter of public concern; and (c) deidentified or aggregated information.

3 – Types of Information Collected

In the past twelve (12) months, we have collected the following categories of Personal Information about Consumers. We collect some categories of Personal Information—and some “examples” within categories—only with respect to particular Consumers or types of Consumers. For example, we collect the Social Security number of job applicants and employees, but not of customers who purchase our products and services:

Category	Examples
A. Identifiers.	A real name; alias; postal address; online identifier; Internet Protocol address; email address; account name; and other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name; physical characteristics or description; address; telephone number; bank account number; credit card number, debit card number, or any other financial information. Some Personal Information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.	Age (40 years or older); sex (including gender, gender identity, gender expression).
D. Commercial information.	Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric Information.	We may collect biometric information, such as your facial geometry, to provide you with certain features including Clarins' "Virtual Try On" Tool. See the "Notice of Clarins' Biometric Data Practices" section of our Privacy Policy for more information.
F. Internet or other similar network activity.	Browsing history; search history; information on a Consumer’s interaction with a website, application, or advertisement.
I. Professional or Employment-Related Information	Employment application information, background check, work authorization, performance and disciplinary records, salary, bonus, commission, and other similar compensation data, benefit plan enrollment, participation, and claims information, health data concerning employee and their family members.
K. Inferences drawn from other Personal Information.	Profile reflecting a person’s preferences, characteristics, predispositions, and behavior.
L. Sensitive Personal Information	Social Security, driver’s license, state identification card, or passport number; racial or ethnic origin (when voluntarily provided); health-related information.

Clarins will not collect additional categories of Personal Information without providing you notice.

4 – When We Collect Personal Information

We collect Personal Information about you as described in our Privacy Policy.

5 – Categories of Sources of Personal Information

We obtain Personal Information from the following categories of sources:

Consumers and others acting on their behalf.
For Consumers who are job applicants: Personal and professional references, and past and present employers.
For Consumers who are employees or their beneficiaries: Health care providers for benefits management.
Outside organizations in connection with human resource activities and employee/applicant/contractor management.
Operating systems and platforms.
Web and data analytics companies.
Contractors and service providers.
Financial and payment technology providers,
Public records or widely available sources, including information from the media, and other records and information that are made available by federal, state, and local government entities.
Outside organizations that provide data to support activities such as fraud prevention, underwriting, and marketing.
Outside organizations in connection with providing products and services, completing transactions, supporting our everyday operations, or business management and development.
Social media.

6 – Purposes for Our Collection of Your Personal Information

We have collected the categories of Personal Information described in Section 3 for the Business Purposes and Commercial Purposes described in Section 4 of our Privacy Policy.

7 – Third Parties to Whom We Disclose Your Personal Information for Business Purposes

We may disclose your Personal Information to third parties for one or more Business Purposes. In the preceding twelve (12) months, Clarins has disclosed the following categories of Personal Information for one or more of the business purposes to the following categories of third parties:

Personal Information Category	Categories of Third-Party Recipients
A. Identifiers.	Affiliates, parents, and subsidiary organizations of Clarins; business partners; advertisers and advertising networks; social media companies; internet cookie information recipients, such as analytics and behavioral advertising services.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Affiliates, parents, and subsidiary organizations of Clarins; business partners; advertisers, and advertising networks.
C. Protected classification characteristics under California or federal law.	Affiliates, parents, and subsidiary organizations of Clarins; business partners; advertisers and advertising networks.
D. Commercial information.	Affiliates, parents, and subsidiary organizations of Clarins; business partners; advertisers, and advertising networks.
E. Biometric information.	We do not disclose your biometrics to any third parties. When using Clarins’ Virtual Try-On tool, the underlying software is provided by Perfect Corp, however, Perfect Corp does not receive, collect, share, or store any biometric information or other user data. The experience runs within the browser on your own device (PC or Mobile).
F. Internet or other similar network activity.	Affiliates, parents, and subsidiary organizations of Clarins; business partners; service providers; advertisers and advertising networks; social media companies; internet cookie information recipients, such as analytics and behavioral advertising service.
I. Professional or Employment-Related Information	Affiliates parents, and subsidiary organizations of Clarins, and outside organizations, in connection with human resource activities and applicant and workforce management.
K. Inferences drawn from other Personal Information.	Business partners; advertisers and advertising networks.
L. Sensitive Personal Information	Affiliates parents, and subsidiary organizations of Clarins, and outside organizations, in connection with human resource activities and applicant and workforce management.

We disclose your Personal Information to the categories of third parties listed above for the following Business Purposes and Commercial Purposes:

Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf.
Short-term, transient use, including non-personalized advertising shown as part of your current interaction with us.
Providing advertising and marketing services to you.
Helping to ensure data security and integrity.
Debugging to identify and repair errors that impair existing intended website functionality.
Internal research for technological development and demonstration.
Performing the services or providing the goods reasonably expected by an average Consumer who requests those goods or services.
Verifying and validating your identity or otherwise preventing, investigating, or providing notice of fraud, unlawful or criminal activity, or unauthorized access to or use of personal information, and our website or data systems.
Personalizing your experience with our services with content and offers that are tailored to you, including special offers from other companies.
Providing you with newsletters, articles, product or service alerts, new product or service announcements, savings awards, event invitations, and other information.
Including you in market research, surveys, promotions, sweepstakes, and contests.
Improving our services, such as the way offers are made, based on the purchasing decisions of our customers and improving the interactions visitors have with our services.
Alerting you about a product safety announcement or recall or correction of an offer, promotion, or advertisement.
Keeping a record of our interactions with you if you place an order or otherwise deal with our representatives over the telephone or online.
Enabling you to interact with content service providers, whether by linking to their sites, viewing their content within our online environment, or by viewing our content within their online environment.
Performing services on our behalf.
Providing advertising and marketing services to you.
Managing employees’, applicants’, and contractors’ relationship with us.
Creating aggregated, pseudonymized, or anonymized information for analytical and statistical purposes.
Complying with our legal obligations, including complying with law enforcement or governmental authority requests, participating in judicial proceedings, responding to requests from third parties based on their legal rights, and investigating fraudulent activity.
Enforcing and defending our legal rights and those of our employees, affiliates, and agents.

8 – To Whom Do We Sell or Share Your Personal Information

Sale of Your Personal Information

As noted in our Privacy Policy, we do not sell Personal Information as the term “sell” is commonly understood to require an exchange for money. However, the use of advertising and analytics cookies on our Site is considered a “sale” of Personal Information, as the term Sale is broadly defined in the CCPA to include communicating Personal Information to a third party in exchange for valuable consideration other than money. Our Sale of Personal Information is limited to our use of third-party advertising and analytics cookies, their use in providing behavioral advertising, and their use in understanding how people use and interact with our Services. Our Sale of your Personal Information in this way is subject to your right to opt-out (see Your Choices Regarding Our Sale or Sharing of Your Personal Information).

Sharing of Your Personal Information for Cross-Context Behavioral Advertising

Clarins may communicate your Personal Information to a third party for the purpose of cross-context behavioral advertising (“Share” it), subject to your right to opt-out (see Your Choices Regarding Our Sale or Sharing of Your Personal Information). Our Sharing of Personal Information is limited to our use of third-party advertising cookies and their use in providing you cross-context behavioral advertising (i.e., advertising on other websites or in other mediums). When the recipients of your Personal Information disclosed for the purpose of cross-context behavioral advertising are also permitted to use your Personal Information to provide advertising to others, we also consider this disclosure as a “sale” of Personal Information under the CCPA.

In the preceding twelve (12) months, Clarins has Sold or Shared the following categories of Personal Information to and with the following categories of third parties:

Personal Information Category	Sold or Shared	Categories of Third Parties To Whom Your Personal Information is Sold or Shared	Business or Commercial Purpose For Selling and/or Sharing
A. Identifiers.	Sold and Shared	Affiliates, parents, and subsidiary organizations of Clarins; Service Providers; Advertisers and advertising networks; Social media companies; Internet cookie information recipients, such as analytics and behavioral advertising services.	Providing you with newsletters, articles, product or service alerts, new product or service announcements, savings awards, event invitations, and other information. Short-term, transient use, including non-personalized advertising shown as part of your current interaction with us. Providing advertising and marketing services to you. Personalizing your experience with our Services with content and offers that are tailored to you
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Sold and Shared	Affiliates, parents, and subsidiary organizations of Clarins; Service Providers; Advertisers and advertising networks; Social media companies; Internet cookie information recipients, such as analytics and behavioral advertising services.	Providing you with newsletters, articles, product or service alerts, new product or service announcements, savings awards, event invitations, and other information. Short-term, transient use, including non-personalized advertising shown as part of your current interaction with us. Providing advertising and marketing services to you. Personalizing your experience with our Services with content and offers that are tailored to you
C. Protected classification characteristics under California or federal law.	Shared	Affiliates, parents, and subsidiary organizations of Clarins; Service Providers; Advertisers and advertising networks.	Providing you with newsletters, articles, product or service alerts, new product or service announcements, savings awards, event invitations, and other information. Providing advertising and marketing services to you. Personalizing your experience with our Services with content and offers that are tailored to you
D. Commercial information.	Shared	Affiliates, parents, and subsidiary organizations of Clarins. Service Providers; Advertisers and advertising networks;	Providing you with newsletters, articles, product or service alerts, new product or service announcements, savings awards, event invitations, and other information. Short-term, transient use, including non-personalized advertising shown as part of your current interaction with us. Providing advertising and marketing services to you. Personalizing your experience with our Services with content and offers that are tailored to you
F. Internet or other similar network activity.	Sold and Shared	Affiliates, parents, and subsidiary organizations of Clarins; Service Providers; Advertisers and advertising networks; Social media companies; Internet cookie information recipients, such as analytics and behavioral advertising services.	Providing you with newsletters, articles, product or service alerts, new product or service announcements, savings awards, event invitations, and other information. Short-term, transient use, including non-personalized advertising shown as part of your current interaction with us. Providing advertising and marketing services to you. Personalizing your experience with our Services with content and offers that are tailored to you
K. Inferences drawn from other Personal Information.	Shared	Affiliates, parents, and subsidiary organizations of Clarins; Service Providers; Advertisers and advertising networks; Social media companies; Internet cookie information recipients, such as analytics and behavioral advertising services.	Providing you with newsletters, articles, product or service alerts, new product or service announcements, savings awards, event invitations, and other information. Short-term, transient use, including non-personalized advertising shown as part of your current interaction with us. Providing advertising and marketing services to you. Personalizing your experience with our Services with content and offers that are tailored to you

Sale and Sharing of Personal Information of Minors Under the Age of 16

We will not Sell or Share (as defined above) the Personal Information of a Consumer if we have actual knowledge that the consumer is less than 16 years of age, unless the Consumer (when the Consumer is at least 13 years of age and less than 16 years of age), or the Consumer’s parent or guardian (when the Consumer is less than 13 years of age) has affirmatively authorized the Sale or Sharing of the Consumer’s Personal Information.

More information on how minors under the age of 16 may change their choice regarding the “sale” or “sharing” of their Personal Information can be found in Your Choices Regarding Our Sale or Sharing of Your Personal Information.

9 – Use and Disclosure of “Sensitive Personal Information”

We do not Use or Disclose Sensitive Personal Information for purposes other than § 7027(m) of the California Consumer Privacy Act Regulations.

We do not process Sensitive Personal Information to infer characteristics about a Consumer.

10 – Consumer Data Requests

The CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights. We will honor requests received to the extent required by law and within the time provided by law. You may exercise these rights yourself or through your Authorized Agent. For more information on how you or your Authorized Agent can exercise your rights, please see Exercising Your CCPA Privacy Rights.

Your Rights and Choices Under California Law

Right to Know. You have the right to request that Clarins disclose certain information to you about our collection, Sale, Sharing, and disclosure of your Personal Information (a “Right to Know” Consumer Request). This includes:
Collection and Disclosure of Personal Information
(a) The categories of Personal Information we have collected about you;
(b) The categories of sources from which that Personal Information was collected;
(c) Our Business Purposes and Commercial Purposes for collecting Personal Information; and
(d) The categories of third parties to whom we disclose Personal Information.
Sale, Sharing, and Disclosure for Business Purposes (a) The categories of Personal Information that we Sold or Shared about you and the categories of third parties to whom the Personal Information was Sold or Shared.
(b) The categories of Personal Information that we disclosed about you for a Business Purpose, and the categories of persons to whom it was disclosed for a Business Purpose.
Access to Specific Pieces of Information. You have the right to request that Clarins provide you with a copy of the specific pieces of Personal Information that we have collected about you in the 12-month period before we received your request, including any Personal Information that we have created or otherwise received from a third-party about you (a “Right to Access” Consumer Request).
Correction. You have the right to request that we correct any inaccurate Personal Information that we maintain about you (a “Right to Correct” Consumer Request). You may review and correct some Personal Information about yourself by logging into the Site and visiting the “My Account” page. You may also request that we correct the Personal Information we have about you as described below under Exercising Your CCPA Privacy Rights.
Deletion. You have the right to request that Clarins delete any Personal Information that we collected from you, subject to certain exceptions (a “Right to Delete” Consumer Request).
Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not do any of the following as a result of you exercising your CCPA rights: (a) deny you goods or services; (b) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (c) provide you a different level or quality of goods or services; (d) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services; or (e) retaliate against an employee, applicant for employment, or Independent Contractor for exercising their rights under the CCPA. We may, however, offer you certain financial incentives as described below.

Your Choices Regarding Our “Sale” or “Sharing” of Your Personal Information

As noted above, like many companies, we communicate Personal Information to third parties for cross-context behavioral advertising. This constitutes the Sale (the only way in which we “sell” Personal Information) and Sharing of Personal Information under California law. You have the right, at any time, to direct us not to Sell or Share your Personal Information.

You may exercise the right to opt-out of the Sale and Sharing of your Personal Information by doing any of the following: (i) clicking the link below, (ii) adjusting your cookie preferences, (iii) configuring your browser to send us a privacy signal, or (iv) making a Consumer Request, all as described in more detail below.

Selling/Sharing Link

Do Not Sell or Share My Personal Information

Adjusting Your Cookie Preferences

You may also opt-out of Sale and Sharing by setting your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you do not consent to our use of cookies or if you select this setting, you may be unable to access certain parts of our Site, App, or other websites. You can find more information about cookies at http://www.allaboutcookies.org and http://youronlinechoices.eu.

Browser Privacy Control Signals

You may also exercise your right to opt-out of the Sale and Sharing of your Personal Information by setting the privacy control signal on your browser, if your browser supports it. We currently recognize and support the following privacy signals sent by browsers:

Global privacy control (for more information on how to configure your browser to send this signal, please see https://globalprivacycontrol.org/).

When we receive one of these privacy control signals, we will opt you out of any further Sale or Sharing of your Personal Information when you interact with our Services through that browser and on that mobile device. We are only able to propagate your choice to opt-out to your account if you are currently logged in when we receive the privacy control signal from your browser. When we are able to propagate your choice to your account, you will be opted out of Sale or Sharing of your Personal Information on all browsers and devices on which you are logged in, and for both online and offline Sale and Sharing.

Consumer Requests

You may also exercise your right to opt-out of the Sale and Sharing of your Personal Information more broadly, by submitting a Consumer Request as described below.

Opting Back In to Sale or Sharing

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to consent to Selling or Sharing. However, you may change your mind and opt back into Selling or Sharing by:

If you have opted out of the Sale or Sharing of your Personal Information through cookies by adjusting your cookie preferences or by following the above link, you may simply re-adjust your cookie preferences.
If you have opted out of the Sale or Sharing of your Personal Information through the use of a browser privacy control signal, you may turn off the signal and re-adjust your cookie preferences.
If you (or your Authorized Agent) submit a Consumer Request to opt-in to our Sale or Sharing of your Personal Information, we will use a two-step process to confirm your choice.

Exercising Your Rights: Making Consumer Requests

To exercise the Right to Know, Right to Access, Right to Correct, and Right to Delete, and to exercise your right to opt-out of the Sale or Sharing of your Personal Information more broadly, please submit a request (a “Consumer Request”) to us by either:

Calling us at (866) 325-2746
Emailing us at Help-USA@Clarins.com
Chatting with Customer Care via our Site
Submitting a form online via the Contact Us page

If you do not make your Consumer Request in the ways described above, we may either treat your request as if it had been made in one of the ways above, or provide you with information on how to submit the request or to remedy any deficiencies with your request.

Only you, or your Authorized Agent, may make a Consumer Request related to your Personal Information. To designate an Authorized Agent, see Authorized Agents below.

All Consumer Requests must:

Provide enough information to allow us to reasonably verify you are the person about whom we collected Personal Information, or the Authorized Agent of such a person. This may include verifying Personal Information that we may already have about you, such as your name, email address, telephone number, and other similar information.
Describe your request with enough detail to allow us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm what Personal Information relates to you or the individual for whom you are making the request as their Authorized Agent.

Making a Consumer Request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.

We will only use Personal Information provided in a Consumer Request to verify the requestor’s identity or authority to make the request.

Authorized Agents

You may authorize your agent to exercise your rights under the CCPA on your behalf by registering your agent with the California Secretary of State or by providing them with power of attorney to exercise your rights in accordance with applicable laws (an “Authorized Agent”). We may request that your Authorized Agent submit proof of identity and that they have been authorized to exercise your rights on your behalf. We may deny a request from your Authorized Agent to exercise your rights on your behalf if they fail to submit adequate proof of identity or adequate proof that they have the authority to exercise your rights.

11 – Personal Information Retention Periods

We will keep your Personal Information for no longer than is necessary for the purpose(s) it was provided for. Further details of the periods for which we retain Personal Information are available on request. However, we may retain any or all categories of Personal Information when your information is subject to one of the following exceptions:

When stored in our backup and disaster recovery systems. Your Personal Information will be deleted when the backup media your Personal Information is stored on expires or when our disaster recovery systems are updated.
When necessary for us to exercise or defend legal claims.
When necessary to comply with a legal obligation.
When necessary to help ensure the security and integrity of our Site

12 – Financial Incentives

We may offer you certain financial incentives that can result in different prices and may be deemed a “financial incentive” or “price or service difference” under the CCPA. If you elect to sign-up for the Club Clarins Loyalty Program, you opt-in to a financial incentive, and in addition to the Club Clarins US Loyalty Program-specific terms provided in our Terms and Conditions, the following terms apply.

In order to provide you with the Club Clarins Loyalty Program, we may use personal information about you, including your name, phone number, email address, purchase history, birthdate, or other similar information to identify you as a member of the program and provide you with relevant messaging, experiences, and deals. By participating in the Club Clarins Loyalty Program, you agree that the incentive you receive as the result of your participation in the program (e.g., Clarins Dollars, free products, or discounts on goods or services that you purchase from us) is reasonably related to the value of any personal information that you provide to us as a result of participating in the program.

Participation in the Club Clarins Loyalty Program is always optional. You may opt-out of the program at any time by emailing us at Help-USA@Clarins.com indicating that you want to opt-out of the Club Clarins Loyalty Program. You acknowledge and agree that you may no longer receive the incentive(s) that are part of the Club Clarins Loyalty Program, and that this difference in price or quality is not a discriminatory practice against you for exercising your rights under the CCPA.

Generally, we do not assign monetary or other value to personal information, however, California law requires that we assign such value in the context of financial incentives. In such context, we calculate the value of any offer, discount, or other financial incentive by using the expense related to the offer. Specifically, the expenses associated with the Clarins Club Loyalty Program include, but are not limited to, 10-15 points earned per dollar spent when purchasing eligible Clarins products and 2x bonus points for one purchase during your birthday month which are redeemable for Clarins Dollars and other special offers, free Clarins products, and/or free shipping. The specific expenses for the program vary based on your participation, activity, reward tier, total spend on Clarins products, the Personal Information you provide, and the discounts, promotion, or offers you choose to use.

13 – Changes to This CCPA Privacy Addendum

Clarins reserves the right to amend this California Privacy Addendum at our discretion and at any time. When we make changes to this California Privacy Addendum, we will post the updated addendum on the Site and update the addendum’s effective date. You are responsible for ensuring we have an up-to-date, active, and valid email address for you, and for periodically visiting our Site and this California Privacy Addendum to check for any changes. Your continued use of our Sites following the posting of changes constitutes your acceptance of such changes.

14 – Contact Information

If you have any questions or comments about this California Privacy Addendum, the ways in which Clarins collects and uses your information described above and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Mail:
Clarins USA, Inc.
Customer Care
15 Olympic Drive
Orangeburg, NY 10962

Email:
Help-USA@Clarins.com

Telephone:
(866) 325-2746