We, Habchi & Chalhoub Trading WLL, for our business unit Make Up For Ever, a company with headquarters located at PO box 21074 Salhiya Complex, Safat 13071, Kuwait City registered under no. 22814 (hereinafter referred as “MAKE UP FOR EVER”) respect the privacy of all our users and are committed to protecting information collected through www.makeupforever.com.kw (hereinafter referred to as the “Website”)
This aim of this privacy charter is to provide you with clear, simple and complete information about how we process the personal data you give us or the data we may collect while you are browsing our website, how it may be transferred to third parties and your rights and options to control your personal information and protect your privacy.
Where Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and the free movement of such data (hereinafter the "GDPR") applies, MAKE UP FOR EVER will be considered as the data controller of personal data collected on the Website.
I. What is personal data?
Personal data is any information that relates to an identified or identifiable living individual which may directly or indirectly lead to the identification of a person including without limitation an identification number, last name, first name, date of birth, customer number, order number, photo, etc.
II. When do we collect your personal data?
We can collect your personal data when you:
o create a customer account on our website, apps, or in our stores;
o order goods from our website;
o make purchases in stores;
o join our loyalty program;
o use our online services, such as the chat service;
o agree to receive marketing communications from us by email, telephone, SMS or post, depending on your selection;
o answer surveys or satisfaction questionnaires based on your customer experience;
o interact with our Company via its official page on social networks or when we suggest re-use of content that you have published on a social network;
o contact our customer service;
o send requests for information to our Company;
o take part in an event we organise;
o browse on the Internet using cookies or similar technology or when you click on advertisements for our products.
III. What personal data might we collect?
(i) 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 address)
· Your personal preferences in relation to the products we market or to our website (language);
· Information relating to your orders, their tracking and your purchase invoices;
· Information you may provide for 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;
Important: your bank details are encrypted on a secured payment platform server. Payments are processed via a secured payment platform, involving additional verifications, in order to guarantee the security of purchases made on the Website and combat fraud.
The details you provide of your Payment Card when placing an order are always encrypted prior to transit using an SSL (Secure Socket Layer) protocol.
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.
(ii) 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.
(iii) 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, read point xxx of this policy.
IV. For what purpose is your personal data collected and used?
MAKE UP FOR EVER processes your data to:
· enable you to create a customer account on our website, applications and at our counters and in our stores;
· manage your access to your customer account on the Internet or our applications;
· process and manage your online orders and their delivery;
· record purchases made at our counters or in our stores;
· secure online transactions, prevent fraud, payment incidents and manage debt collection (see our terms and conditions for more details) ;
· 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;
· profiling purposes that include the analysis of preferences and interests of the user based on the purchases from the Website either for assessing the user’s satisfaction or sending commercial and customized promotions;
· manage our loyalty program where applicable ;
· trace and manage any alerts you may send us;
· 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;
· subject to your consent, send you information on our offers, news and events on your chosen communication media;
· manage your participation in any events to which you have signed up;
V. What are the legal grounds for processing 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;
· within the framework of its legitimate interest for the purposes of marketing management, securing its digital media (websites, applications, etc.) and combating fraud;
· when you have given your consent for the processing of your data, especially for the purposes of managing our 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)
VI. Who are the recipients to which the personal data will be disclosed?
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 our legal obligations.
We may also share your personal data with;
· Affiliates within the Middle East Region or abroad, as well as with our joint venture partners;
· other entities of the LVMH Group, with some of these entities acting as data processors;
· subcontractors, such as:
o site hosting and maintenance service providers and the providers of our electronic personal data collection solutions at counters and in stores;
o payment service providers;
o anti-fraud service providers;
o logistic service providers;
o marketing solution service providers;
o sales prospection and social network communication service providers;
o customer service providers;
o event organisation service providers;
Lastly, MAKE UP FOR EVER may 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. Transferring data abroad
In certain cases, and for data hosting purposes personal data we collected about you may be transferred to affiliates, service providers, business partners located outside Kuwait to which personal data are disclosed in United Arab Emirates and the Kingdom of Saudi Arabia which may not have an adequate level of protection.
We have implemented appropriate safeguards with such data recipients by entering into data transfer agreements based on the European Commission standards clauses with such data recipients. You can ask for a copy of such appropriate safeguards by contacting us as set out in section 9.
VIII. How long do we keep your data?
Client (i.e. you have already purchased a product):
10 years after your first purchase
5 years for business development (ex: newsletter)
- Initial period of 5 years: your status is ‘active’ (current base)
- A second period 5 years: your status becomes ‘inactive’ (intermediate base)
If your status is still ‘inactive’ after the second period, your client profile will be deleted.
The status becomes again ‘active’ in case of interactions with MAKE UP FOR EVER (ex: order, update of your profile etc.).
Prospect (i.e. you have never purchased a product but you are interested in MAKE UP FOR EVER brand)
3 years after the date of the data collection
This period will be renewed each time you interact with MAKE UP FOR EVER (e.g. when participating in an event) or your consent to continue to interact with us after this period.
(i.e. : without a client account)
For the duration of the transaction until the delivery of the order
5 years for intermediate base from the end of the commercial relationship
Person in contact with customer care services
for 30 days or the duration of the processing of the claim in our current record
5 years for intermediate archive
Where cookies are placed on your computer, we shall keep them for no more than 13 months.
When we no longer need to use your personal data, it is removed from our systems and records or anonymized so that you can no longer be identified from it.
IX. 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, restrict the processing, data portability, object and right to provide instructions regarding the storage or deletion of disclosure after your death.
You can exercise these rights directly with MAKE UP FOR EVER including a document proving your identity.
If, at any time, you no longer wish to receive details of our offers, news and events, you can unsubscribe using the hypertext link provided for this purpose in each mail we send you. You can also telephone us on 800 – 6253 landline charges apply from 8 a.m. to 8 p.m.
Information on cookie management
This section is dedicated to our policy for managing cookies on the Website
It has been designed to provide you with information on the origin and use of browsing data processed when you use our website, together with your rights.
What is a cookie?
When you use our website, we may, depending on your choice, place a text file on your terminal (computer, smart phone or tablet) via the web browser.
This text file is a cookie. Throughout the period of validity or registration, it will enable [Name of Company] to identify your terminal during subsequent visits.
Only the entity issuing the cookies is able to read or modify the information they contain.
Below you will find information about the cookies that may be placed on your terminal when you visit the pages of the Website either by MAKE UP FOR EVER or by third parties, together with ways in which you can delete or refuse installation of these cookies.
What is the purpose of the cookies issued on the Website ?
There are several types of cookies, some of which are issued directly by MAKE UP FOR EVER and its service providers, whilst others may be issued by third parties.
I. Cookies issued by MAKE UP FOR EVER and its service providers
Different types of cookies may be placed on your terminal whilst you are browsing on our website:
(i) "Essential" cookies
These cookies are essential for browsing on our website, especially for the functioning of the order process.
Deletion of these cookies may cause problems with browsing on our website and make it impossible for you to place an order.
These cookies are also necessary for tracking the activity of MAKE UP FOR EVER.
They may be installed on your terminal by MAKE UP FOR EVER or by its service providers.
(ii) "Analysis and Customisation" cookies
These cookies are not essential to browsing on our website, but may help you, for example, to search more effectively and optimise your purchasing experience and help us better target your requirements, improve our offer and optimise the functioning of our website.
(iii) "Advertising" cookies
Cookies may also be used for advertising purposes. These cookies ensure that the adverts you see are the most relevant to you.
What is the benefit of seeing special offers and advertising tailored to your browsing preferences?
The aim is to show you the most relevant offers and advertising. As such, cookie technology enables us to display content, in real-time, that is best suited to your fields of interest, as deduced from your browsing history on our website.
The interest you show in content displayed on your terminal when you consult a website often determines the advertising resources of this site, enabling it to provide its services, which are often supplied free of charge to users. You doubtless prefer to see offers and advertising that are relevant to you, rather than content that is of no interest to you at all. Similarly, both MAKE UP FOR EVER and advertisers want their offers and advertising to be shown to Internet users that are likely to be interested in them.
Important information if you share your terminal with other users
If your terminal is used by several people or when a single terminal has more than one type of browser software, we cannot be sure that the services and advertising sent to your terminal will match your use of the terminal, rather than that of another user.
In this case, sharing use of your terminal with others and deciding your browser cookie settings are your free choice and your responsibility.
II. Cookies issued by third-party companies
These cookies are not essential to browsing on our website.
On our website, we may include computer applications from third parties that enable you to share our website content with others, inform others that you have been consulting our website or notify them of your opinion concerning content on our site. This particularly concerns use of the "Share" and "Like" buttons featured on social networks such as Facebook, Twitter, Instagram, Pinterest, etc.
The social network providing these application buttons is likely to identify you via this button, even if you have not used it when browsing our website.
Indeed, this type of application button can enable the social network concerned to track your browsing on our website, simply because your account on the social network in question is enabled on your terminal (a session is open) whilst you are browsing our website.
We have no control over how social networks collect information regarding your browsing on our website and associated with the personal data they hold.
We encourage you to read the privacy policies of the social networks to learn about the purpose, especially advertising, of any browsing information they may collect via these application buttons. These privacy policies should enable you to exercise your choices with respect to these social networks, in particular by changing your account settings.
Visit the websites of the aforementioned social networks for more information about their privacy policies.
III. Managing the cookies placed in your web browser
You can decide whether to allow cookies to be installed on your terminal
The choices offered to you by your browser software (Internet Explorer, Firefox, Google Chrome, etc.).
You can adjust your browser settings as you wish, so that cookies are either (a) accepted and registered on your terminal or (b) refused.
a. Agreeing to Cookies
If your browser software is set to accept the registration of cookies on your terminal, the cookies embedded in the pages and content you have consulted will automatically be registered on your terminal.
b. Refusing Cookies
You can set your browser software so that:
· you systematically refuse the registration of cookies on your terminal.
Important: Any adjustments you may make to the settings in your browser software concerning the acceptance or refusal of cookies may modify your browsing on the Internet and your terms of access to certain services requiring use of these cookies.
For example, by refusing certain essential cookies, you may no longer be able to place orders on our website.
If you choose to refuse the registration of cookies on your terminal or if you delete cookies that are already registered, we decline all responsibility for any consequences relating to the degraded performance of our services resulting from the fact we are unable to register or consult the cookies required for their performance and which you have refused or deleted.
How to exercise your choice, depending on your browser
Settings vary from one type of browser software to another. Details can generally be found in your browser software help menu. We therefore encourage you to look at your settings to find out how you can make choices regarding cookies.