biometric processing notice

Last Updated: 22 May 2023

CONTENTS

About this Notice

What is Biometric Data?

How and Why Your Biometric Data Is Used

How Your Biometric Data

How We Protect Your Biometric Data

Retention and Deletion of Your Biometric Data

Your Rights and Choices

Contact Us

ABOUT THIS NOTICE

Charlotte Tilbury Beauty Inc. (“we”, “us,” etc.) respects your privacy and is committed to protecting it. This Notice explains our practices relating to information that qualifies, or potentially may qualify, as “biometric data.” In particular, we make available certain optional features on our website, www.charlottetilbury.com/us, which may rely on biometric data to function properly. These include: the Pro Skin Analysis and Foundation Finder tools (collectively “Virtual Tools”). Prior to interacting with these Virtual Tools, we require you to agree to this Notice. For information about how we handle other types of personal information, please visit the Charlotte Tilbury Privacy Policy. For other terms and conditions that apply to your interactions with us, please visit our Terms and Conditions of Use.

WHAT IS BIOMETRIC DATA?

As used in this Notice, “biometric data” includes both of the following:

• “Biometric identifiers,” meaning data generated by automatic measurements of an individual's biological characteristics, such as a retina or iris scan, fingerprint, voiceprint, or a scan of hand or face geometry; and,

• “Biometric information,” meaning any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier when used to identify an individual. YOUR RIGHTS AND CHOICES Unless otherwise permitted by law, before your biometric data is collected, used, or disclosed in connection with our products or services, we will first:

• Inform you, or your legally authorized representative, that biometric data will be processed (such as by linking to this Notice), and

• Obtain informed written consent from you, or your legally authorized representative, for the processing of your biometric data as set forth in this Notice.

By agreeing to this Notice, you are providing your consent to the processing of biometric data as described in the Notice.

You are not required to provide us with consent to the processing of your biometric data; however, you may not be able to access or use all of our products and services if you decline to provide it. If you have previously consented to the use of your biometric data, you may revoke your consent at any time by contacting us at legal@charlottetilbury.com.

HOW YOUR BIOMETRIC DATA IS USED

If you choose to use our Virtual Tools, your image will be used to provide the functionality of the Virtual Tools. In some cases, you may choose to either allow access to your camera or upload a photo in order for the Virtual Tool to complete a “face scan,” which occurs entirely on your own device and browser. The output of the analysis is used to visually display the results of the Virtual Tool and related services to you. Some Virtual Tools may include the processing of your biometric data outside of your browser or device, such as where we partner with a third party that collects your biometric data for purposes of providing you with or facilitating the Virtual Tool you are interacting with.

Depending on the Virtual Tool you are interacting with, you may choose to save the results of your Virtual Tool session. If you do, some information about your session, such as one or more images from your session and associated product recommendations, may be saved to your account with us and used to send you additional recommendations and accompanying promotional messages. You may delete these images at any time through your Charlotte Tilbury account.

HOW YOUR BIOMETRIC DATA IS DISCLOSED

We do not share or facilitate the sharing of your biometric data with third parties unless you have consented to the disclosure, or where the disclosure is otherwise permitted or required by law. We never sell, lease, trade, or otherwise profit from your biometric data.

Depending on the specific Virtual Tool, some biometric data may be shared with or directly collected by third parties (such as our service providers) for purposes of providing you with or facilitating the specific product or service that you are interacting with. To the extent that we collect and subsequently disclose any biometric information to third party service providers in order to facilitate our Virtual Tools, we restrict how such partners may use and share your biometric data.

HOW WE PROTECT YOUR BIOMETRIC DATA

Where we collect or otherwise possess your biometric data, we use a reasonable standard of care to store it, transmit it, and protect it from disclosure. Our practices for protecting your biometric data are, at a minimum, just as robust as those we use to store, transmit, and protect other confidential and sensitive information that we possess.

RETENTION AND DELETION OF YOUR BIOMETRIC DATA

If we are ever in possession of your biometric data, we will only keep it until one of the following occurs, at which point we will permanently destroy it, and direct any third party service providers involved to do the same.

1. We will permanently destroy your biometric data once the initial purpose for collecting your biometric data has been satisfied.

2. We will permanently destroy your biometric data once the initial purpose for collecting your biometric data has been satisfied.

We may deviate from the retention schedule described in this section where reasonably necessary to comply with a valid warrant or a subpoena issued by a court of competent jurisdiction, or if otherwise required to do so by law.

FOR MORE INFORMATION

If you have any questions about your biometric data, please contact us at: legal@charlottetilbury.com