privacy policy - us

LAST UPDATED AND EFFECTIVE AS OF AUGUST 20, 2024.

This Privacy Policy explains how Charlotte Tilbury Beauty Inc. (“Charlotte Tilbury,” “we,” or “us”) collects, uses, and discloses information about you when you access or use www.charlottetilbury.com/us, visit our US stores, call our customer care team or otherwise interact with us in or from the United States. Please note that we may provide different or additional privacy notices in connection with certain activities, programs, and offerings. For more information about our privacy practices in another jurisdiction, please refer to the privacy policy posted on our website for that jurisdiction. For information related to our processing of information that qualifies, or potentially may qualify, as “biometric data,” please visit our Biometric Processing Notice.

If you have any questions about this Privacy Policy or our information practices, please contact us at legal@charlottetilbury.com. legal@charlottetilbury.com.

We will update this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

About Us

This Privacy Policy is provided by Charlotte Tilbury Beauty Inc. We are responsible for the Charlotte Tilbury US website (www.charlottetilbury.com/us) and any orders placed by customers on this website or in our US Charlotte Tilbury stores. When you place an order on our website, you are contracting with Charlotte Tilbury Beauty Inc., but we are part of a wider group of Charlotte Tilbury companies across the globe. This includes companies in the UK, Canada, the Netherlands, Germany, France, Spain, Italy and Hong Kong. When we refer to the “Charlotte Tilbury Group,” we are referring to the wider family of Charlotte Tilbury companies. If you want to know more about the Charlotte Tilbury Group, please get in touch with us using the contact details at the end of this Privacy Policy.

Our retail partners

You can purchase Charlotte Tilbury products and services via our retail partners across the US, including retailers such as Sephora, Bloomingdales and Nordstrom stores (our “Retail Partners”). When you purchase Charlotte Tilbury products or services through a Retail Partner online or in one of their stores, you are contracting directly with that Retail Partner and not with us. Any personal information you provide to the Retail Partner will be managed by the Retail Partner and governed by its privacy policy. If you have questions about how our Retail Partners collect, use, and disclose information, you must contact them directly.

Collection of Personal Information

When you use our website, visit our stores, or otherwise interact with us, we collect information from and about you. Some of this information may be considered “personal information,” meaning it identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to you or your household. We also collect, use, and disclose aggregated or de-identified data that cannot reasonably be used to identify you and is not subject to this Privacy Policy.

Personal Information You Provide to Us

We collect personal information directly from you in a variety of ways. For example, we collect information when you:

Register for an online account;
Request additional information about our products or services or sign up to receive news, information, or special offers from us;
Visit our website
Interact with us on social media;
Purchase any product or service from us;
Interact with one of our Pro Beauty Tech Tools and save information about your session to your account;
Book an appointment with a make-up artist;
Apply to join our Pro Artist Program;
Request information or assistance from us, including correspondence with our customer service team;
Participate in or respond to surveys or requests for opinions, feedback, and preferences or fill out other forms on our website or in our stores;
Engage with us via our Website, telephone or cell phone, via Livechat or via VideoChat;
Engage with us via our marketing communications;
Engage with us via games you play on our website or via emails we send you;
Provide reviews of products or post other content in interactive areas of our website; and
Sign up for and participate in events, contests, sweepstakes, or promotions. The types of personal information we collect directly from you include: your name, email address, phone number, mailing address, date of birth, credit card number or other payment information, password, personal preferences, age, gender, skin tone, hair color, eye color, facial image, video and audio recordings and any other information you choose to provide.

Shade Match Tools

If you choose to use any of the Shade Match Tools made available on our website, your image, which may include your skin tone, face shape, eye shape, brow shape, hair colour, age or skin condition, may be used to enable the feature(s) to work. Your image is stored on your web browser and is not retained by the Charlotte Tilbury Group. Charlotte Tilbury Group may engage its trusted service partners to enable these features. We may need to share your image with these service partners so the features work properly; however, our service partners do not store this information in a manner that identifies individuals.

In connection with the Skin Reader service, you may choose to allow Charlotte Tilbury Group to store your image. Charlotte Tilbury Group will store such image in compliance with this Privacy Policy and you may choose to delete any image at any time by logging into your www.charlottetilbury.com account, visiting https://www.charlottetilbury.com/us/account/skincare-profile, clicking “see full reading history” and deleting the relevant image(s).

Automatically Collected Personal Information

We automatically collect personal information when you access and use our website or transact business with us in our stores, including:

Log and Usage Information: We collect information about the device you use to access our website and your use of our website, including the type of browser you use, operating system, IP address, unique device identifiers, access times, pages viewed, links clicked, items placed in your cart, browsing behavior and the referring URL (the webpage you visited before navigating to our website);
Transactional Information: When you make a purchase or return, we collect information about the transaction, such as product details, purchase price, and date and location of the transaction.
Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use different technologies to collect personal information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our website, services and your experience, see which areas and features of our website are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that may be used in our website or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see Cookies below.

Personal Information We Collect from Third Parties

We may collect personal information about you from other sources. For example, we may collect personal information about you from:

Other customers, such as when a friend purchases a gift card for you and provides your email address so we can deliver the gift card electronically;
Our Retail Partners, trade show organizers, and other organizations we partner with to organize contests and events or otherwise promote our products and services;
Social media or messaging services, such as Facebook, Twitter, and WhatsApp, depending on your account settings with those third-party platforms and services; and
Publicly available sources.

Personal Information We Derive

We may derive personal information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address, or that you are interested in a particular product based on your browsing behavior on our website.

Use of your personal information

We collect and use personal information to provide, maintain and improve our products and services and to:

Facilitate and improve your in-store and online shopping experience
Complete the transactions you request, perform our contractual obligations, and send you related information, including confirmations and receipts;
Create and manage your online account and provide technical support (including to debug and troubleshoot) and send you technical notices, updates, security alerts, and support and administrative messages;
Send promotional messages and newsletters (for information about how to manage promotional communications, please see Marketing Communications below);
Respond to your questions and comments and provide customer support;
Allow you to complete surveys or comment on or review our products or services;
Organize and provide events, sweepstakes, contests, and promotions;
Conduct internal research and development;
Engage with you via LiveChat or VideoChat or via our Website;
Recommend products and provide advertising and marketing targeted toward your interests and interactions with us;
Provide you information about and remind you about the products and services you have looked on our Website;
Analyze traffic and user activities on our website, identify popular areas or features of our website, and optimize and personalize website content;
Protect the rights and property of the Charlotte Tilbury Group and others and comply with our legal obligations, including to detect, investigate, and prevent fraud and other illegal activities and to enforce our agreements; and
Carry out any other purpose described to you at the time the personal information was collected.

Email Marketing

When we send email marketing to you, our email marketing provider, may collect data about the locations from which you access and interact with those emails and the website pages you visit through links embedded in those emails. Iyr email marketing provider shares that information with us, which can help us to tailor our marketing to you, for example, by telling you about an event or promotion available at a location which is near to where you frequently interact with our emails and linked website pages. The current email marketing provider we are using is Emarsys, but we will be changing over to Braze before the end of 2024.

Analytics Tools

We use analytics tools to measure the effectiveness of our marketing, understand how customers interact with us on our website and online, and to build a clearer picture of our customers and their motivations. One of our analytics suppliers, Sprinklr, provides us with data about how you interact with Charlotte Tilbury Beauty online. Depending on your privacy settings on certain third-party websites, Sprinklr may collect information about your social media profile, including your follower count thresholds.

Customer Service

Zendesk, our third-party customer service and experience platform, underpins our customer care systems, including the system you use to contact our customer care representatives. Zendesk technology analyses the content of those communications including identifying what language is used, the reason for the communication, and providing our customer care representatives with customer context to communications to ensure your enquiry is handled in an efficient and appropriate manner by our customer care teams.

Sharing of personal information

We may share personal information about you as follows or otherwise described in this Privacy Policy:

With other companies within the Charlotte Tilbury Group to enable us to run data analysis, develop new products and services, and for other business development purposes. We may also share personal information to allow another Charlotte Tilbury Group company to perform services on our behalf.
With our vendors and service providers, who are trusted third parties we hire or work with, to allow us to provide our products and services to you. These service providers need access to your personal information in order to perform services on our behalf, such as web hosting, payment processing, email distribution, marketing and advertising, product and feature support, customer support, information technology, and analytics services.
With our partners, such as organizations with whom we organize contests or events, our Retail Partners, or trade show organizers, and other third parties to provide information on and market our events, products, and/or other services that may be of interest to you.
With other website visitors when you choose to participate in certain interactive areas of our website, such as by posting a product review.
In connection with a corporate transaction, such as any purchase, sale, lease, merger, or other type of acquisition, disposal, or financing involving the Charlotte Tilbury Group.
With our professional advisors, such as our legal, financial, insurance, and other advisors in connection with the corporate transactions described above or the management of our business and operations.
With law enforcement and individuals involved in legal proceedings, when it’s necessary for us to comply with applicable law or legal process, to respond to legal claims, or to protect the rights, property, or personal safety of the Charlotte Tilbury Group, our users, employees, or the public.
With your consent or at your direction.

The above excludes text messaging originator opt-in data and consent; this information will not be shared (outside the Charlotte Tilbury Group) with any third parties.

Retention of Personal Information

To the extent permitted by applicable law and in accordance with the provisions of this Privacy Policy, we keep personal information for so long as (1) it is needed for the purpose for which we obtained it originally or (2) so long as we have another lawful basis for retaining it beyond the purpose for which it was originally obtained.

Your choices

You have options in relation to the personal information we collect about you, as described below.

Marketing Communications

We love keeping you up-to-date about our latest products, services, offers and events, but if you decide that you don’t want to receive these communications at any point, you can unsubscribe by following the unsubscribe instructions in those communications or by emailing us at customercare@charlottetilbury.com. You may also opt out of receiving our text messages by texting STOP to our SMS number. To unsubscribe to our marketing emails, you can also visit the Account Information page on the Charlotte Tilbury website, click on “Newsletters,” and unsubscribe from that page. If you opt out of marketing emails, please note that we may still send you non-promotional emails, such as those about your account or our ongoing business relationship.

Cookies

For detailed information about the cookies we use and the purposes for which we use them, see our Cookie Policy. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

Advertising and Analytics Services Provided by Others

We may allow others to provide analytics services and serve advertisements on our behalf across the web, including Google Analytics. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of our website and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by Charlotte Tilbury and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our website and other websites, and better understanding your online activity. For more information about interest-based ads, or to opt out of having your web browsing activity used for behavioral advertising purposes, please visit our Cookie Policy and the Cookie Management Tool. We may also work with third parties to serve ads to you as part of a customized campaign on third-party platforms (such as Facebook, Snapchat or Instagram). As part of these ad campaigns, we or third-party platforms may convert information about you, such as your email address and phone number, into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and to serve you advertising that is customized to your interests. Note that the third-party platforms may offer you choices about whether you see these types of customized ads.

Your Privacy Rights

Consumers residing in certain states are afforded additional rights with respect to their personal information under the laws applicable to them. If you are a resident of a state that provides its residents additional rights with respect to their personal information, this section applies to you.

We collect the following categories of personal information: identifiers, telephone numbers, characteristics of protected classifications under state or federal law, commercial information, biometric information, internet and electronic network activity, audio and visual information, inferences drawn about you, and other categories of personal information that relates to or are reasonably capable of being associated with you. For details about the precise data points we collect and the sources of collection, please see sections titled “Collection of Personal Information” and “Personal Information We Collect from Third Parties” above. We collect personal information for the business and commercial purposes described in the “Use of Your Personal Information” section above.

In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:

Category of Personal Information	Categories of Recipients
Identifiers	Internet service providers, data analytics providers, operating systems and platforms, social networks, customer service partners, fraud prevention partners, marketing partners, advertising partners, retail partners, payment processors, cloud service providers, other users (if you choose to share certain information, such as product reviews, publicly on our website), other companies within the Charlotte Tilbury Group, and our professional and legal advisors
Telephone Numbers	Advertising networks, social networks, and marketing partners.
Characteristics of protected classifications under California or U.S. law	Other companies within the Charlotte Tilbury Group, operating systems and platforms
Commercial information	Internet service providers, data analytics providers, government entities, operating systems and platforms, customer service partners, fraud prevention partners, marketing partners, payment processors, cloud service providers, other users (if you choose to share certain information, such as product reviews, publicly on our website), other companies within the Charlotte Tilbury Group, and our professional and legal advisors
Internet and electronic network activity	Internet service providers, data analytics providers, operating systems and platforms, fraud prevention partners, marketing partners, advertising partners, cloud service providers, other companies within the Charlotte Tilbury Group, and our professional and legal advisors
Audio and visual information	operating systems and platforms, social networks, customer service partners, fraud prevention partners, marketing partners, other users (if you choose to share certain information, such as product reviews, publicly on our website), other companies within the Charlotte Tilbury Group, and our professional and legal advisors
Inferences drawn about you	Data analytics providers, operating systems and platforms, social networks, customer service partners, marketing partners, advertising partners, other companies within the Charlotte Tilbury Group, and our professional and legal advisors

Certain state laws require that we provide transparency about personal information we “sell,” which broadly means scenarios in which we have shared personal information with third parties in exchange for valuable consideration. Additionally, certain state laws require that we are transparent about the information we “share” for cross-context behavioral advertising, targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects. We “sell” or “share” personal information for the commercial purposes of advertising and marketing our products to you across other websites and via social networks and platforms. In the preceding 12 months, we have “sold” or “shared” the following categories of personal information to the following categories of third parties:

Category of Personal Information	Categories of Recipients
Identifiers	Advertising networks, social networks, and marketing partners.
Telephone Numbers	Advertising networks, social networks, and marketing partners.
Internet or other electronic network activity information	Advertising networks, social networks, and marketing partners.
Inferences drawn about you	Advertising networks, social networks, and marketing partners.

You state of residence may provide you the right to opt out of “sale” or “sharing” of your personal information at any time by visiting our “Do Not Sell or Share My Personal Information” webpage or calling us at +1-855-528-8495. We do not knowingly sell or share personal information about individuals under the age of 16.

In addition to the right to opt out of the “sale” or “sharing” of your personal information explained above subject to certain limitations, your state of residence may provide you the right to (1) request to know more details about the categories and specific pieces of personal information we collect, use, disclose, sell or share (2) request deletion of your personal information, subject to certain exceptions, (3) request that we provide a copy of the personal information we have collected about you, in a portable and, to the extent technically feasible, readily usable format, (4) correct personal information we have about you, (5) not be discriminated against for exercising their rights, and (6) opt-out of the sale of your personal information for valuable consideration or sharing of your personal information for purposes of cross-context behavioral advertising, targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects.

If you are a resident of a state that provides you one or more of these rights (or other rights related to your personal information), you may make a request to exercise such right(s) by calling +1-855-528-8495 or visiting this page. Once we receive your request, we may verify it by asking you to verify your contact information and may ask you for information related to your recent interactions with us, such as information about a recent purchase.

Your state of residence may allow you to appoint an authorized agent to exercise these rights on your behalf. Authorized agents may submit requests on behalf of consumers by contacting us at legal@charlottetilbury.com. If you use an authorized agent registered with the California Secretary of State to exercise your rights, we may ask you to verify your identity with us directly or confirm with us that the agent otherwise has your permission to submit the request on your behalf.

Your state of residence may also require that we not discriminate against you by treating you different for exercising your rights in connection with your personal information, in such case, we will not discriminate against you if you choose to exercise your rights.

If you are a resident of Colorado, Connecticut, or Virginia, and you make a request to exercise any of the above data access rights and we are unable to comply with your request, you may request to appeal our decision. To appeal any data privacy request decision, please contact us contact us at legal@charlottetilbury.com . Indicate in the subject line “Data Access Request Appeal.” You may also contact your Attorney General to file a complaint if you are not satisfied with our handling of your request. Below is the contact information for the appropriate entity for appeal inquiries:

Colorado Residents: Office of the Attorney General, Colorado Department of Law, Ralph L. Carr Judicial Building, 1300 Broadway, 10th Floor Denver, CO 80203

Phone: (720) 508-6000

https://coag.gov

Connecticut Residents: Office of the Attorney General, 165 Capitol Ave, Hartford, CT 06106

Phone: (860) 808-5318

https://portal.ct.gov/AG

Virginia Residents: Office of the Attorney General, 202 North 9th Street, Richmond, Virginia 23219

Phone: (804) 786-2071

https://www.oag.state.va.us/

Utah Residents: Office of the Attorney General, Utah State Capitol Complex, 350 North State Street Suite 230, SLC UT 84114-2320

Phone: (801) 366-0260

https://attorneygeneral.utah.gov/

CALIFORNIA NOTICE OF FINANCIAL INCENTIVE

We make available various offers and financial incentives to our customers. For example, we provide discounts, special offers and other benefits to individuals who participate in our loyalty programs and we may offer you a discount if you sign up to receive our email newsletters. When you participate in the financial incentives we offer, we collect personal information from you, such as identifiers like your name and email address and commercial information like your purchasing habits. In some cases, additional terms may govern a financial incentive, which we will specify when you sign up. You can opt into the financial incentive or price or service difference by following the instructions provided at sign-up, including submitting the relevant personal information. If you do not wish to opt-in to the financial incentive or price or service difference, do not sign up or submit the requested personal information.

If you subsequently wish to withdraw from the financial incentive or price or service difference, the method for doing so will be explained at the time the personal information is to be submitted, or you may request such withdrawal by contacting us at customercare@charlottetilbury.com.

Each financial incentive or price or service difference offered is valued based upon our reasonable determination of the estimated value of such personal information submitted, which takes into consideration, without limitation, estimates in respect of the anticipated revenue generated from such information, the anticipated expenses that may be incurred in the collection, storage, and use of such information in the operation of our business, and other relevant factors related to the estimated value of such information to our business, as permitted under the California Privacy Rights Act (“CPRA”). The value of your personal information is reasonably related to the value of the discount or benefit presented to you.

Lookalike Audiences

For advertising purposes, we occasionally use information about our customers to generate a "lookalike audience" or similar audience of prospective customers through the Facebook, Google, Snapchat, Pinterest or TikTok advertising platforms. This allows us to target advertisements on their networks to potential customers who appear to have shared interests or similar demographics to our existing customers, based on the platforms' own data. We typically do this by uploading a list of email addresses. These third parties’ policies are to irreversibly hash (encrypt) such lists prior to uploading, match the hashed data against their own customers, generate the lookalike audience, then delete the uploaded list and use it for no other purpose. To opt out of our use of your personal information in this manner, please see the Your Privacy Rights section above. We do not have access to the identity of anybody in the lookalike audience, unless they choose to click on the ads. If you wish to opt out of "similar audiences" in Google, you can do so through your Ads Settings. Many of the companies that display interest-based advertising are members of the Network Advertising Initiative ("NAI") and/or Digital Advertising Alliance ("DAA"). To learn more about interest-based advertising and how you may be able to opt-out of interest-based advertising, tracking, and/or sharing of tracking data by their members, visit their online resources at www.networkadvertising.org/choices and www.aboutads.info/choices, respectively.

Other resources (not affiliated with NAI or DAA) include http://preferences-mgr.truste.com/, or for EU residents, www.youronlinechoices.eu.

Session Replay

We utilize session replay services to help us identify any challenges you may encounter while using our website and to help us enhance your use of the website. The session replay utilizes cookies to capture this personal information about your use of the website. For more information about session replay, please visit our Cookie Policy and the Cookie Management Tool.

Marketing Service Providers

Your personal information, which includes but is not limited to demographic information, transaction history, and online behaviour, may be shared with selected marketing service providers for the purposes of the following and is typically known as data profiling:

helping us better understand the likely characteristics of our customers;
creating predictive models that can offer suggestions and recommendations to you and other users about products or services that may interest you or them;
improving the relevancy and appropriateness of our marketing to customers (e.g. offers, its products and services); and
helping us to communicate with our customers more effectively offline and online. This may mean that you receive tailored advertising via direct mail or when you visit a website.

To ensure the security and protection of your data, all information shared with any marketing service providers will be transformed into a non-readable format. This means that your identifiable information will be removed and replaced with pseudonymous identifiers or encrypted tokens. The marketing service providers may have the capability to match the data we share with them with data from their or other third party sources. For example, combining the non-readable data received from us with data collected from various reputable sources to gain more comprehensive insights into consumer behaviour and preferences.

Contact Us

If you have questions regarding this Privacy Policy, you can contact us at legal@charlottetilbury.com.

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