ONE RETAIL

PRIVACY POLICY

One Retail (referred to herein as “We,” “Us” “Our” or “One Retail”) has created this Privacy Policy to provide you with information about how we collect, use, share and protect information we maintain through our One Retail platform (“One Retail”). This notice applies to Customer Advisors (e.g., beauty advisors, sales staff). One Retail is offered by L’Oréal USA, Inc. of 10 Hudson Yards New York, New York 10001.

Your use of the One Retail website (the “Site”) constitutes your acceptance of this Privacy Policy and consent to the practices described. This Privacy Policy is incorporated by reference into the One Retail Terms of Use.

As used in this Privacy Policy, “Personal Information” is defined as any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

INFORMATION COLLECTED

We collect information that you provide to us, information from your engagement with our Site, advertising and media, and information from third parties who have gained your consent to share it. Most of the time personal information we collect is collected directly from you through the One Retail platform or other information you provide to us. We may receive personal information about you from a third party, such as your agency or retailer, to create you a One Retail account. We will also collect information indirectly, such as information about your activity and usage of the One Retail platform (including via web logs, cookies, pixels, web beacons, and other similar technologies).

We may combine information that we collect via one method (e.g., from a website, digital advertising engagement) with another method (e.g., an offline event). We do this to get a more complete view of your preferences, which, in turn, allows us to serve you better.

We have collected or may in the future collect the following categories of personal information about you:

Category of Personal Information Collected

Examples

Summary of Business Purpose for Collection of Personal Information

Identifiers

Account information: your name (including any
nickname or alias you have used), email address, unique personal identifier, online identifier, user name, other contact information.
Site usage information: Internet Protocol address.

Identification and evaluation, provide access to the platform and use its features, communicate with you, security, legal issues/compliance.

Other personal information

Name, address, telephone number, education, employment. Some personal information included in this category overlaps with other categories

Identification and evaluation, provide access to the platform and use its features,communicate with you, security, legal issues/compliance.

Protected classifications

Gender

Identification and evaluation, provide access to the platform and use its features, communicate with you, security, legal issues/compliance

Purchase Information/Transaction History

Products and services obtained while using the One Retail platform

Identification and evaluation, provide access to the platform and use its features, communicate with you, security, legal issues/compliance

Professional or employment- related information; educational information

Retailer/shop name, city, retailer location; educational background; courses taken in e-learning platform

Identification and evaluation, provide access to the platform and use its features, communicate with you, security, legal issues/compliance

Audio/Video data; other user-generated content

Photographs you upload or share; comments shared, questions posed to experts, coach & share features

Provide access to the platform and use its features; provide access to user generated content functionality, security, legal issues/compliance

Internet, computer, or other similar network activity

Device and connection information: information about your computer, phone, table, or other device used to access the Site.
Site usage information: browser type, device type, operating system, application version, pages served to you, the time you browse, preceding page views, and your use of features or applications on the Site.
Social media activities: Facebook and Twitter interactions with the Site.
Other measurement of user-interactions with the service

Information technology administration, work supervision, investigations, communications, performance evaluation, compliance with company policies and procedures, discipline, legal issues/compliance, product improvement, analysis of site usage

Inferences drawn from other personal information

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

Evaluation and advancement, legal issues/compliance

USE AND SHARING OF INFORMATION

We may use the information that we collect about you, including Personal Information that you choose to provide to us, for a variety of purposes such as:

To create and manage your enrollment to One Retail and e-learning sessions;
Tracking your progress in courses you enroll in and complete on the Site;
Responding to your questions and requests to resolve technical issues and to repair and improve the services;
Verifying your identity;
Communicating about your account and activities on the Site;
Manage and offer the One Retail services;
Maintain the security of our products, services, and systems;
Enforce our terms and comply with applicable laws;
For corporate governance, including mergers, acquisitions, and divestitures;
Protect our rights, property, and safety, or the rights, property, and safety of others;
Conducting research and analytics related to the courses and offerings on the Site; and
Any other incidental business purposes related to or in connection with the above.

We may share the information we collect from you with L’Oréal USA and its affiliates. We will not sell your Personal Information to third parties and we will not disclose your Personal Information to third parties outside of the L’Oréal family of brands unless the disclosure is for one or more of the following limited purposes:

Third Parties Providing Services On Our Behalf: We share your information with third party service providers that host, operate or assist with the technical operation of our Site, provide analytics, and/or site usage information. For example, service providers that assist and help us in providing digital services; service providers that assist us in providing IT services, such as platform providers, hosting services, maintenance and support; and service providers that assist us in providing training, seminars, and events.

Categories of information shared include identifiers, other personal information, internet or network activity, purchasing or other commercial activity, protected classifications, professional or employment-related information, audio-visual information, and inferences generated from the foregoing categories of information.

Third Parties to Fulfill a Transaction You Have Requested. We may share information with third parties to fulfill a transaction you have requested. For example, third parties required to deliver a product to you (e.g., postal/delivery services).

Business Transfers: We may share information with other entities and affiliates of the L’Oréal Group, our parent company. As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or our assets, or assets related to the Site, Personal Information, user content, usage information, and any other information that we have collected may be disclosed to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.

Legal Disclosures: We may transfer and disclose information, including your Personal Information, account information, user content, usage information and device identifiers, (including IP address), to third parties to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our Terms of Use or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to our Site or the public.

CHILDREN

The Site is not directed to children under 16. We do not knowingly collect, use or disclose Personal Information from anyone under 16 years of age. If we determine upon collection that a user is under this age, we will not use or maintain his/her Personal Information without the parent/guardian’s consent. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 16, we will make reasonable efforts to delete such information from our records.

RETENTION AND SECURITY OF YOUR INFORMATION

We may retain your Personal Information only for the period needed to fulfill the purpose for which it was collected as described in this Policy. We also retain your Personal Information in order to protect our rights and the rights of others; to resolve disputes; and to enforce our legal terms or policies to the extent permitted under the applicable Laws.

We take the security of your Personal Information very seriously and we maintain a risk-based approach to physical, administrative, and technical security measures to protect the confidentiality, availability, and integrity of your Personal Information. We regularly monitor our systems for possible vulnerabilities and attacks.

The protection of your Personal Information is a shared responsibility. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

By using the Site, or providing us with any information, you (a) acknowledge that the Site is subject to the laws of the United States, (b) consent to the collection, processing, maintenance and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen, and (c) waive any claims that may arise under those laws.

CHANGES AND POLICY UPDATES

Please note, we may change information on the Site and/or this Privacy Policy, at any time without prior notice to you, and any changes will be effective immediately upon the posting of the revised Privacy Policy on the Site. One Retailwill use your Personal Information in a manner consistent with the Privacy Policy in effect at the time you submitted the information, unless you consent to the new or revised policy. We encourage you to periodically review this page for the latest information on our privacy practices.

CONTACT US

If you have any questions or concerns regarding this Privacy Policy, our privacy practices, or you would like to exercise any of your rights as outlined in this Policy, please contact us at [insert] Last Updated: June 2021