Lancôme Training Privacy Notice

Lancôme Training, offered by L’Oreal USA, Inc. (referred to herein as “we,” “us”, or “our”) has created this Privacy Notice to provide you with information about how we collect, use, share and protect information We maintain through our LancomeTraining.com platform (“Lancôme Training” or the “Site”). This Notice applies to individuals who are currently employed by L’Oréal, individuals who work through a third-party retailer selling Our products or under an agency contract, or other individuals authorized to access Lancôme Training. Individuals currently employed by L’Oréal should review the Employee Privacy Notice for full and complete details information about the collection, use, and/or sharing of personal information in connection with your role as an employee. Beauty Advisors not employed by L’Oréal but who are engaged by a third party (e.g., a retailer or with an employment agency) should review the privacy notice available at https://www.beautyadvisorjobs.com/pages/privacy-policy.html or https://www.fragranceadvisorjobs.com/pages/privacy-policy.html for full and complete information about the collection, use, sharing of personal information about you, along with information about rights available to you under applicable law, in connection with your role as a Beauty or Fragrance Advisor.

Your use of Lancôme Training constitutes your acceptance of this Privacy Notice and consent to the practices described. This Privacy Notice is incorporated by reference into the Lancôme Training Terms of Use. If you are a resident of California, please review the Section titled “State Disclosures; Rights” for additional information specific to the State of California.

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 Lancôme Training; advertising and media, and personal information from third parties who have your permission to share it with us. 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:

SOURCES OF INFORMATION COLLECTED

We obtain the types of data listed above from the following categories of sources:

PERSONAL INFORMATION YOU PROVIDE

When you interact with Lancôme Training, take a training course, collaborate and/or communicate using Lancôme Training, enter a sweepstakes, contest, or giveaway, share a photograph, video, or product reviews, call our Consumer Care Center, sign up to receive offers or email, or interact with us in another way, we collect the information that you provide to us. This information includes Personal Information (information that can be used to identify you as an individual) such as your name, social media handle, email, telephone number, home address, and payment information (such as account or credit card number) and the other information described in the chart above. If you use a chat feature on our Site, we collect the information you share during the interaction.

INFORMATION WE AUTOMATICALLY COLLECT

We collect some data automatically when you use our Site. We may obtain information by automated means such as through cookies, pixels, web server logs, web beacons, and other technologies described below. Information collected via automated means include identifiers (e.g., IP address, device ID, cookie ID, mobile advertising identifier), geolocation, commercial information, and internet or network activity (e.g., browsing and search history, interactions with our websites or applications).

Cookies and Other Technologies: Our Site, applications, email messages, and advertisements may use cookies and other technologies such as pixel tags and web beacons. These technologies are used help us to (1) remember your information so you do not have to re-enter it, (2) track and understand how you use and interact with our Sites, (3) tailor the Sites and our advertising around your preferences, (4) manage and measure the usability of the Sites, (5) understand the effectiveness of our content, (6) otherwise enhance the Sites and our beauty offerings, and (7) protect the security and integrity of our Site.

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 Lancôme Training, e-Training sessions, and access to events;
• Communication about brands and products, and any information related to the products and services provided by Lancôme. For example, when you use the “contact us” feature or when you subscribe to receive external; communications. This includes personalized communications we may send to You;
• Other community management, such as providing chat functionality, communications, social sharing; and providing rewards. This is to increase engagement and offer new ways of communication, to keep the community up to date with brands and products, and providing access to user generated content functionality to allow the community to create and share content (e.g., comments, ratings, questions to experts, coach & share features). We also we collect and use information when you are communicating and collaborating on the Site, such as when you join a meeting or engage in chat conversations. This includes identification data (name, surname), Your posts, chat conversations, comments, and/or files uploaded; email address; phone number; picture; and associated brand’
• Learning management, such as providing access to learning platform and use its features (catalog of courses, rewards, games, quizzes, gift shop). For example, when you access and self-enroll in education e-learning opportunities offered through the Site. We collect and use personal information to create and manage enrollment, and, if applicable, for rewards/games/quizzes. This includes use of identification data (name, surname), store, brand, email address, user name/password, gender, retailer/ship names, addresses, activity on the e-learning platform (training performed, published content) rewards/certifications;
• 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 Lancôme Training 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;
• To protect our rights, property, and safety, or the rights, property, and safety of others;
• 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. Information is disclosed to the following categories of recipients:

Third Parties Providing Services On Our Behalf: We share information with third party service providers fulfilling the above purposes on our behalf, including service providers that host or assist with technical operation of our Site; information technology vendors that provide information technology services; analytics, and research vendors; vendors that assist and help us in providing digital and e-commerce services such as social listening, store locator services, loyalty programs and program administration, identity management, ratings and reviews, sampling and redemption services, CRM, web analytics, and user generated content curation tools; fraud prevention, legal, compliance, and risk management vendors; order processing fulfilment vendors who process orders, transactions and payments, and provide customer service; marketing, advertising, digital, and social media agencies and vendors that help us deliver advertising, marketing and campaigns, to analyze their effectiveness, and manage your contact and questions; social media, or other third parties that participate in or administer our promotions, contests, sweepstakes, surveys or provide marketing or promotional assistance. Additionally, from time-to-time we use third parties that assist Us in providing training, seminars, and events. These third parties may use this information for their internal business purposes, such as process or product improvement, but are not permitted to use personal information for their own independent marketing or other purposes. We may also share non-identifying information, such as aggregate statistics or usage information, with third parties.

Categories of information shared (depending on the specifics of the business transaction) include identifiers, other personal information, internet or network activity, purchasing or other commercial activity, protected classifications, professional or employment-related information, audio-visual information, geolocation information, payment 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). Additionally, some of features of the Site may provide the opportunity to post content in a public forum. For example, providing ratings & reviews, posting user content (e.g., pictures), or other community engagement tools (e.g., chat or communication functionality). If you decide to submit information in these public forums, including through the Site, the information will be publicly available to other users (e.g., activity including Your posts, comments, content, profile, photos uploaded or shared, etc.

Other Third Parties (Ad Networks and Advertising Companies). We share or make available personal information (such as identifiers, Internet or similar network activity, commercial information, inferences) with third party marketing and advertising networks and social media platforms to serve You tailored and personalized advertisements on other websites and services and across other devices. For example, when You provide Us with personal information, We use that information to optimize our advertisements, serve You advertisements, and measure advertisement performance. We do this generally by uploading an identifier You provided Us or We obtained (email, phone number, cookie or device ID, other identifier, etc.) to a platform that is selling advertisements (such as Facebook, YouTube, Instagram, Pinterest, etc.). We can use that same data to serve You with advertising on websites that participate in online auctions of their ad inventory.

Additionally, when You visit Our Sites We use cookies (or other similar technologies) from third parties. Information collected by these companies is used to build a profile of Your interests to show You relevant advertising on other websites or to other devices connected to You (cross-device advertising) by Us or other companies, and includes identifiers, internet or network activity, commercial information, and inferences generated from the foregoing. In connection with advertising or Our Sites, You may be asked to receive information and/or marketing offers from someone else, or to otherwise agree to the sharing of Your information with a third party.

Some pages on Lancôme Learning have features such as plugins, widgets, or other tools provided by third parties. These tools collect identifiers along with internet or similar network activity. If you engage with such plugins, widgets, or other tools, additional information may be shared. For example, if you use Facebook’s “like” feature, Facebook may register the fact that you ‘liked’ a product and may post that information on Facebook. The use of information is not governed by this privacy notice.

These companies use personal information they receive to improve their own products and optimize their own ad targeting systems.

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.

STATE DISCLOSURES; RIGHTS

Individuals who are residents of certain states have additional rights under state laws.

Do Not Track; Online Tracking

Under several states’ laws, website and online service operators are required to disclose how they respond to web browser “do not track” signals. Lancôme Learning does not currently take actions to respond to “Do Not Track” signals as a uniform standard for such response has not yet been established.

These states’ laws requires website and online service operators to disclose whether third parties may collect Personal Information about their users’ online activities over time and across different sites when the users use the operator’s website or service. Third parties that have content or services on our Site such as a social feature, analytics service, or an advertising network partner, may obtain information about your browsing or usage habits.

California – Removal of Content

If you are a minor under 18 and have an Account, you may ask us to remove any user content that you posted on the site by writing to us and providing as much detail as possible (i.e. date and caption) as to the post(s) you want removed. We will begin to process your request within 30 days. Please note that processing your request does not ensure complete or comprehensive removal of user content that you posted.

California Privacy Rights Act (Effective January 2023):

The California Privacy Rights Act (CPRA) provides California residents with specific rights regarding their personal information. This section describes your rights and how you can submit your request to us.

While Our processing of personal information varies based upon our relationship and interactions with You, the table in the “INFORMATION COLLECTED”, section, above, identifies, generally, the categories of personal information We have collected about California residents. The source(s) of personal information is outlined in the “SOURCES OF INFORMATION COLLECTED”, section, above. How We use and disclose personal information is outlined in the “USE AND SHARING OF PERSONAL INFORMATION” , section, above. We do not use or disclose sensitive personal information about You other than as authorized pursuant to California law. Under CPRA, California residents have the following rights (subject to certain limitations).

California residents also have the following rights (subject to certain limitations). Please note, while California provides individuals with the ability to opt-out of any ‘sales’ or ‘sharing’ of personal information for the purpose of cross-contextual behavioral adverting. We do not ‘sell’ (as ‘sell’ is traditionally defined) personal information about Our consumers. We do not make available or provide consumer’s names, phone numbers, addresses, email addresses, or other personal information to third parties in exchange for money. Like many companies, however, We do make available personal information to third parties due to Our use of cookies (or similar technologies) provided by third parties on Our Site (careers.loreal.com). California law considers this as a ‘sale’ or ‘share’ of personal information. You have the right of opt-out of such activities in California.

Frictionless Preference Signals: This Site processes your opt-out preference in a frictionless manner – meaning that all you need to do to “opt out” is change your browser to broadcast a browser-based opt-out signal recognized by California (such as the Global Privacy Control). If you choose this option, you will not receive a notification, pop-up, text, graphic, animation, sound, video, or any interstitial content in response to your opt-out preference signal. This will not change your experience with Our website and We will not charge a fee or require anything in return for your use of the opt-out preference signal. You may also adjust settings via the “Cookies Settings” link on the footer of this Site, including to consent to use of Cookies on this Site and ignoring the opt-out preference setting.

Additionally, California also provides individuals with the ability to limit the use of sensitive personal information to certain enumerated purposes if a company uses the sensitive personal information to infer characteristics about an individual. While we do collect personal information that is considered ‘sensitive’, We do not believe we use this information to infer characteristics about you and/or only use it for certain enumerated purposes outlined in the statute. Accordingly, We do not provide an option to limit the use of sensitive personal information.

Access to Information

You have the right to request that we disclose information about our collection and use of your personal information over the past 12 months, including:

• Categories of personal information we collected
• Categories of sources for the personal information we collected
• Our business purpose for collecting personal information
• The categories of third parties with whom we share that personal information
• The specific personal information we collected about you

Correction

You have the right to request We correct inaccurate personal information We maintain about You. In responding to Your request, We will take into account the nature of the personal information as well as the purposes for the processing of such personal information.

Deletion

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny a deletion request where retaining the information is necessary for us or our service providers. For example, data may need to be kept to:

1. Complete a sales transaction for which we collected the personal information (such as the sale of our beauty products to you)
2. Track consumer complaints or product issues
3. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity
4. Comply with a legal obligation
5. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us

Submitting a Request

Only you or a person that you authorize to act on your behalf, may make a request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of a California resident who wishes to make a request.

We may not be able to respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will ask you for the email information that you used to interact with us or sign up for a loyalty, email, or to make purchases along with other information you submit (such as contact information like name, address, phone number) and the information we have in our systems, to help verify your identity or authority to make the request and confirm that your information is in our system. Information provided to submit a request will only be used for request purposes.

You may designate an agent to submit requests on your behalf. We will need the agent to provide us with your signed permission to act on your behalf. We may also require you to verify your identity with us directly and confirm that you provided the agent permission to submit the request on your behalf.

Employees may submit a request as outlined in Our Employee Privacy Notice. Beauty Advisors not employed by L’Oreal but who are engaged by a third party (e.g., retailer or with an employment agency) may submit a request as outlined in our Beauty Advisor or Fragrance Advisor privacy notice available at https://www.beautyadvisorjobs.com/pages/privacy-policy.html or https://www.fragranceadvisorjobs.com/pages/privacy-policy.html, respectively.

Timing

We will endeavor to respond to a verified consumer request within 45 days. If we require more time, we will inform you of the reason and extension in writing.

We do not charge a fee to process or respond to a verified consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will provide explanation and a cost estimate prior to completing the request.

You may only make a request for access or data portability twice within a 12-month period.

Non-Discrimination

We will not discriminate against you for exercising any of your CPRA rights

Rewards Offers/Programs Calculation – Financial Incentives

We may offer incentives, such as a coupon or discount on purchase in exchange for personal information (e.g. email sign-up). We may also offer a loyalty program that will provide certain perks, such as rewards and exclusive offers, as well as other programs like sweepstakes or contests. We generally do not assign monetary or other value to personal information. If, however, we are required by law to assign such value, we have valued the personal information collected and used as based, in part, on the value of consumer trail of new products and sharing future offers tailored to your interest with competitive value. The value is a practical and good-faith effort often involving the (i) categories of personal information collected (e.g., names, email addresses), (ii) the transferability of such personal information for us, (iii) the discounted price offered, (iv) the volume of consumers enrolled in our programs, and (v) the product or service to which the programs, or price or service differences, applies. The disclosure of the value described herein is not intended to waive, nor should be interpreted as a waiver to, our proprietary or business confidential information, including trade secrets, and does not constitute any representation with regard to generally accepted accounting principles or financial accounting standards.

CHILDREN

The Site is not directed to children under 13. We do not knowingly collect, use or disclose Personal Information from anyone under 13 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 13, 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. Lancôme Training will 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 Last Updated: December 2023