Customer Service

Effective Date: 12^th October 2022

Estee Lauder (Vietnam) LLC (“we”, “us”, or “our”), operator of Jo Malone London, respect your concerns about privacy and value the relationship we have with you. As used in this Privacy Policy, personal data means any information relating to an identified or identifiable individual, and is intended to include all data which enables the identification of an individual, whether directly or indirectly (“Personal Data”). This Privacy Policy describes the types of Personal Data we collect, use, disclose, and/or transfer cross-border (“process” or “processed”) about our customers, how we may process the Personal Data, with whom we share it, and the choices available to our customers regarding our use of the information. We also describe the measures we take to protect the security of the information and how our customers can contact us about our privacy practices.

Click on one of the links below to jump to the listed section:

• PERSONAL DATA WE COLLECT
• PERSONAL DATA YOU PROVIDE
• HOW WE USE PERSONAL DATA
• PERSONAL DATA WE COLLECT BY AUTOMATED MEANS
  
  • TECHNOLOGIES WE USE
    • COOKIES, WEB SERVER LOGS AND WEB BEACONS
    • THIRD PARTY WEB ANALYTICS SERVICES
  • TARGETED ADVERTISING
• HOW WE USE PERSONAL DATA COLLECTED BY AUTOMATED MEANS
• PUSH NOTIFICATIONS AND IN-APP ALERTS AND UPDATES
• PERSONAL DATA WE SHARE
• YOUR RIGHTS AND CHOICES
• DATA TRANSFERS
• HOW WE PROTECT PERSONAL DATA
• LINKS TO OTHER WEBSITES
• UPDATES TO OUR PRIVACY POLICY
• HOW TO CONTACT US
• DISCREPANCIES

PERSONAL DATA WE COLLECT

We may obtain Personal Data about you from various sources. We may collect this Personal Data when you provide it on or via our website, via or when you access and/or use our social media/ social networking pages (or their relevant platforms or corresponding mobile applications, e.g. Facebook, Instagram), when you download (via Apple iOS, Android or other operating systems) one of our mobile applications onto (and/or use such applications in) your mobile device, when you visit one of our stores or attend events, when you join any of our loyalty program or apply for any membership program of ours. Our products are available for sale in many department stores. Unless otherwise indicated at the time that you provide your Personal Data, any Personal Data collected in these department stores is not provided to us. This Privacy Policy does not address any data collection by our retail partners. When you visit this site, our social media/ social networking pages (or their relevant platforms or corresponding mobile applications), or when you use the services or features of one of our mobile applications or via our website, we may also collect certain information about your device or usage by automated means or by using technologies such as cookies, web server logs and web beacons).

PERSONAL DATA YOU PROVIDE

You may choose to provide Personal Data to us in a number of ways, such as when you participate in an offer or promotion, or when you make a purchase, at any of our counters in department stores, our stores or on our site, via our social media/social networking pages (or their relevant platforms or corresponding mobile applications) or through one of our mobile applications. The types of Personal Data you may provide to us, if applicable, include:

• Contact information (such as name, postal address, email address, and mobile phone or other phone numbers, mobile service provider);
• Age and date of birth;
• Ethnicity, gender, preferred language;
• Username and password;
• Payment information (such as your payment card number, expiry date, delivery address, and billing address);
• Purchase history;
• Product preferences and communication channel preferences;
• Your physical characteristics and skincare concerns and/or skincare regimes, skin type, skin conditions (sensitivities or allergies) and medications for the same that may be deemed sensitive Personal Data under applicable laws;
• Contact information for friend(s) or other people you would like us to contact (under the circumstance that you have obtained the required consent of such individuals for such use by us);
• Content you provide (such as photographs, videos, reviews, articles, survey responses and comments);
• Information provided to us when you visit our social media pages or use one of our social networking or mobile applications (such as your name, profile picture, likes, location, friend list and other information described on the social media network or application sign-up page, or your geo-location details when using one of our mobile applications);
• Your membership program or loyalty program account identification number;
• Further Personal Data of you that may be obtained from the matching the Personal Data you provided hereunder to us with those held by second or third parties across channels / brands / countries.

You may be aware that some types of Personal Data listed above, such as your payment card information, your physical characteristics and skincare concerns and/or skincare regimes, skin type, skin conditions (sensitivities or allergies) and medications for the same, your geo-location details when using one of our mobile applications, etc. may be deemed sensitive under local laws.
It is voluntary for you to provide your Personal Data to us, but all or certain of our services and promotions as outlined herein may not be available to you if you do not provide your Personal Data as specified above.

HOW WE USE PERSONAL DATA

We and/or our affiliates may use your Personal Data to the extent permitted or required under applicable laws, for the following purposes, including but not limited to:

• Send you promotional materials or other communications;
• Provide requested information and services to you;
• Contact you to follow up or confirm your orders, appointments (including any virtual/online appointment bookings), returns, or refunds, via emails, SMS communications or other communication channels;
• Send you other non-marketing communications related to products and services we provide to you;
• Process your payment transactions and/or gift card transactions;
• Create and manage your account, including access to your on-line and in-store purchase history;
• Assist with product selection and replenishment, including through our customer registry;
• Administer our membership list and loyalty program list, if any;
• Respond to your inquiries;
• Tailor ads on our website, social media platforms and elsewhere to your interests and history with us;
• Communicate with you about, and administer your participation in, special events, contests, sweepstakes, programs (such as loyalty program, if any), surveys and other offers;
• Operate and communicate with you about our social networking or mobile applications;
• Operate, evaluate and improve our business (including developing new products and services enhancing and improving our products and services; managing our communications; analyzing our products; performing market researches, data analytics and customer relations management programs; and performing accounting, auditing and other internal functions);
• Comply with applicable legal requirements, relevant industry standards and our policies;
• To avoid duplication and ensure accuracy of your Personal Data and/or to provide a more tailored user experience, periodically conduct data cleansing, matching or merging of your data against the data obtained from other channels / brands / countries, either internally or through our service providers.

We also may use the information in other ways for which we provide specific notice at the time of collection.

If you provide us with your Personal Data, we intend to use it for direct marketing purpose to offer or advertise the availability of our goods and/or services. However, we may not use your Personal Data for such purpose unless we have received your consent to our intended use.

All types of Personal Data listed in the section “Personal Data You Provide” above may be used by us in direct marketing if you provide such Personal Data to us and you expressly consent to such use in writing or in electronic form. We may not use your Personal Data for direct marketing purposes unless we legally obtain your consent in compliance with applicable laws. In that event, we may market the following classes of goods and services directly to you using your Personal Data:

• Beauty and skincare products;
• Hair care and hair styling products;
• Hair dye;
• Makeup;
• Perfumes, scents, aromas, deodorants, home fragrance and candles;
• Shampoo, conditioners and cleansers;
• Tea and teabags;
• Special events, contests, sweepstakes, programs and surveys; and
• Any other products or services offered by us.

Direct marketing communications may be sent to you through various channels, for example by telephone, post, email, SMS, through mobile apps, online apps, social media platforms and other online means.

We, Estee Lauder (Vietnam) LLC, being the operating company of Jo Malone London Vietnam, are an affiliate of the Estee Lauder Companies (“ELC”) – a global leader which is dedicated exclusively to prestige beauty and the owner of a number of worldly renowned brands in the arena of cosmetics, beauty, fragrance industry, such as Estee Lauder, Bobbi Brown, Clinique, Jo Malone London, La Mer, M.A.C, Origins, etc. Please visit https://www.elcompanies.com/en/our-brands for further details on ELC and brands. To share with you more of our multi-brands’ beauty tips and information through our connection with you, when you sign up for an account or program with us (e.g. membership account, loyalty program etc.), or when you receive services from us, in addition to any interaction that you may have with the brand that you originally have contact with, you may be invited to subscribe to marketing materials of our multiple adjacent brands offered by our group of companies as a whole. Upon your consent, the Personal Data you provided in the form, or the Personal Data you provided at the time when you consented to the said subscription, would simultaneously be used by us for marketing purpose. The handling of any data transfer issues concerned under this paragraph would remain consistent with what is provided in this Privacy Policy.

Unless stated otherwise under applicable laws, if you are below the age of majority, it is required that the consent must be obtained from both you and your parent/legal guardian. We have no intention to collect Personal Data of minors. If you do not wish us to use your Personal Data in direct marketing, you may opt out of our direct marketing at any time by following the procedures set out in the section “Your Rights and Choices” below. We must, without charge to you, cease to use your Personal Data in direct marketing if you so require.

We will use the Personal Data supplied by you for direct marketing only in accordance with the Constitution 2013, Civil Code 2015, Advertising Law 2012 and other local applicable laws. Our direct marketing materials may come in several forms, including but not limited to marketing mails, emails and text messages, the details of which are set out in the following sub-sections.

PERSONAL DATA WE COLLECT BY AUTOMATED MEANS

When you visit this site or click on our online advertisements (including our advertisements on third party websites), visit our social media/ social networking pages (or their relevant platforms or corresponding mobile applications), or download and/or use one of our mobile applications, we also collect certain information about your usage or device by automated means or by using technologies such as cookies, web server logs and web beacons. For example, if you use one of our mobile applications, we may collect your IP address, your unique device identifier (or other device identifier) and/or geo-location data in order to offer you certain features or functionalities within that mobile application. As set forth in more detail below, we may also collect information about your usage and browsing habits using various web-based technologies.

For your convenience, our mobile applications may also include functionality that allows you to remain logged in to the application so that you do not have to reenter a password each time you want to access the application. IF YOU CHOOSE TO REMAIN LOGGED IN, YOU SHOULD BE AWARE THAT ANYONE WITH ACCESS TO YOUR MOBILE DEVICE WILL BE ABLE TO ACCESS AND MAKE CHANGES TO YOUR MOBILE ACCOUNT AND MAY BE ABLE TO MAKE PURCHASES THROUGH YOUR ACCOUNT. For that reason, if you choose to remain logged in to the application on your mobile device, we strongly recommend you enable the Passcode Lock security feature on your mobile device to protect against unauthorized access to and use of your mobile device and your account in the application.

Technologies We Use

• Cookies: “Cookies” are small bits of information or small text files that websites send to your browser which may then be stored on the hard drive of your computer as a tag that identifies your computer. Cookies remember information about your activities on the site to make your visits to our website more enjoyable and valuable to you by providing a customized experience and recognizing your preferences when you visit our website. Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. If you have chosen to disable cookies on your browser, some of the functionality of our website may be lost. To edit your cookie settings, click here: Cookie Settings.
• Flash cookies: “Flash cookies” (also called Local Shared Objects or “LSOs”) are data files similar to cookies, except that they can store more complex data. Flash cookies are used to remember settings, preferences, and usage, particularly for video, interactive gaming, and other similar services.
• Web Server Logs: Web server logs are records of activity created by the computer that delivers the webpages you request to your browser. For example, a web server log may record the search term you entered or the link you clicked to bring you the webpage. The web server logs also may record information about your browser, such as your IP address of the device you use to connect to the Internet, operating system type, browser type, domain, the cookies set on your browser by the server, the language your system uses and country and time zone in which your device is located.
• Web beacons, clear pixels, or pixel tags: To control which web servers collect this information, we may place tags on our web pages called “web beacons”. “Web beacons” are computer instructions that link web pages to particular web servers and their cookies. They are small graphic images on a Web page or in an e-mail that can be used for such things as recording the pages and advertisements clicked on by users, or tracking the performance of e-mail marketing campaigns.
• Geo-location technologies: Geo-location technology refers to technologies that permit us to determine your location. We may ask you to manually provide location information on our website, or to enable your mobile device to send us precise location information. We may also automatically collect general location information from your web browser.

We may use third party web analytics services on this site, our social media/ social networking pages (or their relevant platforms or corresponding mobile applications), or our mobile applications, such as those of Adobe Site Catalyst and/or Google Analytics. The service providers that administer these services use technologies such as cookies, web server logs and web beacons to help us analyze how visitors use the site. The information collected through these means (including IP address) is disclosed to these service providers, who use the information to evaluate use of the website. You may deactivate the ability of these analytics services to analyze your browsing activities on this site. To learn more about web analytics services, and exercise your choice with respect to their collection of information on this site:

• For Adobe Site Catalyst, please click here: http://www.adobe.com/privacy/opt-out.html.
• To disable Google Analytics, please download the browser add-on for the deactivation of Google Analytics provided by Google at http://tools.google.com/dlpage/gaoptout?hl=en. To learn more about privacy and Google Analytics please consult the Google Analytics overview provided by Google at: http://www.google.com/intl/en/analytics/privacyoverview.html.
• We have implemented certain Google Analytics Advertising Features (Google Analytics Demographics and Interest Reporting). You can opt out of the Google Analytics Advertising Features through Google Ad settings or by visiting https://tools.google.com/dlpage/gaoptout/. We will use the data provided by Google Analytics Demographics and Interest Reporting as described under “How We Use Personal Data”.
• To disable other third-party web analytics service provider cookies, some browsers indicate when a cookie is being sent and allow you to decline cookies on a case-by-case basis. You may also turn off cookies in your browser.

We also may contract with third-party advertising networks that collect IP addresses and other information through the use of cookies, web server logs and web beacons on our websites and emails; on third-party websites and emails; and on our advertising placed on third-party websites. They use this information to provide advertisements about products and services tailored to your interests (including for companies not affiliated with us). You may see these advertisements on other websites. This process also helps us manage and track the effectiveness of our marketing efforts. To learn more about advertising networks and to opt out of interest-based advertising, visit the Digital Advertising Alliance at http://www.aboutads.info/choices or the Network Advertising Initiative at http://www.networkadvertising.org/choices.

We may also use third-party platforms, including platforms operated by social networks, such as Google, Facebook, Pinterest, WeChat, LINE, Kakao, etc., to show interest-based ads. We may convert your email address, telephone number or other information into a unique value which can be matched by those third parties with a user on their platform or with other data they may have collected from you. This matching allows interest-based ads to be delivered on those platforms. To opt out of these ads, you must change your advertising preferences on those third-party platforms. These platforms may have their own privacy notices or policies, which we strongly suggest you review.

HOW WE USE THE INFORMATION COLLECTED BY AUTOMATED MEANS

We may use the information collected through automated means on this site, for market research, data analytics and system administration purposes, such as to determine whether you have visited us before or are new to the site, to tailor ads displayed to you on our site and elsewhere to your interests and history with us, and for compliance with our legal obligations, policies and procedures, including compliance with relevant industry standards and the enforcement of our TERMS AND CONDITIONS or other relevant terms. We also may use the information in other ways for which specific notice is provided at the time of collection.

PUSH NOTIFICATIONS AND IN-APP ALERTS AND UPDATES

When you download one of our mobile applications, we may provide you with the option to opt in to receive push notifications from us on your mobile device in connection with that mobile application. These push notifications may include promotional communications regarding our products and services. You may, after downloading the applicable mobile application, opt out of receiving push notifications by adjusting the settings on your mobile device. Opting out of push notifications will not affect other communications you receive from us, such as email communications. You also may receive alerts and updates within our mobile applications regarding our products and services or your accounts with us. To opt out of receiving these alerts and updates, you may uninstall the applicable mobile application from your mobile device.

PERSONAL DATA WE SHARE

We do not rent, or sell, or otherwise (except as described here) disclose Personal Data we collect about you, so as to permit those third parties to directly market to you. But as may be required for the performance of the purposes discussed in earlier sections, we may share your Personal Data with:

• our affiliates (including across different brands owned by us and/or our affiliates now or in the future within the Estee Lauder Companies umbrella of companies for the purposes described in this Privacy Policy or as otherwise specified in the notice provided at the time of collection). For a list of our corporate affiliates, please see https://www.elcompanies.com/en/news-and-media/contact-us;
• service providers, licensees and/or joint venture partners who may be located overseas (including but not limited to Singapore, South Korea, and the United Kingdom), and they may perform services on our behalf based on our instructions and send you direct marketing in relation to the goods and services. We do not authorize these service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. Examples of these service providers include entities that process credit card payments, fulfill orders, and provide web hosting, advertising and marketing services;
• other third parties through social networks, widgets and plug-ins. If you use any features made available to you on our website by a third party, it may result in information being collected or shared between us and the third party. For example, if you use Facebook’s “Like” feature, Facebook may register the fact that you “liked” us and may post that information on Facebook. Also, some of our Facebook applications may share your information collected through those apps with your Facebook friends or other Facebook users.

Where we need to share your Personal Data to third parties for the performance of purposes discussed above on our behalf, we would request such parties to adopt a privacy practice with Personal Data handling at an equivalent or even stricter level. Some types of Personal Data listed above may be deemed sensitive, and local laws may impose restriction on disclosure of sensitive Personal Data. We may not be able to offer certain services or benefits to you if you do not consent to the sharing of your data.

In addition, we may disclose and/or transfer cross-border your Personal Data (i) if we are required to do so by law or legal process, such as for the national security, social orders, social morality, public health (ii) to law enforcement authorities or other government officials, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or (iv) in connection with an investigation of suspected or actual fraudulent or illegal activity.

We also reserve the right to transfer Personal Data we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use Personal Data you have provided to us in a manner that is consistent with our Privacy Policy. Following such a sale or transfer, you may contact the entity to which we transferred your Personal Data with any inquiries concerning the processing of that information.

YOUR RIGHTS AND CHOICES

We offer you certain choices in connection with the Personal Data we collect from you, such as how we use the information and how we communicate with you. To update your preferences, ask us to remove your information from our mailing lists or submit a request, please contact us as specified below.

Email Opt-Out

You can at any time tell us not to send you marketing communications by email by clicking on the unsubscribe link within the marketing emails you receive from us or by contacting us as indicated in the “How to Contact Us” section below. You also may opt out of receiving marketing emails from Jo Malone London Vietnam by contactus.vn@jomalone.com

Postal Mail Opt-Out

You can request Jo Malone London Vietnam to stop sending you marketing communications by postal mail by following the instructions that may be included in our promotional mail. You can also request that we refrain from sending you promotional mails by contacting us as indicated below.

Text Message Opt-Out

You can request that we refrain from sending you text messages by contacting us as indicated below, or calling the phone number or sending an unsubscribing text message included at the end of our text messages sent to you.

Social Networking Application Opt-Out

To remove or delete our social media applications from your social networking account, follow the instructions from the social network.
For Facebook: please see instructions provided by the Facebook Help Center.

Geo-Location Information

When you use one of our mobile applications, you may be asked for your geo-location via such mobile application. You may choose not to share your geo-location details by adjusting your mobile device’s location services settings. To decline sharing your geo-location details, follow the instructions on your mobile device on changing the relevant settings; otherwise, please contact your service provider or device manufacturer.

Withdrawing Consent

Unless there is any restriction for consent withdrawal under applicable laws, you may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your Personal Data. We will apply your preferences going forward. In some circumstances, withdrawing your consent to our use or disclosure of your Personal Data will mean that you cannot take advantage of some of our products or services.

Reviewing, Updating and Modifying Personal Data

We may retain and use your Personal Data for as long as necessary to fulfill the purposes set out above. Subject to applicable law, you may have the right to request access to and/or receive details about the Personal Data we maintain about you, obtain a copy of or request to transfer, update and correct inaccuracies in your Personal Data, and have your Personal Data blocked, deleted, destructed or anonymized, or to restrict and/or object to certain activities in which we engage with respect to your Personal Data, as appropriate. The right to access Personal Data may be limited in some circumstances by local law requirements. We may take reasonable steps to verify your identity before granting access or making corrections. You may request to exercise such rights, please contact us by sending an email to contactus.vn@jomalone.com with attention to our data protection officer. To the extent such rights are available to you under applicable laws and your request complies with the statutory requirements, we will give effect to your rights as required by law. You also have the right to lodge a complaint with a competent data protection authority under applicable laws.

DATA TRANSFERS

We may transfer the Personal Data we collect about you to markets / countries other than the market / country in which the information was originally collected and your Personal Data may be processed and stored outside your market / country of residence. You understand and agree that the destination market / country may or may not have a sufficient data protection standard. These markets / countries may not have the same data protection laws as the market / country in which you initially provided the information. When we transfer your information to other markets / countries, we will protect that your Personal Data as described in this Privacy Policy.

HOW WE PROTECT PERSONAL DATA

We maintain appropriate administrative, technical and physical safeguards designed to protect the Personal Data you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure, transfer or use. However, no security system is perfect, and we cannot promise that information about you will remain secure in all circumstances, including the security of your data during transmission to us or the security of data on your mobile device.

LINKS TO OTHER WEBSITES

Our website may provide links to other websites for your convenience and information. These websites may operate independently from us. Linked sites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are not owned or controlled by us, we are not responsible for the sites' content, any use of the sites, or the privacy practices of the sites.

UPDATES TO OUR PRIVACY POLICY

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our Personal Data practices. We will post a prominent notice on our website to notify you of any significant changes to our Privacy Policy and indicate at the top of the Policy when it was most recently updated.

HOW TO CONTACT US

If you have any questions or comments about this Privacy Policy, or if you would like us to update information we have about you or your preferences, please contact us by email at contactus.vn@jomalone.com

DISCREPANCIES

If there is any conflict between the Vietnamese and English versions of this Privacy Policy, the English version shall prevail.