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PRIVACY POLICY

OUB

LAST UPDATE OF OUR PRIVACY POLICY ON 18 OCTOBER 2018

 

L’OFFICINE UNIVERSELLE BULY would like to explain what it does with your personal data in the following lines.

 

You will find here information regarding how you can access your personal data and change your choices about how they are used, like your opposable rights on some of the uses we make of it or, when we ask for your consent, your right to withdraw it. 

 

You will find in the following paragraphs all the information concerning your rights and preferences.

 

INTRODUCTION

The present policy was updated in order to comply with the General Data Protection Regulation (GDPR), enforced on 25 May 2018.

 

All of our data processing activities are covered by this Policy, including personal data collected through all means, online (e.g. our website, mobile apps linked to our Company as well as our social networks) and offline (e.g. our stores, our customer service and during events).

Furthermore, it explains how some of the information is collected through the use of cookies or similar technologies in our whole digital ecosystem.

Depending on the way you interact and communicate with L’OFFICINE UNIVERSELLE BULY, some of the sections may not be applicable to you.

Please note that we combine the personal data we collect in one way (e.g. on our social media) with personal data we collected in another way (e.g. during an event in one of our stores) and through different entities of L’OFFICINE UNIVERSELLE BULY. 

You will find below further information about these activities. 

 

This Policy will be updated with every change we make in the way we collect and process your personal data. 

In the event of a change that would affect significantly our privacy practices, we may notify you through other means (e.g. via email).

You are invited to check our platforms regularly to take note of our updates or modifications of this Policy. In this regard, we reserve the right to amend our practices and this Policy at any time.

 

We may give you additional information when we collect your personal data and whenever we think it is necessary. 

 

1. PERSONAL DATA WE COLLECT

 

We collect personal data from you or about you via several different sources, online and offline, particularly when you: (i) interact with our website or our mobile website/applications (together, ‘the Platforms’); (ii) interact with us on our pages on social media, our direct message services, blogs or forums; (iii) visit one of our stores, boutiques or corners; (iv) participate in our events and demos, loyalty programs or other customer programs, contests, special offers or surveys; or (v) participate in beauty consultations or interact with our beauty counsellors and our customer service.

Our products are sold by several approved retailers. Unless stated otherwise when you provide your personal data, personal data our partner distributors collect won’t be provided to us and the present Policy does not apply to the aforementioned personal data. 

We collect the following personal data: 

The information we receive from you (e.g., by creating an account on our website, by subscribing to our loyalty programs or other customer programs, or by providing information about you in one of our stores, boutiques or corners): 

• Your contact details (such as your name, phone number – land line and mobile – , postal and email address;)
• Your age, date of birth, gender, nationality, selected language, areas of interest and lifestyle; 
• Invoicing information (including delivery address and payment details). We reserve the right to ask for justification or additional proof of validity for the invoicing information whenever we deem it reasonably necessary. Please note that we do not save your credit card details (unless necessary for refund purposes).
• Login details on the website (including username and password). When you create your account, you can securely save your credit card details (kept by our third-party service provider) in order to facilitate and accelerate payment process, save or change your delivery address or invoicing information, and consult your purchase and orders history.
• Personal preferences (such as preferred contact mode and language settings)
• Your interactions with us (such as your orders history or information about your physical characteristics or questions about skin care collected through a beauty consultation, a survey or when you visit our pages on social media, our blogs or forums, or when you interact with our customer service or our messagingservice); and/or
• Correspondence and communication with you.

 

We also organise special offers or events during which you can recommend us someone you know who could be interested in our products and services. If this person gives you his/her consent to give us his/her contact details, we will only use this information to this end and will not send this person any other offer unrelated to it. We may mention you were the sponsor in the message we send him or her. 

We do not intentionally collect information about underage people.

Information collected automatically from your use of our Platforms, our pages on social media or your interactions with our online ads.

• We automatically collect the following information: technical data, such as your IP address, browser type and version, time zone, browser plug-in types and versions, operating system, device identifier and ad ID; and
• Information about your visit on our website, such as your browsing history to and from our Platforms (including date and time), products you viewed or searched, content (and ads) you watch and interact with, page response times, download errors, length of the visit on certain pages, interactions with the page (scrolling, clicks and mouseovers), and methods used to leave the page.

Some of this information is collected using cookies and associated technologies. 

 

Information collected through third parties

We may sometimes (when the governing law allows it) collect through trusted third parties information such as your preferences, areas of interest and other demographic data, available either publicly or commercially (e.g. through business partners or sellers, payment or delivery services, social media, advertising networks, statistics providers, information search services providers). This information will be used for the purposes stated in this Policy. 

We also receive the personal data you provide to the approved distributors of our products and services, and we will use them for the purposes stated in this Policy.

Whenever you pay our products (either in physical stores or online), we collect information from our payment processing service provider (OGONE and PAYPAL), who will verify your solvency and the absence of fraud, as well as the payment method you chose, in order to confirm your identity, validate your credit or debit card, obtain an initial credit or debit approval on your card and/or authorise the purchase. 

In order to keep your personal data accurate and improve your customer experience, we link or associate the information we collect from different sources (described above) in order to provide personalized services andcontent, targeted information and ads (for example, we associate data about your online purchases with information collected at our stores, boutiques and corners such as details from a beauty consultation, aiming to send you personalised offers and recommendations about skin care via the preferred contact method you selected). That includes combining personal data collected through various entities of L’OFFICINEUNIVERSELLE BULY. 

You can choose whether to receive or not marketing content from us. We will only send you such content with your previous express consent. 

 

HOWEVER, WHEN YOU MAKE A PURCHASE IN A STORE OUTSIDE FRANCE, THE OFFICINE UNIVERSELLE WHERE YOU MAKE THAT PURCHASE AND/OR PLACE YOUR ORDER IS THE SOLE CONTROLLER OF THE PROCESSES USED FOR TRANSACTION AND INVOICING MANAGEMENT PURPOSES LINKED TO YOUR PURCHASES.

 

2. WHY DO WE NEED YOUR PERSONAL DATA?

 

We need to process your personal data for the following purposes: 

• In order to execute a contract or take measures linked to a contract: it concerns you when you make apurchase with us: It includes
o setting up and managing your online account on our Platform;
o fulfilling orders and processing your transactions (including payment details processing, credit card verification, and fraud prevention activities); these controls can be required, among other reasons, to verify your identity, validate our credit or debit card, obtain an initial credit or debit authorisation on your card and/or authorise purchases; and
o sending information related to the service and answer your requests.
• Whenever necessary in order to pursue our legitimate interests or those of third parties. These interests are:
o allow you to engage with the interactive functions of the website; 
o ask you for your opinion or ask you to participate in market research;
o provide personalized services and content to you, as well as targeted messages and ads on our Platforms and selected partners’ websites, loyalty programs and other customer programs. We may do that by linking or combining information we collect in different ways (as described above) or by creating segments based on different factors such as your age, gender, or supposed interests. We work with data processing platform providers to help us in this process. Some of these activities can require the use of cookies or other similar devices.
o monitor your account in order to avoid, investigate on and/or report any fraud, act of terrorism, false statement, security incident or crime, in compliance with the governing law;  
o investigate all claims we receive from you or from other parties regarding our Platforms or our products and services and
o monitor the use of our Platforms and use your information to help us monitor, improve and protect our products, content, services and Platforms, online and offline, as well as your experience with us, including via demographic surveys and research; analyse and cleanse data;and assess the performance of our advertising campaigns;
o use personal data related to complaints, our conformity policy, for regulation or investigation purposes whenever it is necessary (including personal data disclosure related to a legal procedure or a dispute), or to enforce our conditions of use or any other agreement; or to protect the rights, property or security of L’OFFICINE UNIVERSELLE BULY, of our customers, or of other parties; 
o for internal company reporting purposes.
o When you give your consent: whenever you ask for more information about our products, services, special offers and events by phone, mail, text, email or online, or via our apps, or to send you samples, gifts or rewards in conformity with your contact preferences and in the limits of the governing law. It includes, among other things, being contacted by one of our group’s entities for these purposes; 
o when you consent to allow cookies and similar devices;
o for other purposes specified to you when we collect your consent.
• In order to comply with a legal obligation
o In compliance with a request from the government or judicial authorities in the course of an investigation.

 

Disclosure of your personal data 

 

• In addition to L’OFFICINE UNIVERSELLE BULY’s entities mentioned in the Data controller and Contact section below, we may share your personal data (when governing laws related to data protection allow it and in compliance with these laws) with: other companies from our group for the purposes described above. 
• approved retailers banks and our payment services provider (OGONE and PAYPAL) for transaction processing purposes; 
• third parties, when we have your consent to do so (e.g. social media, concierge service or our partner retailers.) Your personal data, once shared, will be subject to these third parties’ privacy policies; 
• potential buyers of our business (if we or a substantial part of our assets are bought by or merged with a third party, including in case of bankruptcy;)  
• any law enforcement agency, court, regulating or governmental authority or other third party whenever we deem it reasonably necessary, in order to comply with legal or regulatory obligations or to apply or enforce our Terms of Use or any other agreement; or to protect the rights, property or security of L’OFFICINE UNIVERSELLE BULY, our customers, or another party. It includes information exchange with other companies or organisations for fraud prevention or credit risk reduction purposes; or
• With our third-party service providers (as well as the group’s entities) who perform services on our behalf following our instructions. We do not allow these parties to use the information or disclose it except to the extent necessary to the performance of the services they provide on our behalf, or in order to comply with legal obligations. These parties include, among others, companies who fulfil orders and deal with refunds, provide data hosting and maintenance services, provide personalized content, ad and marketing services (including digital and personalized ads), and data cleansing, processing, segmentation and analysis.

We also share information with third parties, including social media and search engines: 

We aggregate your personal data with other customers’ information, thus creating a data sets about the use of our Platforms, the purchase of our products, and other general information about our customer base. Although this set is assembled and anonymized, which means it doesn’t allow to identify you directly as an individual, it does provide a precious overview of the uses of our Platforms and we share it with third parties selected by us. These third parties include among other companies from our group. 

We also transfer information about you to advertising sales departments and to social media and search engines (including Facebook, Google and Twitter), so that they can identify your devices and provide content and ads based on your areas of interest. This information may include your name, postal and email address, device ID, or other encrypted login details. Providers often process data in segmented or anonymized form. These providers may collect other information from you, such as your IP address, and information about your browser or operating system; combine your information with the ones from other companies in data sharing cooperatives we are part of; and can place and read their own single cookie on your browser. Third parties who create cookies have their own privacy policies and we can’t access nor read those cookies.

 

Data transfer

If you are located in the Russian Federation, personal data you provide through our Platforms may be stored on USA-based servers. 

If you are located in the European Economic Area (EEA) or in Switzerland, the personal data you provide through our Platforms may be stored on servers based or maintained in the USA. We transfer personal data related to you (whether collected online or offline) to companies belonging to our group and to other service providers who perform functions on our behalf and are located all around the world, including in countries outside the EEA and Switzerland. This information may be stored and processed in these countries, which can have differing laws regarding data protection from those applicable in your country of residence. You may obtain a list of the countries where we have businesses on our website www.buly1803.com. For European and Swiss citizens, when your personal data is transferred outside the EEA and Switzerland, and when this transfer is made to a company belonging to the group or a service provider located in a country for which the European Commission has not issued an adequacy assessment, we will take all necessary measures to ensure your information is adequately protected by standard contractual clauses approved by the European Commission or by Switzerland, transferred to an organisation which complies to the EU-US Privacy Shield or protected through binding company regulations. You may obtain, for examination, a copy of the relevant mechanism by sending a request. If the aforementioned mechanisms have not been put in place, then you consent to these data transfers by providing your personal data and by interacting with our Platforms.

 

Data Retention

Your personal data will be kept for a definite period of time based on the following criteria: (i) as long as necessary for the purposes defined in this Policy; (ii) to comply with the applicable law and regulations; (iii) as long as it is necessary to answer any deleting request on your part whenever it applies. Personal data used to offer you personalised information and services will be kept to the maximum extent permitted by applicable law. For more information, please contact us.

 

3. COOKIES AND ASSOCIATED TECHNOLOGIES

 

What are cookies?

We use third-party service providers and authorise them to use cookies, pixels and other similar devices on our Platforms, our social media pages and in our communications. We allow this in order to understand your use of our services, improve your user experience and activate personalized functionalities and content; optimise our ads and our marketing and allow third-party advertising agencies to help us publish ads tailored to your online areas of interest.  

Cookies are small text files that websites send to your computer, mobile phone or any other piece of equipment connected to the Internet in order to identify your browser’s signature or to store information or settings in your browser. 

Our cookies and their functions

The types of cookies we use: 

• Strictly necessary cookies 
• These cookies are essential to operate our website and its functionalities, such as product selection storage in your cart while you continue shopping and/or browse different pages of the website, or access to secure areas of the website. We need to use cookies to operate the website correctly, whether you consent or not to the use of said cookies. 
• Performance/Analytical Cookies
• These cookies gather information about the way you use the website and services, in order to improve the way they work and to develop them according to our customers’ and visitors habits and preferences. For example, cookies and pixels can be used for: test different designs and ensure we keep a coherent visual and experience on all our websites;  
• follow and provide trend analysis about the way you interact with our websites and communications; 
• detect errors and measure our ad campaigns’ performance.

The data collected is generally grouped to provide trends and user models for commercial analysis, improvement and performance assessment of the website/Platform. Our cookies and the resulting analysis of them may also be shared with our business partners. The type of information we collect include number of visitors on our websites, number of customers who log in, the time and duration of their visit and the parts of our websites and services visited, but they are generally not used to identify you personally. We may also receive similar information about visitors on our partner websites. To this end, we use Googles Analytics, performed by Google Inc. If you refuse to be followed by Google Analytics, you can choose to opt out at the following address: https://tools.google.com/dlpage/gaoptout.

 

Functionality Cookies

These cookies allow the website to remember you in order to provide personalized and advanced functionalities (like language settings.) These cookies can also be used to remember changes you made to font size, type and other parts of the website’s pages you can personalise. The information these cookies collect may be anonymized and they can’t follow your activity on other websites. 

 

Social Media Cookies 

These cookies are used when you share information through a sharing or ‘Like’ command on a social media, or when you contact us on or via social media, such as Facebook, able to link your use of our Platforms to targeting/advertising activities. We do not control the way these social media use cookies. Interaction with these functions are subject to the privacy policies of the companies who provide them.

 

Advertising and Targeting Cookies 

These cookies are used to deliver ads tailored to your tastes on our websites, the websites of our group’s companies, and those of our partners. We undertake targeted advertising activities towards our existing customer base, and target other people we think might be interested in our products and services. They are also used to limit the number of times you see an ad and to help us assess the performance of our ad campaigns. They allow us to better understand and evaluate left clicks on our ads in order to improve the service you get. They are usually placed by advertising networks with your permission. They remember when you have visited a website and this information is shared with other organisations like advertisers. Advertisers and other third parties (including advertising networks, ad broadcasting companies and the service providers they may use) may assume that users who interact with or click on a personalized ad or content are part of the demographic group this ad or content is intended for.

In order to refuse cookies related to targeted advertising, you may visit www.youronlinechoices.eu.However, please note that you will still receive ads – your refusal only means that the ads you receive will not be adapted to your preferences. Also note that we only use a few of the many networks listed on this website.

 

We use these third-parties advertising cookies on our Platforms: 

Company

Description

Google 

The GA Audience cookie allows us to send you ads related to your areas of interest on the web and on your apps. This cookie’s maximum lifespan is 13 months.

Criteo 

The Criteo cookie allows us to send you ads after you visited our Platforms or interacted with a different ad in the past. This cookie’s maximum lifespan is 13 months.

Facebook 

The Facebook cookie allows us to send you ads related to your areas of interest on this social media. This cookie’s maximum lifespan cycle is 13 months.

DoubleClick(Google) 

The Facebook cookie allows us to send you ads related to your areas of interest on this social media. This cookie’s maximum lifespan is 13 months.

Yahoo 

The Yahoo! Audiences cookie allows us to send you ads related to your areas of interest on the web and on your apps. This cookie’s maximum lifespan is 13 months.

Web Servers Logs and Pixels 

As well as collect information through cookies, our Web servers may log information such as your operating system type, browser types, domain and other system settings, as well as the language your system uses and the country and time zone in which your device is located. Web server logs may also log information such as the web page address that referred you to our website and the IP address of the device you use to connect to the Internet. This information helps us fix errors, improve performance and maintain security on our Platforms. In order to control which Web servers collect this information, we can place tags named pixels on our Web pages. They are digital instructions linking Web pages to specific Web servers and their cookies. We may also use cookies and similar devices (like pixels) to allow us to figure if an email we sent you was opened and resulted in an action, and if our mailing tools work properly or in order to assess their performance level and provide adapted content and ads to you.

Can I refuse cookies and similar devices?

If you oppose the placement of all cookies, or wish to authorise only certain cookies, please open your browser settings. You can also use your browser settings to withdraw your consent to the use of cookies at any time and delete cookies that have already been placed. To know more about cookies, please consult http://www.allaboutcookies.org/manage-cookies/. By refusing or disabling cookies, some content or functionalities might become inaccessible to you. You will find details about the way to refuse Google Analytics and targeted ads-related cookies in the previous paragraphs.

Considering pixels are identical to any other content request included in a Web page’s recipe, you cannot refuse them. Nevertheless, you may be able to disable pixels in electronic messages if you don’t download the images included in messages you receive (this function varies depending on the email software used on your personal computer). Doing so will not always disable a pixel or other similar devices within the electronic message because of the specific capacities of the email software. For further information, please read the information provided by your email software or service provider. Pixels may also be disabled under certain circumstances by refusing cookies or by changing the cookie settings on your browser.

 

4. PERSONAL DATA HOSTING

 

We are committed to protecting the personal data we collect. It is of the utmost importance to us to ensure the security of your personal data. We take all measures to guarantee that your personal data is protected from any unauthorised or illegal processing, any loss, damage or accidental destruction and we limit access to your personal data to the people who reasonably need them in order to provide products or services. 

Any data transmitted from our browser to our Platforms through online forms, our store localiser or your cart is secured with SSL technology (Secure Socket Layer). SSL is a cryptographic protocol that ensures data confidentiality and integrity when they are communicated between two authenticated parties.

Our Platforms may contain links to and from third-party websites. If you follow one of these links, please note that these websites have their own privacy policy and that we decline all responsibility regarding these policies or the way these third parties may use your personal data. Please read these policies before providing any personal data to these websites.

If you create an account with us, you will be asked to provide a username and a password for it, as a part of our security measures. You must treat this data as confidential information and must not disclose it to third parties.

 

5. YOUR RIGHTS

 

We do everything possible to give you a choice regarding the personal data you provide to us. The following mechanisms give you control over your personal data: 

Advertising, marketing and customisation (online and offline:)  

If you wish to receive information about our products and services, events, loyalty programs or other customer programs, and other promotional activities, you can let us know your contact preferences by ticking the corresponding box or boxes on our Platforms or on the customer cards in our stores, or by answering the question or questions asked by our beauty counsellors or our salespeople in stores. Some of our activities and communications can be tailored to your specific areas of interest and your preferences (which will be done with your permission, if the law requires it).

If you don’t wish to receive our marketing communications anymore (and/or don’t wish to receive personalized marketing communications), simply let us know at any time by following the Unsubscribe instructions in said communication. Please note that you will not stop receiving service messages from us (i.e. non-marketing communications, such as email updates to follow your order or notifications about your account’s activities).

Cookies/Similar devices and Advertisement based on your areas of interest: you can set parameters on your browser to refuse all or some cookies or to be warned when cookies are used, or to use the unsubscribing tools provided. You also have a choice regarding ads based on your areas of interest. 

 

6. YOUR PREFERENCES 

 

Pursuant to applicable law, you have the right to ask us for a copy of your personal data, in order to correct them, delete them or to limit their processing, or to ask us to transfer some of this data to other organisations. You also have the right to oppose part of the processing and, when we asked for your consent to process your personal data, to withdraw it. When we process your personal data pursuing a legitimate interest (as explained above), you also have the right to oppose it. These rights may be limited under certain circumstances – for example, when we can prove that we have a legal or contractual obligation to process your personal data. In some cases, it may mean that we can keep your personal data even when you withdrew your consent. We will then take all appropriate measures and precautions to protect your personal data.

Please contact us if you wish to exercise any of these rights. 

In order to comply with your wishes, we can demand proof of your identity.