LAST UPDATED: 5/24/2022
Q: HOW DO WE COLLECT PERSONAL INFORMATION FROM YOU?
LAURA MERCIER WEBSITES AND APPLICATIONS
We may collect Personal Information from you through one of our Canadian or international websites or applications. This could include (a) any site that we own and control under our own domain (such as lauramercier.ca, or some other domain name that redirects you to one of these sites), or (b) any site or web application that we may develop and run on a third party social network such as Facebook. This could also include any site or application that we specifically design for use on a cell phone or other mobile device, such as a mobile-enabled site (i.e., WAP site) or mobile application (e.g., iPad/iPhone app). This Policy will only apply if it is posted or linked to on the website or application which you are using.
LAURA MERCIER STORE COUNTERS
We may collect Personal Information from you at one of our store counters located within department stores. This may take the form of a printed registration card or electronic registration, or other Personal Information collected during checkout.
LAURA MERCIER TEXT MESSAGING PROGRAMS
We may collect Personal Information from you through one of our inbound text messaging programs. For example, periodically we may allow customers to send us inbound text messages using a short code that we create and advertise in connection with a special offer or promotion. These programs might be advertised in one of our store boutiques or on one of our websites or applications. If you choose to participate in one of these programs, Personal Information about your physical geo-location may be collected and used for marketing purposes.
CALL CENTER ORDERS
We may collect Personal Information from you through our call centers, for example if you place an order over the phone. By email, or through live chat to our customer service department. These methods of ordering are available in Canada and in some locations outside of Canada. Our call centers may also collect Personal Information from you to respond to your question or comment or other follow-up request.
We may collect Personal Information from you if you correspond with us via email. For example, if you send an email to our customer service department, we may obtain certain Personal Information about you (such as your contact email address) and use it to follow up.
DATA COLLECTED FROM OTHER SOURCES
Occasionally, we may obtain Personal Information about you from other sources. For example, we may hire a third party data aggregator or vendor to provide us additional Personal Information about our existing customers (this is known as “data appending”), including Personal Information from your profile or postings on a third party social network. We may also receive Personal Information from third party co-sponsors who we may partner with occasionally to run special promotions or giveaways. We may also receive Personal Information about customers in the event we acquire other companies. We may also receive Personal Information from other methods that are not inconsistent with this Policy.
Q: WHAT PERSONAL INFORMATION DO WE COLLECT FROM YOU?
Depending on how you interact with Laura Mercier (online, in-store, on the phone, etc.), we may collect from you various types of Personal Information, which are described in more detail below. In some instances (and unless we say otherwise below), we may combine one type of Personal Information with another type of Personal Information, and store them together in our records. In all cases, however, we strive to limit the amount of Personal Information we collect and store to that which is necessary to provide you the relevant services.
PERSONAL CONTACT INFORMATION
This includes any Personal Information that would allow us to personally contact you, such as your name, home or mailing address, phone number, or email address. In some cases, this could include Personal Information that you give us about someone else (for example, if you ask us to ship a Laura Mercier product to a friend). We typically collect personal contact information in connection with a variety of activities, including account registration, product orders, customer service, contests and promotions, and customer feedback. If you create an account with us, some of your personal contact information may be stored under your account profile. To review or edit this Personal Information, go to the relevant “My Account” section of our site or contact Customer Service.
This includes any Personal Information that you use to make a purchase, such as your credit card details (cardholder name, card number, expiration date, etc.), gift card information, check or other forms of payment (if such are made available). This also includes the billing name and address associated with your form of payment. We only collect payment information for purchases (whether your purchase is made in-store, online, or by phone). If you create an account with us, your payment information (along with your purchase history and other related preferences) may be stored under your account profile. To review or edit this information, go to the relevant “My Account” section of our site or contact Customer Service.
ACCOUNT LOGIN INFORMATION
This refers to any Personal Information that is required for you to establish a unique account with us or for us to give you access to your specific account information. Examples include customer number, login ID, screen name, password, and/or security question and answer. Certain login information, such as your customer number, may be generated by us and then sent to you. We only collect (or create for you) unique login information for those activities that require an account. Your unique login information, especially your password, should always be kept confidential and should never be shared with anyone else. To change your account password, go to the relevant “My Account” section of our site or contact Customer Service.
This includes any Personal Information that describes demographic or psychographic characteristics. Examples may include your date of birth, age or age range, gender, facial attributes (e.g., hair color, eye color, skin type, skin tone, etc.), general geographic location (e.g., postal code or city and province/territory), favorite products, hobbies and interests, or lifestyle information. We typically collect demographic information in connection with a variety of activities, including account registration, contests and promotions, and customer surveys. If you create an account with us, you may be allowed to modify certain demographic information stored under your account profile. To do so, go to the relevant “My Account” of our site or contact Customer Service. For demographic information associated with your profile on a third party social network (e.g., Facebook), see separate paragraph on “Social network information” below.
TECHNICAL COMPUTER INFORMATION
WEBSITE USAGE INFORMATION
This includes information that you voluntarily share with us about your experience in using our products or services, including our beauty products, websites and applications, and store boutiques. Examples may include comments and suggestions, testimonials, or other feedback you send us about what you may have liked (or disliked) about your experience in using our products or services. We typically collect this Personal Information in the form of customer surveys, feedback forms, and email correspondence.
This refers to any content that you create and then share with us (and perhaps others) by uploading it to one of our websites or applications, such as our Facebook fan pages or applications (THURD https://www.facebook.com/about/privacy/previous). Examples may include photos, videos, personal stories, or other similar media or content. We mostly collect customer-generated content in connection with contests and promotions, website community features, customer engagement, and third party social networking.
SOCIAL NETWORK INFORMATION
This refers to any Personal Information that is part of your profile on a third party social network (such as Facebook) and that you allow the third party social network to share with us or that you post publicly. Examples may include your basic account information (e.g., name, email address, profile picture, gender, birthday, current city, user ID, list of friends, etc.) and any other additional Personal Information or activities that you permit the third party social network to share with application developers or that you post publicly on a Laura Mercier social networking page. For example, we may receive your social network information (or parts of it) when you download or interact with a Laura Mercier application on a social networking site (such as Facebook) or use a third party social networking feature that is integrated within a Laura Mercier site (such as Facebook Connect).
If you share Personal Information that also includes Personal Information belonging to another individual, you undertake to obtain their consent before disclosing their Personal Information to us.
To learn more about how your social network Personal Information may be obtained by Laura Mercier (or other application developers), please visit the website of the relevant third party social network (Facebook (https://www.facebook.com/about/privacy/previous), Pinterest (https://policy.pinterest.com/en/privacy-policy), and Instagram (https://help.instagram.com/519522125107875/?helpref=uf_share).
OTHER PERSONAL INFORMATION (DEPENDING ON CONTEXT)
This refers to any other Personal Information that we might need to collect for a specific Laura Mercier form, feature, or other service that you use or request. What this Personal Information might include will vary depending on the method of collection and the specific purpose(s) for which the Personal Information is being collected. Please see the section “How do we use your information?” below for more specific examples.
Q: HOW DO WE USE YOUR PERSONAL INFORMATION?
The following paragraphs describe the various purposes and features for which we might collect and use your Personal Information, and the different types of Personal Information that might be collected for each. Please note that not all of the uses listed below will be relevant to every customer.
We may collect and use your Personal Information to process and ship your orders, to inform you about the status of your orders, and to follow up with you about your satisfaction with the ordered products. Depending on how you make a purchase (e.g., online, in-store, call center, etc.), this could involve the collection and use of certain personal contact information, payment information, account login information, and/or Personal Information related to your purchase (such as products ordered). This could also involve the ongoing storage of your payment information to allow for easier checkout on future purchases.
Please note that there are many independent e-commerce sites that sell Laura Mercier products but that are not controlled or operated by Laura Mercier. Because these sites may have different privacy and security practices than we do, we recommend that you read their privacy policies before making any purchases on those sites.
We may use your Personal Information to maintain your accounts with us, including administering any customer loyalty or rewards programs associated with such accounts. This typically involves the use of the information that was originally collected to set up your account (e.g., personal contact information, payment information, account login information, demographic information, etc.).
We may collect and use your Personal Information to provide you customer service, including responses to your inquiries. This typically requires the collection and use of certain personal contact information (such as your name, email address) and information regarding the reason for your inquiry (e.g., order status, technical issue, product question, general question, etc.). Customer service may be provided through various forms of communication, such as email correspondence and call center support.
PRODUCT IMPROVEMENT AND CUSTOMIZATION
We may collect and use your Personal Information so we can constantly improve our products, tailor them to your needs, and come up with new product ideas. This mostly involves the collection and use of demographic information and customer feedback.
PERSONALIZED PRODUCT RECOMMENDATIONS
We may use your Personal Information to provide you with Laura Mercier product recommendations, offers, and rewards that are tailored to your interests and profile. This mostly involves the use of your previous order history (including online, boutique, and call center purchases), as well as certain demographic information (such as your favorite look, unique facial attributes, birth date, etc.).
CONTESTS AND PROMOTIONS
We may collect and use your Personal Information to administer a contest, sweepstakes, giveaway, competition, or other similar marketing campaign or promotion. These events typically require the collection and use of personal contact information (for prize fulfillment), limited demographic information (for eligibility), and, in some cases, customer-generated content. Some promotions with customer-generated content or a social networking component will be run on third party social networks such as Facebook (e.g., on Laura Mercier’ Facebook fan page or application). To comply with sweepstakes laws, we may publish or share limited Personal Information about promotion winners (such as name and city of residence). For more information about our contests and other promotions, please see the official rules or details posted with each promotion.
We may collect and use your Personal Information to send you marketing communications, such as email communications, mobile messages (including text and/or push notifications), and postal mailings. These communications may inform you about new products, store events, special discounts and coupons, beauty tips, and other news and special offers. On occasion, these communications may also contain information or offers about third party products.
Sending you marketing communications mostly requires the collection and use of certain personal contact information and/or demographic information. In some instances (such as for mobile messages), this may involve the use of technical information or precise geo-location information obtained from your mobile device. This allows us to send you messages directly to your mobile device, including offers and coupons based on your location.
WEBSITE PERSONALIZATION AND CONVENIENCE
We may collect and use your Personal Information to personalize your experience and save you time when you visit our websites and applications. This is typically done through the use of automated technologies (such as cookies) that collect and remember certain account login information, technical information, and/or previous website usage information. For example, we might remember your login ID or username so you can quickly login the next time you visit our site or so you can easily retrieve the items you previously placed in your shopping cart. Based on this type of Personal Information, we might also show you specific Laura Mercier content or offers that are more relevant to your interests.
WEBSITE COMMUNITY FEATURES
We may collect and use your Personal Information to give you access to our website community features, such as features that may allow you to upload and share ratings, reviews, questions/answers, stories, pictures, videos, or other content. This typically involves the collection, use, and (in some instances) public display of certain personal contact information, account login information, demographic information, and/or customer-generated content. Because these types of features are “communal” in nature, Personal Information you post in these areas may be visible to others. Please use caution when using these features or uploading content to a Laura Mercier site or application. For some community features, you may have the ability to control whether some parts of your profile can be seen by others and whether we send you notifications about certain community activities (like the fact that one of your questions has been answered). To access these settings, go to the “My Account” section of our site and login to the relevant community account. For community features that are integrated with third party social networks such as Facebook, see separate section on “Third party social networking” below.
WEBSITE VIRAL FEATURES (E.G., TELL-A-FRIEND)
Where permissible under applicable law, we may request and use your Personal Information so you can use our website viral features, such as tell-a-friend. These features allow you to easily share certain Laura Mercier news, product information, promotions, wish list items, or other content with family members and friends. These features typically require the collection and use of certain personal contact information (such as email addresses and names) so that the selected message or content can be delivered to the proper recipients. In some instances, this Personal Information may be stored in our records so we can track and reward our customers for their referrals. For tell-a-friend or other viral features offered by third party social networks (such as Facebook “Share” and “Like” features), see separate paragraph on “Third party social networking” below.
THIRD PARTY SOCIAL NETWORKING
We may collect and use your Personal Information when you interact with third party social networking features, such as Facebook Connect, Facebook Like ((https://www.facebook.com/about/privacy/previous), Pinterest (https://policy.pinterest.com/en/privacy-policy), and Instagram (https://help.instagram.com/519522125107875/?helpref=uf_share). These tools may be embedded into our sites or applications for the purpose of running contests, allowing you to share content (such as beauty tips, articles, stories, etc.), allowing you to sign up for certain Laura Mercier accounts, or for other stated purposes. If you use these tools, we may have the ability to obtain certain Personal Information about you from your social networking profile (see the section “Social network information” above). You can learn more about how these features work, and the profile data we may obtain about you, by visiting the website of the relevant third party social network.
THIRD PARTY ONLINE ADVERTISING
We may allow third party ad networks, such as Facebook and Google, to collect and use your Personal Information to show you ads that are targeted to reach people (or people similar to people) who have visited our website or are identified in one or more of our databases ("Matched Ads"), including Laura Mercier ads on our sites or on other sites. This is done by Laura Mercier uploading a customer list to the third party ad network or incorporating a pixel from the third party ad network on our website, and the third party ad network matching common factors between our data and their data. Some of these ads may entice you to come back and revisit our site for new offers and promotions. This type of advertising typically involves an ad network collecting and tracking certain technical information (such as your IP address) and website usage information (such as your browsing history) on our sites and across many other sites on the Internet. To opt-out of receiving Matched Ads, please contact the applicable third party ad network, or you can opt-out from this type of third party tracking at any time by going to: https://www.networkadvertising.org/managing/opt_out.asp. If we use Facebook Custom Audiences to serve Matched Ads on Facebook services, you should be able to hover over the box in the right corner of such Facebook ads and find out how to opt-out. We are not responsible for such third party ad network’s failure to comply with your opt-out instructions.
OTHER GENERAL PURPOSES (E.G., WEBSITE SECURITY, INTERNAL RESEARCH)
We may collect and use your Personal Information for other general business purposes, such as to maintain the day-to-day operation and security of our websites and applications and to conduct internal marketing and demographic studies. These activities mostly require the collection and use of certain Personal Information, demographic information, technical computer information, website usage information, and customer feedback.
You can learn more about cookies and how they work at www.allaboutcookies.org or www.youronlinechoices.eu. You can always disable cookies through your browser settings. Doing so, however, may disable certain features on our websites, such as online ordering.
To opt-out from third party cookies that are used for advertising purposes, you can do so on the NAI website at https://www.networkadvertising.org/managing/opt_out.asp.
We may use third party web analytics services on our websites or applications, such as Google Analytics. The service providers that administer those services use technologies such as cookies, web server logs and web beacons to help us analyze how visitors use the site. The Personal Information collected through these means (including IP address) is disclosed to these service providers, who use the Personal Information to analyze use of our websites and applications. You may deactivate the ability of these analytics services to analyze your browsing activities on our websites and applications. To learn more about web analytics services, and exercise your choice with respect to their collection of Personal Information on our websites or applications:
To disable Google Analytics, please download the browser add-on for the deactivation of Google Analytics provided by Google at https://tools.google.com/dlpage/gaoptout?hl=en. To learn more about privacy and Google Analytics, please consult the Google Analytics overview provided by Google.
Q: WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
We may share your Personal Information with the types of companies or in the situations described below. We do not sell, rent, or otherwise share your data to any third-party for a business or commercial purpose under any circumstances unless you specifically consent to such disclosure.
THIRD PARTY VENDORS
These are outside vendors, agencies, or contractors we hire to help us run our business (e.g., fulfill orders, operate our websites, run promotions and marketing campaigns, operate our call center, etc.). The Personal Information shared with our vendors could include personal contact information, payment information, demographic information, or other types of Personal Information depending on the service being provided by the vendor. For some vendors, we may need to transfer your Personal Information to locations outside your home country, such as to the United States. Our vendors are only allowed to use your Personal Information for the specific tasks we’ve hired them to do, and for no other purpose. They’re also required to keep your Personal Information confidential and secure.
LEGAL DISCLOSURES (WHEN NECESSARY)
This is when we may need to share your Personal Information for law enforcement or other legal purposes. This type of sharing may be necessary in connection with a lawsuit, claim or investigation, governmental inquiry, court order, enforcement of legal rights (e.g., contract terms, intellectual property rights, etc.), safety issue, or other similar legal or security matter. Sharing your Personal Information for these reasons is not a regular event, but could arise from time to time. We will strive to limit the types and amount of Personal Information we may need to share for legal purposes to that which is reasonably necessary.
BUSINESS TRANSFERS (E.G., SALE OR ACQUISITION OF COMPANY)
AFFILIATED BRANDS AND COMPANIES
We may share (or receive) Personal Information about you, including Personal Information, with our corporate affiliates, including our parent company, Orveon Global Limited, or other brands in the Orveon portfolio. For additional information regarding our corporate affiliates or other brands, please see https://www.orveonglobal.com.
Q: HOW DO WE KEEP YOUR PERSONAL INFORMATION UP TO DATE
Laura Mercier uses reasonable efforts to ensure that your Personal Information is kept as accurate, complete and up to date as possible. We do not routinely update your Personal Information, unless such an update in necessary. In order to help us maintain and ensure that your Personal Information is accurate and up to date, you must inform us, without delay, of any change in the information you provide to us by contacting firstname.lastname@example.org.
Q: HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION AND HOW DO WE DISPOSE OF IT?
Laura Mercier will not retain Personal Information longer than is necessary to fulfil the purpose for which it was collected including for the purposes of satisfying any legal, accounting, or reporting requirements and, where required for us to assert or defend against legal claims, until the end of the relevant retention period or until the claims in question have been settled. As this purpose varies depending upon the Personal Information involved, we invite you to contact our CPO for any inquiries pertaining specifically to you.
Upon expiry of the applicable retention period we will securely destroy your Personal Information in accordance with applicable laws and regulations and with our document retention policy.
Q: HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
We use a variety of standard methods (described below) to keep customer Personal Information confidential and secure. Please note, however, that these protections do not apply to any Personal Information you choose to share in public areas such as our website community features or other social areas.
SECURE OPERATING ENVIRONMENTS
We store your Personal Information in secure operating environments that are protected from the public and that we only allow authorized Laura Mercier employees and agents/contractors to access on a need-to-know basis.
ENCRYPTION FOR PAYMENT INFORMATION
We use industry-standard encryption to provide greater protection for sensitive financial information, such as your credit card information or other payment information, when such information is sent to us over the web. For example, encryption is used when you make payments through our online store, as well as if you choose to have your payment information stored with us for future online purchases.
OTHER SECURITY MEASURES
In addition to the methods above, we may take other measures to protect your Personal Information, depending on the sensitivity of the data and other considerations (such as how the information is collected and where it is stored). These measures may include (among other things) additional access restrictions, password requirements, physical protections (e.g., secure data centers, etc.), and employee training.
MEASURES YOU CAN TAKE
Despite all of our efforts, no security safeguards or standards are guaranteed to provide 100% security. It is also important for you to play a role in keeping your Personal Information safe and secure. When signing up for an online account, please be sure to choose an account password that is hard for others to guess and never to reveal it to anyone else. If you use a shared or public computer, never choose to have your login ID or password remembered and make sure to log out of your account every time you leave the computer.
Q: WHAT ARE MY DATA SUBJECT RIGHTS?
Depending on the province in which you reside, you have the following rights related to your Personal Information:
- The right to request whether we hold Personal Information on you and to request a copy of such information.
- The right to have your Personal Information kept accurate, current, and complete. We encourage you to contact us at email@example.com to let us know if any Personal Information is not accurate or changes, so that we can update your Personal Information.
- The right to request that we cease disseminating your Personal Information if the dissemination is contrary to the law or a court order.
- The right to request that we cease disseminating your Personal Information where the following conditions are met:
- the dissemination of the information causes you serious injury in relation to your right to have your reputation or privacy respected;
- the injury is clearly greater than the public’s interest in knowing the information or than any person’s right to express themselves freely; and
- the cessation of dissemination requested does not exceed what is necessary for preventing the perpetuation of the injury.
- The right to request that we de-index any hyperlink attached to your name that provides access to information by a technological means if the dissemination is contrary to the law or a court order.
- The right to request that we de-index a link providing access to information where the following conditions are met:
- the continued indexation of the information causes you serious injury in relation to your right to have your reputation or privacy respected;
- the injury is clearly greater than the public’s interest in knowing the information or than any person’s right to express themselves freely; and
- the de-indexation requested does not exceed what is necessary for preventing the perpetuation of the injury.
- The right to request that we re-index a link providing access to information where the following conditions are met:
- a failure to do so causes you serious injury in relation to your right to have your reputation or privacy respected;
- the injury caused by the failure to re-index is clearly greater than the public’s interest in knowing the information or than any person’s right to express themselves freely; and
- the re-indexation requested does not exceed what is necessary for preventing the perpetuation of the injury.
- The right to request that digital Personal Information collected from you be communicated to you in a commonly used technological format as well as to any person or body authorized by law to collect such information. This right does not extend to information that was created or inferred from your Personal Information and we are under no obligation to communicate such information if doing so raises serious practical difficulties.
- The right to lodge a complaint with the supervisory authority responsible for the province in which you reside, or to seek a remedy thought the courts If you believe that your Personal Information protection rights may have been violated.
- The right to fully or partly withdraw your consent if you have provided your consent to the Processing of your Personal Information. Once we have received notification that you have withdrawn your consent, we will no longer Process your information for the purpose(s) to which you originally consented unless there is another legal ground for doing so.
Please note: some provisions may exceed regulatory requirements in your province. In such circumstances, we have full discretion with respect to their application. In addition, the above rights are not absolute, and we may be entitled by law to refuse or limit the requests.
You can exercise any of your rights as described in this Privacy Notice and under applicable Personal Information protection laws by contacting our DPO at the coordinates provided below.
Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm your identity.
We will not retaliate against an employee who, in good faith and on the basis of reasonable belief, raises questions or concerns regarding their Personal Information.
Q: WHOM DO I CONTACT TO FIND OUT MORE ABOUT HOW MY PERSONAL INFORMATION IS PROCESSED?
Please contact firstname.lastname@example.org to respond to any inquiries you may have concerning our Processing of your Personal Information or how to exercise your Data Subject Rights. We welcome you to contact them at the coordinates provided below:
OTHER IMPORTANT POLICY INFORMATION?
This section provides additional information that is important for you to know about this Policy or our practices.
YOUR PERSONAL INFORMATION MAY BE TRANSFERRED OUTSIDE YOUR HOME COUNTRY
WE DO NOT COLLECT PERSONAL INFORMATION FROM CHILDREN
We do not solicit or collect any type of Personal Information from a person known to be under the age of 14. If we discover that we have accidentally collected Personal Information from a child, we will remove that Personal Information from our records as soon as feasibly possible (or obtain the necessary parental permission to retain it).
WE ARE NOT RESPONSIBLE FOR THIRD PARTY SITES/FEATURES
Our websites and applications may provide links to, or features from, other third party sites (such as third party social networks) that we do not own or control. If you click on such links or use such features, you do so at your own risk. We are not responsible for the content or practices of any third party site, application, or feature.
ORGANISATIONAL ROLES AND RESPONSIBILITIES FOR YOUR PERSONAL INFORMATION
Laura Mercier is responsible for communicating this Policy to you and ensuring that we fully comply with it al all times.
BUSINESS AND INFRASTRUCTURE UNITS
Our business or infrastructure units that Process Personal Information are responsible for ensuring that these activities comply with the Policy.
Our CPO is responsible for:
- developing our Personal Information protection strategy;
- developing and maintaining the Policy, accompanying guidelines and any other policy or procedure related to Personal Information and ensuring they comply with applicable law; and
- serving as our official liaison with the federal and provincial commissioners.