Fresh Cosmetics pays particular attention to the processing, confidentiality and safety of your personal data.
This aim of this privacy charter is to provide you with clear, simple and complete information about how we process the personal data you give us or the data we may collect while you are browsing our website, how it may be transferred to third parties and your rights and options to control your personal information and protect your privacy.
Fresh Cosmetics Ltd., a UK company with headquarters located at 6th Floor UK House, 180 Oxford Street, London, W1D 1AB, registered in the London trade and companies register under no. 04647334 and Fresh, Inc., a US corporation formed under the laws of the State of Delaware, with headquarters located at 130 5th Avenue, 11th Floor New York, NY 10011, (hereinafter “Fresh”) are the data controllers of personal data collected on the website www.fresh.com/uk, in shops and counters in the sense of regulations applying to personal data, in particular Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and the free movement of such data (hereinafter the "GDPR").
I. What is personal data?
Personal data is any information about an identified physical person or a physical person that may be directly or indirectly identified via an identification number or one or more elements particular to them, such as their last name, first name, date of birth, customer number, order number, photo, etc.
II. When can we collect your personal data?
We can collect your personal data when you:
• create a customer account on our website, apps, or in our stores;
• order goods from our website;
• make purchases in stores;
• join our loyalty program;
• use our online services;
• agree to receive marketing communications from us by email, telephone, SMS or post, depending on your selection;
• answer surveys or satisfaction questionnaires based on your customer experience;
• interact with our Company via its official page on social networks or when we suggest re-use of content that you have published on a social network;
• contact our customer service;
• send requests for information to our Company;
• take part in an event we organise;
• browse on the Internet using cookies or similar technology or when you click on advertisements for our products.
III. What personal data might we collect?
(i) As part of the services we provide, we may need to collect certain data directly from you using electronic forms on our website, mobile apps or in selected stores, or in paper form, for a range of purposes (see IV for a list of processing purposes).
Information we might collect includes:
• Your identity
• Your contact details (e.g. email address)
• Your personal preferences in relation to the products we market or to our website (language);
• Information relating to your orders, their tracking and your purchase invoices;
• Information you may provide for our customer service;
• Specific health data if you notify us of any undesirable side-effects concerning any of our products;
• Your bank details if you place an order via our website;
Important: your bank details are encrypted on Fresh.com/uk servers. Payments are processed via a secured payment platform, involving additional verifications, in order to guarantee the security of purchases made on http://www.fresh.com/uk, and combat fraud.
The details you provide of your Payment Card when placing an order are always encrypted prior to transit using an SSL (Secure Socket Layer) protocol.
Personal data essential to Fresh Cosmetics is marked with an asterisk on all personal data collection forms on our website, in electronic form at some of our counters and stores, as well as off-line in paper form. If you do not fill in these compulsory fields, Fresh Cosmetics will probably be unable to respond to your request and/or provide you with the requested services. Other information is optional and enables us to get to know you better and improve our communications and services with respect to you.
(ii) We may also collect certain data generated by your purchases of products or services, online or in stores, particularly information regarding the amount and type of your purchases.
(iii) Lastly, we may collect information regarding the use of our website, especially with respect to your browsing (pages visited, links clicked, etc.). Some of this information may be collected using cookies placed in your web browser when you browse our website. For more information about cookies, read point XI. of this policy.
If you apply for a job with our Company via our website, we may collect the following information:
- Your identity;
- Your contact details;
- Your Curriculum Vitae;
- Your application letter
As this data concerns your application, please inform us in writing of any changes to your contact details or, more generally, to your career and employment situation, to help us to manage your application efficiently.
IV. For what purpose is your personal data collected and used?
Fresh Cosmetics processes your data to:
• enable you to create a customer account on our website, applications and at our counters and in our stores;
• manage your access to your customer account on the Internet or our applications;
• process and manage your online orders and their delivery;
• record purchases made at our counters or in our stores;
• secure online transactions, prevent fraud, payment incidents and manage debt collection (see our terms and conditions for more details) ;
• manage customer relations with respect to any requests for information or complaints you may send us via our website, customer service or social network pages;
• manage our loyalty program;
• trace and manage any alerts you may send us as part of our cosmetic vigilance obligations;
• manage and optimise your customer experience by improving our knowledge of our customers;
• propose appropriate, tailored services, particularly when we enhance our products and services;
• conduct statistical analyses to develop management, measuring and reporting tools in order to adjust and improve our sales, marketing and product manufacturing;
• subject to your consent, send you information on our offers, news and events on your chosen communication media;
• manage your participation in any events to which you have signed up;
• manage any online job applications.
V. What legal grounds legitimise the processing of your data?
Fresh Cosmetics processes your personal information:
• to perform the contract agreed between yourself and Fresh Cosmetics, to manage your access to your customer account and to process and track your orders;
• within the framework of its legitimate interest for the purposes of marketing management, securing its digital media (websites, applications, etc.) and combating fraud ;
• when you have given your consent for the processing of your data, especially for the purposes of managing our sales prospection, and of your browsing data via cookies, etc.
• within the framework of compliance with our legal obligations, particularly fiscal obligations (conserving purchase invoices) and cosmetic vigilance with regard to Regulation (EU) 1223/2009 of 30 November 2009 on cosmetic products;
VI. Who are the recipients of your personal data?
Your personal data is processed by the personnel of Fresh Cosmetics. We ensure that only authorised persons within Fresh Cosmetics have access to your personal data when this is necessary for the purpose of managing our commercial relations or meeting our legal obligations.
We may also share your personal data with;
• other Fresh subsidiaries as well as with our parent company Fresh Inc, other entities of the LVMH Group, with some of these entities acting as data processors;
• subcontractors, such as:
o site hosting and maintenance service providers and the providers of our electronic personal data collection solutions at counters and in stores;
o payment service providers;
o anti-fraud service providers;
o logistic service providers;
o marketing solution service providers;
o sales prospection and social network communication service providers;
o customer service providers;
o service providers for managing cosmetic vigilance alerts;
o event organisation service providers;
Lastly, Fresh Cosmetics may need to share your personal data with third parties to meet its legal, regulatory or treaty obligations, or to respond to requests from authorised legal authorities.
VII. Transferring data abroad
Some recipients of your personal data may be located abroad, including outside of the European Economic Area.
All data transfers outside of the European Economic Area are subject to appropriate guarantees, especially contractual, technical and organisational guarantees, that comply with applicable regulations relating to the protection of personal data.
VIII. How long do we keep your data?
IX. What are your rights and how can you exercise them?
Under current regulations, particularly the GDPR, you have the right to access and correct your personal data, request erasure, object to processing on legitimate grounds and obtain limitation or portability, insofar as this is applicable.
You also have the right to issue general or specific directives concerning the preservation, erasure and communication of your data post-mortem.
You can exercise these rights directly with Fresh Cosmetics by sending an email to email@example.com or a non-registered letter by post to 6th Floor UK House, 180 Oxford Street, London, W1D 1AB including a document proving your identity.
If, at any time, you no longer wish to receive details of our offers, news and events, you can unsubscribe using the hypertext link provided for this purpose in each email we send you. Or you can send a non-registered letter to 6th Floor UK House, 180 Oxford Street, London, W1D 1AB
You may also lodge a complaint with the Data Controller, Fresh Cosmetics, 6th Floor UK House, 180 Oxford Street, London, W1D 1AB
X. Contact details of the Data Protection Officer (DPO) and your right to lodge a complaint
For all questions relating to the collection and processing of your data by Fresh Cosmetics you can contact the Fresh Cosmetics Data Protection Officer at firstname.lastname@example.org or Data Controller, Fresh Cosmetics, 6th Floor UK House, 180 Oxford Street, London, W1D 1AB.
XI. Information on Cookie Management
This section is dedicated to our policy for managing cookies on the website www.fresh.com/uk
It has been designed to provide you with information on the origin and use of browsing data processed when you use our website, together with your rights.
What is a Cookie?
When you use our website, we may, depending on your choice, place a text file on your terminal (computer, smart phone or tablet) via the web browser.
This text file is a cookie. Throughout the period of validity or registration, it will enable Fresh Cosmetics to identify your terminal during subsequent visits.
Only the entity issuing the cookies is able to read or modify the information they contain.
Below you will find information about the cookies that may be placed on your terminal when you visit the pages of the website www.fresh.com/uk, either by Fresh Cosmetics, or by third parties, together with ways in which you can delete or refuse installation of these cookies.
What is the Purpose of the Cookies Issued on www.fresh.com/uk?
There are several types of cookies, some of which are issued directly by Fresh Cosmetics and its service providers, whilst others may be issued by third parties.
1. Cookies issued by Fresh Cosmetics and its service providers
Different types of cookies may be placed on your terminal whilst you are browsing on our website:
a. "Essential" cookies
These cookies are essential for browsing on our website, especially for the functioning of the order process.
Deletion of these cookies may cause problems with browsing on our website and make it impossible for you to place an order.
These cookies are also necessary for tracking the activity of Fresh Cosmetics.
They may be installed on your terminal by Fresh Cosmetics or by its service providers.
b. "Analysis and Customisation" cookies
These cookies are not essential to browsing on our website, but may help you, for example, to search more effectively and optimise your purchasing experience and help us better target your requirements, improve our offer and optimise the functioning of our website.
c. "Advertising" cookies
Cookies may also be used for advertising purposes. These cookies ensure that the adverts you see are the most relevant to you.
What is the benefit of seeing special offers and advertising tailored to your browsing preferences?
The aim is to show you the most relevant offers and advertising. As such, cookie technology enables us to display content, in real-time, that is best suited to your fields of interest, as deduced from your browsing history on our website.
The interest you show in content displayed on your terminal when you consult a website often determines the advertising resources of this site, enabling it to provide its services, which are often supplied free of charge to users. You doubtless prefer to see offers and advertising that are relevant to you, rather than content that is of no interest to you at all. Similarly, both Fresh Cosmetics and advertisers want their offers and advertising to be shown to Internet users that are likely to be interested in them.
Important information if you share your terminal with other users:
If your terminal is used by several people or when a single terminal has more than one type of browser software, we cannot be sure that the services and advertising sent to your terminal will match your use of the terminal, rather than that of another user.
In this case, sharing use of your terminal with others and deciding your browser cookie settings are your free choice and your responsibility.
2. Cookies issued by third-party companies
These cookies are not essential to browsing on our website.
On our website, we may include computer applications from third parties that enable you to share our website content with others, inform others that you have been consulting our website or notify them of your opinion concerning content on our site. This particularly concerns use of the "Share" and "Like" buttons featured on social networks such as Facebook, Twitter, Instagram, Pinterest, etc.
The social network providing these application buttons is likely to identify you via this button, even if you have not used it when browsing our website.
Indeed, this type of application button can enable the social network concerned to track your browsing on our website, simply because your account on the social network in question is enabled on your terminal (a session is open) whilst you are browsing our website.
We have no control over how social networks collect information regarding your browsing on our website and associated with the personal data they hold.
We encourage you to read the privacy policies of the social networks to learn about the purpose, especially advertising, of any browsing information they may collect via these application buttons. These privacy policies should enable you to exercise your choices with respect to these social networks, in particular by changing your account settings.
Visit the websites of the aforementioned social networks for more information about their privacy policies.
3. Managing the cookies placed in your web browser
You can decide whether to allow cookies to be installed on your terminal.
Using the Ghostery browser extension available on our website, or by changing the settings of your browser software, you can choose whether to accept the installation of cookies on your terminal at any time, simply and free of charge.
a. Choices offered to you via Ghostery
Ghostery enables you to choose the cookies that can be installed on your website, except for essential cookies that are required for browsing and placing orders on www.fresh.com/uk, and for managing the activity of Fresh Cosmetics
If you do not want Fresh Cosmetics to install some or all of the Cookies, you can notify us of your choices via Ghostery, which can be accessed from the cookie information strip displayed when you first use our website.
b. The choices offered to you by your browser software (Internet Explorer, Firefox, Google Chrome, etc.).
You can adjust your browser settings as you wish, so that cookies are either (a) accepted and registered on your terminal or (b) refused.