ABOUT THIS POLICY
“Personal information” (as defined in the Privacy Act 1993) means information about an identifiable individual; and includes information relating to a death that is maintained by the Registrar General Pursuant to the Births, Deaths, Marriages and Relationships Act 1995, or any former Act.
1 L’ORÉAL PRIVACY OBLIGATIONS
The 12 IPPs are defined as follows:
1. Purpose of collecting personal information.
2. Source of personal information.
3. Collecting information from subject.
4. Manner of collecting personal information.
5. Storage and security.
6. Access to personal information.
7. Correcting personal information.
8. Accuracy to be checked before use.
9. How long personal information is held.
10. Limits on use of personal information.
11. Limiting disclosures of personal Information.
12. Unique identifiers.
2 PERSONAL INFORMATION
L’Oréal will, from time to time, collect personal information.
The types of personal information L’Oréal collects and the purposes for which that personal information is used will depend on the circumstances. We give examples below of the typical information L’Oréal collects in given situations.
L’Oréal may collect personal information from its employees in connection with their employment. Personal information includes an employee’s name, address, date of birth, photographs, bank account details and employee records.
Any personal information obtained and held by L’Oréal directly related to an employee’s employment with L’Oréal will be exempt from compliance with the Act. L’Oréal may be required to disclose the personal information of its employees, from time to time, for the purposes of conducting its business or otherwise in accordance with this policy.
L’Oréal may, from time to time, obtain sensitive information about its employees, either directly or indirectly. Where L’Oréal comes into possession of sensitive information relating to an employee, this information will only be used for the purposes for which it was obtained.
L’Oreal sometimes collects personal information about consumers. This information includes name, contact information (including postal and email address and telephone numbers), gender, age, product preferences and purchasing histories of consumers. We use that information to assist in the supply of products and services for promotional purposes and for our internal administrative purposes. We may also use personal information for marketing, although we will not do so if the person concerned indicates to us that they do not wish to receive marketing material from us.
Personal information of consumers is not usually disclosed by L’Oreal to third parties.
2.3 Web Site Users
Typically, L’Oréal collects personal information from visitors to the L’Oréal web site such as name, contact information (including postal and email address and telephone numbers), gender, age or age group and credit card details. Depending on the purpose for which we sought that information, we may use it to supply goods and services and for our internal administrative purposes related to that supply, or to enter people in promotions and competitions. We may also use personal information for marketing, although we will not do so if the person concerned indicates to us that they do not wish to receive marketing material from us.
L’Oréal may also collect “clickstream” information (such as which areas of the web sites you have accessed, the time and date of access, the type of browser software used, the visitor’s IP address and the previous web site that visitor has linked to the site from) from a visitor’s use of our web sites. We may also store “cookie” information (such as user preferences relating to a visitor’s use of the web site) on the visitor computer. That information is used to customize and improve L’Oréal web sites.
2.4 Applicants for Employment
L’Oréal collects a range of personal information about applicants for employment such as name, contact information (including postal and e-mail address and telephone numbers), employment and training history and any other information included as part of an application, resume or curriculum vitae. We may also obtain personal information from psychological or aptitude tests and from referees. We use all of that information only to assess a person’s suitability for available employment positions.
Applicants for employment agree to L’Oréal collecting, using and disclosing the information for the purposes for which it was disclosed and to the extent permitted by the Act.
Where L’Oréal holds personal information from a previous employment application, the applicant can request to access the personal information in accordance with clause 7 of this policy. The request must be provided to L’Oréal within a reasonable timeframe and must particularise the information sought and the purpose for which the information is sought. L’Oréal will provide access unless an exception to access applies under the Act.
L’Oréal will take reasonable steps to destroy all personal information it holds if the information is no longer required for the purpose for which it was obtained.
2.5 Suppliers, Purchasers, Customers and Contractors
The personal information L’Oréal collects about suppliers, purchasers or contractors who are individuals is typically name, contact information (including postal and e-mail addresses and telephone numbers), payment and banking details. We use that information for our transactions with that individual, our internal administrative purposes related to our relationship with that person as a supplier, purchaser or contractor and in building and managing our commercial relationship with them.
3 DISCLOSURE OF PERSONAL INFORMATION
L’Oréal does not generally disclose personal information to third parties except:
• where third party contractors appointed by L’Oréal require access to personal information held by us to perform services for us on our behalf (such as marketing agencies, customer service, parties who provide credit card processing services and website data hosting);
• to our related companies;
• to our professional advisors, accountants, insurers, lawyers and auditors on a confidential basis;
• in the unlikely event that we, or any of our assets, are or may be acquired by a third party, to that third party and its advisors;
• in certain circumstances, to third parties that require information for law enforcement or to prevent a serious threat to public safety;
• where L’Oréal is required or authorised by law to disclose personal information; or
• with the consent of the individual concerned.
Where those third parties require access to personal information held by L’Oréal to perform those services, L’Oréal requires that our contractors are obliged to keep that personal information confidential and not to use or disclose it for any purpose other than performing services for us or on our behalf.
You should be aware that some information that you upload to parts of our websites or to social media pages may be available to be viewed by the public. You should use discretion in deciding what information to upload to such sites.
4 PROCESSING AND TRANSFER OF INFORMATION
As L’Oréal is an international business, some information (including personal information) may be transferred to countries outside of New Zealand in the ordinary course of our business including to parties located in:
• the USA;
• other countries in Asia; and
• countries in the EU.
5 STORAGE AND SECURITY
L’Oréal will take reasonable steps to ensure the security of personal information that it holds.
6 SEEKING ACCESS
Individuals have the right to seek access to personal information which L’Oréal holds about them and to request correction of that information.
There are a number of circumstances in which L’Oréal may decline to grant such access. These are set out in the Act. Those circumstances include, but are not limited to, where granting access would reveal evaluative information generated within L’Oréal in connection with a commercially sensitive decision making process, where granting access would prejudice negotiations with that individual, where granting access would reveal information relating to existing or anticipated legal proceedings which would not be discoverable in those proceedings or where the request for access is frivolous or vexatious.
If you have any questions or concerns about L’Oréal’s collection, use or disclosure of your personal information, or if you would like to access, update or correct the information we hold about you, please contact us (see section 9 of this policy).
L’Oréal will endeavor to acknowledge such requests as soon as possible and within at least 20 days.
If L’Oréal is required to or otherwise agrees to grant access to the personal information, it will endeavor to give access within 14 days. At that time, L’Oréal will notify the person concerned of the method by which it will give them access to the information.
If L’Oréal is not required to and elects not to grant access to the personal information, it will inform the individual concerned of the grounds on which it is not required to grant access and inform them of their options to seek to have that decision reviewed.
7 AMENDMENTS TO THIS POLICY
8 COMPLAINTS ABOUT PRIVACY
All complaints will be taken seriously and will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information we may require.
If individuals are not satisfied with our handling of a complaint by them, they may refer the issue to the Privacy commissioner at www.privacy.org.nz
9 QUESTIONS ABOUT PRIVACY
Individuals who have any questions or concerns about L’Oréal collection, use or disclosure of their personal information should contact L’Oréal’s Privacy Officer via the Consumer Affairs Department at Building B, Millennium Centre, 600 Great South Road Auckland 1051, telephone 0800 655 444.