CUSTOMER CARE

This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from www.emmalewisham.com or any of their subdomains (the “Site”). It also explains how to access and update your personal information, and where to go for further information.  

This Site and the products and services are provided by Emma Lewisham Limited and in the United States by Emma Lewisham US, Inc (‘we’, ‘us’ or ‘our’). Any reference to ‘we’, ‘us’ or ‘our’ for products and services provided in the United States shall be to Emma Lewisham US, Inc.  

When you provide us with personal information, we respect your privacy. We will never sell, distribute or pass on your personal information to anyone else except as set out in this Privacy Policy to provide you with our products and services. If you have any questions about this Privacy Policy or you wish to exercise any of your rights, then you can contact us at legal@emmalewisham.co.nz.  

Alternatively: 
If you are based in the UK, we have appointed an authorised representative in the UK to facilitate and deal with any queries or requests that you may have. You can contact our authorised representative via the details below: By email: gdpr@gsverde.law By Post: GS Verde Law, The Generator Building, Counterslip, Redcliffe, Bristol, BS1 6BX. If you are based in the European Economic Area (EEA), we have appointed an authorised representative in the EU to facilitate and deal with any queries or requests that you may have. You can contact our authorised representative via the details below: By email: eugdpr@gsverde.law By post: The GEC, Taylor’s Land, The Liberties, Dublin 8, IrelandGS Verde Group
 

We collect and use personal information from customers, users or visitors of the Site, social media channels, products or services. The type of personal information that we collect and use depends on the type of dealings that you have with us and can include your name, address, telephone number, email address, postal or delivery address, date of birth, payment information (such as credit card details), proof of identity information and documents, and information about the products and services you have ordered or enquired about.

When you submit your personal information to us, or by using, browsing or accessing our Site or social media channels, you are giving your consent to the collection, use and disclosure of your personal information as set forth in this Privacy Policy.

When you visit the Site, we automatically collect certain information about the device you are using, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.

We collect Device Information using the following technologies:

• “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org
• “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
• “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

When you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, postal or delivery address, payment information (such as credit card details), email address, phone number and the products and services you have ordered. We refer to this information as “Order Information”.

We may collect Personal Information about you through social media or other online channels when you contact us with a query or request information about our products and services, complete any forms or agreements for our products and services, when you participate in competitions, promotions, events, surveys or questionnaires either from us or third parties or publicly available sources of information (including, but not limited to, social media sites).

Additionally, if you create an account with us, you will be part of the Beauty Circle Rewards Program (“Program”). We will process your Personal Information to enable us to administer and manage the Program. This includes notifying you from time about offers, gifts, benefits or reward opportunities. When we talk about “Personal Information” in this Privacy Policy, we are talking about Device Information, Order Information and any other personal information we have outlined in this Privacy Policy that we will collect.

The Personal Information collected by us will track your use, or enhance your use, of the foregoing and assist us in providing a better service. We do not use or share Personal Information for any purpose other than for the purpose for which it was disclosed. We will only collect Personal Information that is necessary for one or more of our functions or for the purpose disclosed to you.

We use your Personal Information for the purposes for which the information is collected. The Personal Information that we collect is generally used to provide our products, services, website and social media channels (including customised online content and advertising displayed on our website or social media channels) to you. We also use it to improve or develop our products, services and website, to operate, maintain and test and upgrade our systems and to notify you of opportunities (whether product or service, related) that we think you might be interested in. We may disclose Personal Information to our business partners, third party contractors, agents, suppliers and service providers (as set out in section 4 below) in connection with providing our products and services to you.

We use the Order Information that we collect generally to fulfil any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and order confirmations). Additionally, we use this Order Information to communicate with you, screen our orders for potential risk or fraud, and when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimise our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

If you provide your Personal Information to us, whether via one of our websites or social media channels, through any of our promotions or competitions, or otherwise, the information you provide may be used by us to create and deliver to you direct mail, emails, SMS, surveys or invitations to attend customer research or discussion groups or other communications containing product, services and event information, tips, promotions or competitions. If you prefer not to receive such communications, see section 5 below.

We may also contact you to respond to product questions or concerns that you may express. These types of communications are necessary to serve you, respond to your concerns and to provide the high level of customer service that we offer our customers

Disclosure of your Personal Information
We may share your Personal Information with the parties set out below:
We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store—you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy.

We also retain other companies and individuals to perform functions consistent with our Privacy Policy including customer support, internet and website service providers, fulfilment companies (companies that deliver your product and co-ordinate mailings), cloud based storage providers, marketing and research agencies, financial and credit card institutions, and our advisors. Such third parties will only be provided access to Personal Information to perform their functions.
We also use Google Analytics to help us understand how our customers use the Site—you can read more about how Google uses your Personal Information here: www.google.com/intl/en/policies/privacy/.

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Information in the same way as set out in this Privacy Policy.
We may also share your Personal Information to comply with applicable laws and regulations, to respond to a court order or other lawful request for information we receive, or to otherwise protect our rights.

We may also exchange information, including Personal Information, with other companies and organisations for credit fraud protection and risk reduction. This may occur in several instances, including when your bank or other financial institution requests proof of authorisation of a payment.

We require all third parties to respect the security of your Personal Information and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Information for their own purposes and only permit them to process your Personal Information for specified purposes and in accordance with our instructions.

International transfers
Many of our external third parties are based outside the UK and/or the EU so their processing of your Personal Information will involve a transfer of data outside the UK and/or the EU.

Whenever we transfer your Personal Information out of the UK and/or the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the safeguards is implemented:

• We will either, transfer your Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information such as New Zealand.
• Where we use certain service providers we may use specific contractual arrangements approved for use in the UK and/or EU which give Personal Information the same protection it has in the UK and/or EU.

Please contact us if you want further information on the specific mechanisms used by us when transferring your Personal Information out of the UK and/or EU.

We have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

If you have provided your express consent or we are relying on legitimate interest to receive such communications from us, you may receive offers that are tailored towards your preferences based on your use of our services, your purchase history, your Program settings, your participation in promotions, surveys, your use of the Site, apps and other digital channels as well as other data that you have provided to us.

We may send this information by mail, email, SMS, telephone, on or via social media or other online channels (including by customising online content advertised or displayed on our Site or social media channels).

We may send you service or product updates and notifications only where you are an existing user or customer and such updates and/or notifications are necessary for the proper functioning of the services and products that you use.

If you do not wish to receive direct marketing communications or offers from us you can opt out at any time by (a) using the unsubscribe facility that we include in our commercial electronic messages (i.e. email or SMS); or (b) Contacting us via the details provided in section 1 above.

You can opt out of targeted advertising by using the following common links:

• FACEBOOK - https://www.facebook.com/settings/?tab=ads
• GOOGLE - https://www.google.com/settings/ads/anonymous
• You can also opt out of Google Analytics here: https://tools.google.com/dlpage/gaoptout

How long will you use my Personal Information for?
We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you

To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers such as your name, address, financial and transactional data six years after they cease being customers for tax purposes.

We maintain reasonable safeguards to protect against unauthorised disclosure, use, alteration or destruction of the Personal Information you provide us
Despite our reasonable steps, we are unable to ensure or warrant the security of any Personal Information transmitted to us. Accordingly, all Personal Information disclosed by you to us is at your own risk and we are not liable for any unauthorised access to the Personal Information.

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. As we may make changes at any time without notifying you, we suggest that you periodically consult this Privacy Policy.

If we change our Privacy Policy, we will post the revised copy on this webpage.