PRIVACY POLICY

When you use our Site, receive any services from us, or in your interactions with us (including over the phone, by email, in person or otherwise), we may collect personal data through a variety of activities. These activities include, but are not limited to, the following instances:

(a) Data collected directly from you. We may collect personal data directly from you when you:

• enter into a contract with us for the supply of goods or services, including any purchases made by you through the Site or in person;
• create a customer account, be it through out Site, our digital applications or in-store;
• agree and consent to receive marketing, commercial and/or personalized communications from us by email, SMS or post, depending on your selection;
• participate and answer our surveys or satisfaction questionnaires;
• contact or interact with our customer services department, including providing feedback, mentioning our products on social networks, interacting with us via the Site or social networks;
• contact us through any other means to submit requests, make appointments or find out more about the goods or services we provide;
• participate in any event organized by us;
• collect samples from our stores through our consultants or by notification from our microsites or websites; and
• request for any invoice or other transactional documentation pertaining to the purchase and supply of any of our goods or services.

(b) Data collected by automated means. Our Site adopts various technologies to make them more user-friendly, effective and secure for its users. Such technologies may result in data being collected automatically by us or by third parties on our behalf. This data does not always, but may, contain an individual's personal data or comprise personal data. Examples of such technologies include:

• Click-stream data: A visit to our Site results in data that is transmitted from your browser to our server being automatically collected and stored by us or by third parties on behalf of us;
• Cookies: Our Site adopts the use of cookies, which are small text files stored on your computer's hard drive or user device by your web browser. Some cookies are essential for using the Site, and other cookies optimize and personalize the contents displayed on the Site. By default, web browsers enable the use of cookies, but this function can also be disabled. It is also possible to manually delete cookies after their use via the web browser. For more information about cookies, please refer to our cookie policy; and
• Web Analytics: Web analytics is the term given to a method for collecting and assessing the behavior of visitors to websites. This includes the analysis of traffic patterns in order, for example, to determine the frequency of visits to certain parts of a website, or to and out which of our information and services our visitors are most interested in. For these purposes, we primarily make use of click-stream data and the other techniques listed above.

The personal data that we might collect when you use our Site, receive any services from us provide, or in your interactions with us (including over the phone, by email, in person or otherwise) include but is not limited to:

(a) Data collected directly from you

• Your personal particulars, including your first and last name, date of birth, gender and identification number (such as national ID or passport details)
• Your signature
• Your personal contact details, such as your personal phone number(s), email address and residential address
• Your personal preferences in relation to our products and services or use of our Site
• Other information required to be able to process your order and provide you with our services, such as information concerning the products that you have ordered or the service that we are providing you, billing and/or delivery addresses, and banking and/or credit/debit card details
• If you have contacted customer service, the details of this contact, the contact history and any information you may have provided to our customer service team
• Your feedback, publications and/or mentions about Guerlain and/or our products via social media or any other channels
• Any specific health data that you notify to us

(b) Data collected by automated means

• In respect of click-stream data, this data can include the IP address of the visitor of the Site, the date and time of the visit to our Site, the referral URL (the site from which the visitor was directed); the pages visited on our Site and any information about the browser used, such as the browser type and version, and operating system
• Information collected using cookies. For more information about cookies, please refer to our cookie policy
• Information collected for the purpose of web analytics

Personal data essential to Guerlain is marked with an asterisk on all personal data collection forms on our Site, 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, Guerlain may not be able to respond to your request and/or provide you with certain requested services. Any other information provided is optional and enables us to get to know you better and improve our communications and services with respect to you.

We generally rely on the accuracy of the personal data provided by you. In order to ensure that your personal data is current, complete, and accurate, please update us if there are any changes to your personal data by contacting us through the contact details listed at section X below. We will not be responsible for relying on inaccurate or incomplete personal data arising from your not updating us of any changes in your personal data that you had initially provided us with. We also will not and do not have obligations to verify the accuracy or completeness of the personal data given by or on behalf of you.

Guerlain will/may collect, use, disclose and/or Process your personal data for one or more of the following purposes:

(a) processing, facilitating and/or dealing with your interest in our products and/or services;
(b) enable you to create a customer account on our Site, applications and at our counters and in our stores;
(c) manage your access to your customer account on the Site or our digital applications;
(d) manage customer relations with respect to any requests for information or complaints you may send us via our Site or customer service;
(e) administering, facilitating, managing, processing and/or dealing with your purchase of our products and services (each, a "Transaction"). Without limiting the generality of the foregoing, should you make a Transaction that includes third party individual(s) or on behalf of third party individual(s) or for third party individual(s), you consent to us disclosing personal data that identifies you, to the said third party individual(s) (such as but not limited to your name);
(f) administering, facilitating, managing, processing and/or dealing with your relationship with us, activities carried out by you on the Site or at our premises/establishments or with us, and your requests, including but not limited to: dealing with your ad hoc queries or requests, dealing with your preferences and dealing with your membership needs;
(g) administering, facilitating, processing and/or dealing in any matters relating to your use or access of our website or including identifying you for login to our website, our portals and other online services provided by us;
(h) monitoring, processing and/or tracking your use of our website in order to provide you with a seamless experience, facilitating or administering your use of our website, and/or to assist us in improving your experience in using our website;
(i) contacting you or communicating with you via phone/voice call, text message and/or fax message, email and/or postal mail for one or more of the Purposes stated herein. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
(j) the conduct of training or training purpose, so as to develop or improve our products or services and/or our staff's and agents' services and/or service quality. Without limiting the generality of the foregoing, such training may involve collection, use, disclosure or processing of your personal data including your feedback or comments or reviews;
(k) trace and manage any alerts you may send us as part of our cosmetic vigilance obligations;
(l) manage and optimize your customer experience by improving our knowledge of our customers;
(m) propose appropriate, tailored services, particularly when we enhance our products and services;
(n) conduct statistical analyses to develop management, measuring and reporting tools in order to adjust and improve our sales, marketing and product manufacturing;
(o) business improvement purposes such as to manage and optimize your customer experience by improving our knowledge of our customers, and/or to create a profile about you;
(p) manage your participation in any events to which you have signed up or been invited to;
(q) for marketing purpose subject to your free, specific, informed and unambiguous consent: to send you personalized communication, marketing, advertising and promotional information, materials and/or documents relating to products, services and/or events (including products, services and/or events of third party organisations with which we may collaborate with) that we (and/or any other Guerlain group entity) or such third party organisations may be selling, marketing, offering, organizing, involved in or promoting, whether such products, services and/or events exist now or are created in the future according to the communication preferences you have indicated to us and to use third party services to personalize your profile;
(r) carrying out due diligence or other screening activities (including background checks, anti-money laundering checks, know your client checks) in accordance with legal or regulatory obligations (whether of Singapore or other countries) applicable to us or any Guerlain group entity, the requirements or guidelines of governmental authorities (whether of Singapore or other countries) which we determine are applicable to us or any Guerlain group entity, and/or our or any Guerlain group entities' risk management procedures that may be required by law (whether of Singapore or other countries) or that may have been put in place by us or any Guerlain group entities;
(s) complying with or as required by any applicable law, governmental or regulatory requirements of any jurisdiction applicable to us or any Guerlain group entity, including meeting the requirements to make disclosure under the requirements of any law binding on us or any Guerlain group entity, and/or for the purposes of any guidelines issued by regulatory or other authorities (whether of Singapore or other countries), with which we or any Guerlain group entity is/are expected to comply;
(t) complying with or as required by any request or direction of any governmental authority (whether of Singapore or other countries) which we or any Guerlain group entity is/are expected to comply with; or responding to requests for information from public agencies, ministries, statutory boards or other similar authorities (whether of Singapore or other countries). For the avoidance of doubt, this means that we may/will disclose your personal data to the aforementioned parties upon their request or direction;
(u) storing, hosting, backing up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Singapore;
(v) to facilitate and/or ensure the safety and security of our premises, our customers, our staff and/or visitors to our premises; to deal with, handle and/or conduct disciplinary, security, crime prevention and/or quality assurance processes, matters and/or arrangements. Without prejudice to the generality of the aforesaid, we wish to bring to your attention that if there are surveillance cameras installed at our premises and/or offices, whether now or in future, such surveillance cameras are for security, crime prevention, safety and training reasons and you acknowledge that your personal data will be collected by such cameras and processed by us consequently, should you visit our premises or offices;
(w) maintaining and/or developing our IT or business systems and infrastructure including testing and upgrading of these systems;
(x) facilitating, dealing with and/or administering external audit(s) or internal audit(s) of the business of Guerlain and/or of any Guerlain group entities, Transaction(s), and/or our or a Guerlain group entity's transactions with our/its customers;
(y) dealing with and/or facilitating a business asset transaction or a potential business asset transaction, where such transaction involves Guerlain as a participant or involves only a Guerlain Group entity as a participant or involves Guerlain and/or any Guerlain group entities as participant(s), and there may be other third party organisations who are participants in such transaction. "business asset transaction" is defined in the PDPA and includes the purchase, sale, lease, merger or amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation;
(z) Guerlain, the Guerlain group's or a Guerlain group entity's reporting purposes including but not limited to reporting on Guerlain's business performance;
(aa) to deal with the or as part of a bankruptcy, winding up, reorganization, restructuring, insolvency, receivership or an assignment for the benefit of creditors, of Guerlain;
(bb) to train, develop or implement artificial intelligence to support the user experience, functionality and operations of or in connection with the Site; and
(cc) any other incidental business purposes related to or in connection with the above,
(the purposes above set out in this section III shall be collectively referred to as the "Purposes")

When we send personalized communications or content, we may use so-called profiling techniques. We will only do so in compliance with the PDPA. For the sake of transparency within this Policy, profiling is defined as any form of automated processing of personal data that consists of using that personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict elements concerning the preferences, interests, behavior, location of that natural person. In these circumstances, you may withdraw your consent at any time by contacting us through the contact details listed at section X below.

If you have listed your telephone number on the "Do Not Call" Registry in Singapore and you do not wish for us to contact you for marketing or promotional activities, please inform us accordingly in writing.

Guerlain processes your personal information when you have given your consent for the Processing of your data for one or more of the Purposes stated at Section III above (such as by your agreeing or consenting to this Policy), unless any exception to consent under the PDPA applies which allows Guerlain to Process your personal information without consent; or pursuant to any other grounds under the PDPA.

Guerlain may rely on the legitimate interests exception under the PDPA to collect, use or disclose your personal data without your consent, for the purpose of detecting and/or preventing, among others:

(a) fraud;
(b) an illegal activity; and/or
(c) the misuse of services provided by or to be provided by Guerlain,
on the basis that such collection, use or disclosure is for the legitimate interests of Guerlain or some other organisation, and that such legitimate interests outweigh any adverse effect (if any) on you.

Should Guerlain rely on this exception, Guerlain may/will need to disclose your personal data that is being Processed in reliance on such exception, to third parties, whether located within or outside Singapore, for the purposes stated in this Section IV, and such third parties would be Processing your personal data for the purposes stated in this Section IV.

Your personal data is Processed by the personnel of Guerlain or Guerlain's agents or authorised third parties as set out below. We ensure that only authorised persons have access to your personal data when this is necessary for the purpose of managing our commercial relations or meeting our legal obligations, or for one or more of the Purposes.

Guerlain may/will need to disclose your personal data to third parties, whether located within or outside Singapore, for one or more of the Purposes. In this regard, you hereby acknowledge, agree and consent that we may/are permitted to disclose your personal data to such third parties for one or more of the Purposes (including the cross-border transfer of your personal data for one or more of the Purposes) and for the said third parties to subsequently collect, use, disclose and/or Process your personal data for one or more of the above Purposes.

Without limiting the generality of the foregoing or of section III, such third parties include:

(a) our associated or affiliated organisations or related corporations, including but not limited to any Guerlain group entities (including other affiliates of Guerlain in France, Singapore or abroad) and our parent company and any other entities of the LVMH group (collectively, the "LVMH Group"), with some of these entities acting as data processors;
(b) agents, subcontractors and/or third party service providers, such as:
    (i) site hosting and maintenance service providers and the providers of our electronic personal data collection solutions at counters and in stores;
    (ii) payment service providers;
    (iii) anti-fraud service providers;
    (iv) logistic service providers;
    (v) marketing solution service providers;
    (vi) sales prospection and social network communication service providers;
    (vii) customer service providers;
    (viii) service providers for managing cosmetic vigilance alerts; and
    (ix) event organisation service providers;
(c) our professional advisers, such as auditors, lawyers, accountants and/or insurers;
(d) third parties with whom we enter into or may enter into any contractual or other arrangement in relation to the products or services to be provided to you, or in relation to a Transaction;
(e) third parties to whom disclosure by Guerlain is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes; and
(f) third parties wishing to know your interests so that they can build up similar audiences and target prospects corresponding to your profile. In the context of this specific processing, these partners may re-use the personal data made available to them to be able to carry out autonomous and distinct targeting for commercial prospecting purposes, for which they are responsible, and are responsible for their legal and regulatory obligations.

For the avoidance of doubt, without prejudice to the generality of the foregoing, Guerlain may also 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.

Because Guerlain operates in many countries around the world and in order to provide you with personalized services worldwide, some of your data may be collected, accessed or stored outside your country of residence.

You should be aware that data protection and security requirements differ from place to place and may not provide the same level of protection as in your home country. Nevertheless, any transfer of personal data out of Singapore will be in compliance with the requirements of the PDPA. You are informed that your data may be transferred for one or more of the Purposes mentioned in section III above to third parties located in countries outside Singapore. Prior to any transfer of personal data outside of Singapore, Guerlain will take all necessary measures and guarantees to secure such transfers, in compliance with the PDPA.

Data may also be processed by staff operating outside Singapore who work for us or for one of our service providers.

We may retain your personal data for as long as it is necessary to fulfil the Purpose(s) for which it was collected, or as required or permitted by applicable laws.

We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, including but not limited to legal, tax and/or audit purposes and one or more of the Purposes set out in section III above.

When we no longer need to use your personal data, it is deleted from our systems and our registers or made anonymous so that it can no longer be identified, subject to retention for archival purposes. claims and litigation management as well as to meet our business or legal needs and/or regulatory obligations and/or to respond to requests from authorities authorized to make the request.

Guerlain has implemented physical, technical, administrative and operational safeguards that are designed to protect your personal data from and against loss, misuse, alteration, destruction and unauthorized access. The safeguards are updated from time to time in order to ensure that your data remains adequately protected, such as in relation to new threats and risks, and to address new requirements, standards and technologies. We require our partners and group companies to maintain a similar level of protection for your personal data as we do.

You should be aware, however, that no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

(a) Request for Access. You have the right to access the personal data that we hold about you, subject to exceptions under applicable law. If you wish to make an access request for access to a copy of the personal data which we hold about you and information about the ways in which we use or disclose your personal data, you are welcome to contact us through the contact details listed at section X below.

(b) Request for Withdrawal. The consent that you provide for the Processing of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw your consent to the Processing of your personal data in our possession or under our control by contacting us at through the contact details listed in section X below.

We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request, unless an exception under the law or a provision in the law permits us to. However, please take note that your above withdrawal of consent could result in certain legal consequences arising, including us being unable to perform the transactions requested by you or the termination of your relationship with us, as the case may be. Please also note that withdrawing consent does not affect our right to continue to Process your personal data where such collection, use and disclose without consent is required or authorised under applicable laws.

(c) Request for Update/Correction. We take reasonable steps to ensure that any personal data we collect, disclose and use is accurate and complete, if your personal data is likely to be used by us to make a decision that affects you, or disclosed to another organisation. However, it is important that you advise us of any changes to your personal data or if there are any errors in the personal data we hold about you. You are welcome to contact us through the contact details listed at Section X below to update us if there are any changes to your personal data.

(d) Marketing Communications. 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 mail we send you or by contacting us through the contact details listed at section X below. You can also request to receive non-personalized communications about our products and services.

Please contact us at the contact details listed in section X below to exercise these rights or if you have any other questions or complaints regarding the processing of your personal data.

We will use our reasonable commercial endeavors to respond to any of your requests as soon as reasonably practicable. Should we be unable to respond to your request within 30 days after receiving such request, we will inform you. If we are unable to provide you with any personal data or to make a correction requested by you, we will use our reasonable commercial efforts to inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA or in our reasonable view, those reasons contain or pertain to confidential information or business secrets of the Company and/ or the LVMH Group)

For all questions relating to the collection and processing of your data by Guerlain, you can contact the Guerlain Data Protection Officer at privacy@sg.lvmh-pc.com.