We may collect your personal data when you:

• create a customer account on our website, apps, or in our stores;
• make purchases in stores;
• agree to receive personalized communications from us by email, SMS or post, depending on your selection;
• answer surveys or satisfaction questionnaires based on your customer experience;
• mention of our products on social networks or provide feedback;
• interact with our Maison 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 Maison;
• take part in an event we organize;
• browse on the Internet using cookies or similar technology or when you click on advertisements for our products;
• take an appointment online using our online booking.
   

(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, mailing address and/or your phone number);
• Your personal preferences in relation to our products or use of our website;
• Interest in our products and services;
• Information you may provide for our customer service team;
• Your feedback about Guerlain and our products via social media;
• Your publications/mentions relating to our products on social networks;
• Specific health data if you notify us of any undesirable side-effects regarding any of our products.

Personal data essential to Guerlain 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, Guerlain 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) As well, 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 our cookie policy, here.
 

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 website, applications and at our counters and in our stores;
(c)    manage your access to your customer account on the Internet or our applications;
(d)    manage customer relations with respect to any requests for information or complaints you may send us via our website or customer service.
(e)    administering, facilitating, managing, processing and/or dealing with your relationship with us, activities carried out by you on the Website or at our premises/establishments or with us, your requests, including but not limited to dealing with your adhoc queries or requests, dealing with your preferences, dealing with your membership needs. Without limiting the generality of the foregoing, should you make a reservation or 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, 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. Without limiting the generality of the foregoing, :
(g)    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;
(h)    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;  
(i)    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;
(j)    trace and manage any alerts you may send us as part of our cosmetic vigilance obligations;
(k)    manage and optimize your customer experience by improving our knowledge of our customers;
(l)    propose appropriate, tailored services, particularly when we enhance our products and services;
(m)    conduct statistical analyses to develop management, measuring and reporting tools in order to adjust and improve our sales, marketing and product manufacturing;
(n)    business improvement purposes such as to manage and optimise your customer experience by improving our knowledge of our customers, and/or to create a profile about you; 
(o)     manage your participation in any events to which you have signed up;
(p)    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 personalise your profile;
(q)    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;
(r)    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;
(s)    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;
(t)    storing, hosting, backing up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Singapore;
(u)    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;
(v)    maintaining and/or developing our IT or business systems and infrastructure including testing and upgrading of these systems;
(w)    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;
(x)    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;
(y)    Guerlain, Guerlain Group’s or a Guerlain Group entity’s reporting purposes including but not limited to reporting on Guerlain’s business performance; and
(z)    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.

(the purposes above set out in this section IV shall be collectively referred to as the “Purposes”)
In the latter interaction, when we send personalised 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 analyse or predict elements concerning the preferences, interests, behaviour, location of that natural person. In these circumstances, you have the right to withdraw your consent.   
 

Guerlain processes your personal information when you have given your consent for the processing of your data for the Purposes stated at Section IV above (such as  by your agreeing or consenting to this Privacy 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 :  

(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 V, and such third parties, would be processing your personal data for the purposes stated in this Section V.
 

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 above Purposes, as such third parties, would be processing your personal data for one or more of the above Purposes. In this regard, you hereby acknowledge, agree and consent that we may/are permitted to disclose your personal data to such third parties (whether located within or outside Singapore) for one or more of the above 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 IV, such third parties include :
 

(a)    any Guerlain Group entities including other affiliates of Guerlain in France or abroad; other entities of the LVMH Group with some of these entities acting as data processors;
(b)    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;
        ix. event organisation service providers;
(c)    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 the Transaction; and
(d)    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.

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

Because Guerlain operates in many countries around the world and in order to provide you with a personalised service worldwide, some of your data may be collected, accessed or stored outside your country of residence as described above.

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 the Purposes mentioned above to companies located in countries outside Singapore  . Prior to the transfer outside 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   .
 

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.

The legal retention periods defined by Guerlain respect the recommendations of the regulation(s) in force and the legal obligations to which Guerlain is subject.

In general, your personal data is kept in our database:
 

Data subject: Regular customer (i.e.: having a customer profile)
Duration: 5 years from the date of the first purchase or account creation
Specificity: This period will be renewed each time you interact with Guerlain (for example a purchase or an update of your profile) or your consent to continue to interact at the end of this period
 

Data subject: Prospect (i.e. never purchased products from Guerlain but registered for our communications)
Duration: 3 years from the date of data collection
Specificity: This period will be renewed each time you interact with Guerlain (e.g. participation in an event) or your consent to continue to interact at the end of this period


Data subject: Client ‘Guest’ (i.e. not having a client account)
Duration: 5 years from the date of first purchase
Specificity: This period will be renewed each time you interact with Guerlain (e.g. a purchase)


Data subject: customer care (i.e.: complaints or information)
Duration: duration of the processing of the request plus 5 years. For exercises of rights, under GDPR, the request is kept during its treatment plus 6 years


Data subject: cosmetovigilance
Duration: duration of the processing of the request plus 5 years
Specificity: These data are sensitive, they are stored with adequate security measures


Data subject: Privileged interlocutors (e.g. agents, stylists, journalist, celebrity managers, artists) in relation to Maison Guerlain Public Relations services
Duration: 10 years from the date of your first contact
Specificity: This period will be renewed each time you interact with Guerlain (for example a request for information on the Guerlain)

If cookies are placed on your computer, we keep them for a maximum of 6 months.

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 adopted the data protection and security practices described in this Privacy Policy for all individuals concerned. In addition, we have also identified and taken into account the data protection and security measures required at local or regional level to prevent unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage, and/or alteration of your personal data  . This includes, for example, those required for residents of the European Union / European Economic Area under the General EU Data Protection Regulation (GDPR) 2016/679 or under the PDPA. 
 

In particular, the PDA provides the following rights: 

• Right to information: you have the right to obtain clear, transparent and understandable information about how we use your personal data and about your rights. You will find all of this information in this Privacy Policy.
• Right of access: you have the right to access the personal data that Guerlain holds about you, subject to exceptions under the law.
• Right of rectification/correction: you have the right to have your personal data rectified/corrected if it is inaccurate or obsolete and / or to supplement it if it is incomplete.
• Right of opposition: you can at any time request to no longer receive our communications relating to our offers, news and events.   You can in particular use the hypertext link provided for this purpose in each email or communication that we send to you. You can also request to receive non-personalized communications about our products and services.
• Right to withdraw consent at any time for data processing based on consent: you can withdraw your consent relating to our processing of your data when this processing is based on consent.
• Right to data portability: Once this right has come into force under the PDPA, you have the right to move, copy or transfer data from our database to another, subject to the limits and in accordance with the requirements for such right as provided for under the PDPA. 

Further rights may arise in future under amendments to the PDPA and in such a case, we will accord you such rights as provided for by the PDPA.

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

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. 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  .

You can exercise these rights directly with Guerlain by sending an email to dpo@guerlain.fr or a non-registered letter by post to GUERLAIN – Service Relation Client: 391B Orchard Road #12 - Ngee Ann City Tower B – Singapore 238874. 
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. You can also contact us by email clientserviceth@guerlain.fr from 9am to 6pm, 5 days a week or by post at the following address: Service Relation Client 391B Orchard Road #12 - Ngee Ann City Tower B – Singapore 238874.
 

For all questions relating to the collection and processing of your data by Guerlain, you can contact the Guerlain Data Protection Officer at dpo@guerlain.fr