Clinique E-LEARNING PRIVACY AND COOKIE POLICY 

 

Effective Date:  August 16, 2018

 

We at Clinique Labs, LLC and your local Estée Lauder affiliate (collectively referred to herein as “Clinique” “we”, “us”, or “our”) respect your concerns about privacy and value the relationship we have with you. Your use of the Clinique eLearning site or mobile application (“Site”) is subject to this Privacy Policy and our Terms and Conditions .

 

This Privacy Policy describes the types of personal information we collect about you, how we use this information, with whom we share it, and your rights regarding our use of the information.  We also describe the measures we take to protect the security of the information, how long we retain it and how you can contact us about our privacy practices and how to exercise your rights. 

 

Click on one of the links below to jump to the listed section:

 

  • Information We Collect
    • How We Use the Information
    • Information We Collect by Automated Means
      • Technologies We Use
        • Internal Cookies Essential for the Site to Work
        • Third Party Web Analytics Cookies
        • How We Use the Information Collected by Automated Means
        • California Do Not Track Notice
  • Information We Share
  • Your Rights And Choices
  • Data Transfers
  • Data Retention
  • How We Protect Personal information
  • Links To Other Websites
  • Updates To Our Privacy Policy
  • How To Contact Us

 

Information We Collect

 

We may obtain personal information about you from various sources such as directly from you, from our HR system or personnel, or from our retail partners. When you visit this Site, we also collect certain information about your device or usage by automated means, including using technologies such as cookies, web server logs and web beacons.

 

The types of personal information we may collect includes: 

  • Name
  • Employee Number
  • Business and Personal Contact Information (such as email address and mailing address)
  • Information about your position (such as your job title, country/region/market, retailer, store, and your managers/supervisors)
  • Username and password, nickname/screen name
  • User profile photo
  • Information or content you provide (such as survey/quiz responses and comments)

 

How We Use the Information

 

We will use the information we collect to:

  • Provide education and training services to you
  • Create and manage your account on the Site and operate features on our Site
  • Respond to your inquiries
  • Operate and communicate with you about the Site
  • Operate, evaluate and improve our business and the Site (including developing new products and services; enhancing and improving our services, managing our communications; analyzing the Site; performing data analytics; and performing accounting, auditing and other internal functions)
  • Comply with applicable legal requirements, relevant industry standards and our policies

 

We also may use the information in other ways for which we provide specific notice at the time of collection.  

 

Information We Collect by Automated Means

 

When you visit this Site, we also collect certain information about your usage or device by automated means or by using technologies such as cookies, web server logs and web beacons. For example, if you use one of our mobile applications, we may collect your IP address, your unique device identifier (or other device identifier) and/or geo-location data in order to offer you certain features or functionalities within that mobile application. As set forth in more detail below, we may also collect information about your usage and browsing habits using various web-based technologies.

 

For your convenience, our Site may also include functionality that allows you to remain logged in so that you do not have to reenter a password each time you want to access the Site.  IF YOU CHOOSE TO REMAIN LOGGED IN, YOU SHOULD BE AWARE THAT ANYONE WITH ACCESS TO YOUR DEVICE WILL BE ABLE TO ACCESS AND MAKE CHANGES TO YOUR ACCOUNT.  For that reason, if you choose to remain logged in on a mobile device, we strongly recommend you enable the Passcode Lock security feature on your mobile device to protect against unauthorized access to and use of your mobile device and your account in the application.

 

Technologies We Use

 

Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser.  Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies.

 

The following types of cookies are set on this Site.

           

Internal Cookies Essential for the Site to Work

 

We use first-party cookies to help the Site work in the best possible manner.  You can opt out of receiving these cookies and disable them by adjusting your browser settings.  Please note, however, that without these cookies, your user experience may be impacted.

 

In conjunction with obtaining information through cookies, our web servers may log details such as your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone in which your device is located.  The web server logs also may record information such as the address of the web page that linked you to our Site and the IP address of the device you use to connect to the Internet. 

 

To control which web servers collect this information, we may place tags on our web pages called “web beacons.”  These are computer instructions that link web pages to particular web servers and their cookies.           

 

Third Party Web Analytics Cookies

 

We may use third party web analytics services on this Site, such as Google Analytics.  The service providers that administer these services use technologies such as cookies, web server logs and web beacons to collect information (such as IP address) and use that information to help us analyze how visitors use the Site.  These vendors may use cookies placed on this Site (such as the Google Analytics cookie) and cookies placed on third-party web sites (such as Google advertising cookies), or other third-party identifiers, together, to analyze our Site visitors. 

 

To learn more about web analytics services, and to disable Google Analytics, please download the browser add-on for the deactivation of Google Analytics provided by Google at http://tools.google.com/dlpage/gaoptout?hl=en.  To learn more about privacy and Google Analytics please consult the Google Analytics overview provided by Google at: http://www.google.com/intl/en/analytics/privacyoverview.html.

 

How We Use the Information Collected by Automated Means

 

We may use the information collected through automated means on this site to deliver personalized content, to improve the Site, for data analytics, for system administration purposes, such as to determine whether you’ve visited us before or are new to the Site, for compliance with our legal obligations, policies and procedures, including compliance with relevant industry standards and the enforcement of our Terms and Conditions. We also may use the information in other ways for which specific notice is provided at the time of collection.

 

California Do Not Track Notice

 

Under California law, website and online service operators are required to disclose how they respond to web browser “do not track” signals or other similar mechanisms that provide individuals the ability to exercise choice regarding the collection of personal information about an individual’s online activities over time and across third party websites. We currently do not change our tracking practices in response to “do-not- track” signals or other similar mechanisms. California law also requires website and online service operators to disclose whether third parties may collect personal information about their users’ online activities over time and across different sites when the users use the operator’s website or service. Third parties that have content or services on the Site such as a social feature, analytics service, or an advertising network partner, may obtain information about your browsing or usage habits but this information does not include personal information. These third parties do not change their tracking practices in response to “do-not- track” signals from your web browser and we do not obligate these parties to honor “do-not- track” signals. To learn more about browser tracking signals and “Do Not Track,” please visit http://allaboutdnt.org.

 

Information We Share 

 

We do not rent lists, sell or otherwise disclose personal information we collect about you, except as described here.  We may share your personal information with:

  • Our corporate affiliates for the purposes described in this Privacy Policy.  For additional information regarding our corporate affiliates, please see: http://elcompanies.com.
  • Service providers who perform services on our behalf based on our instructions.  We have contractually bound these service providers to appropriate information security and confidentiality requirements in accordance with applicable laws.  Examples of these service providers include entities that provide web hosting services. 
  • Other third parties with your consent.  

 

In addition, we and our affiliates and service providers may disclose information about you (i) if we are required or permitted to do so by law or legal process, (ii) to law enforcement authorities or other government officials, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.

 

We also reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets.  Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with our Privacy Policy.  Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information. 

 

Your Rights and Choices

 

We offer you certain rights and choices in connection with the personal information we collect from you.  To update your preferences or submit a request, please contact us as specified below. 

 

  • Geo-Location Information

 

When you use one of our mobile applications, we may ask you for your geo-location. You may choose not to share your geo-location details by adjusting your mobile device’s location services settings. To decline from sharing your geo-location details, follow the instructions on your mobile device on changing the relevant settings; otherwise, please contact your service provider or device manufacturer.

 

  • Withdrawing Consent

You may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your personal information.  We will apply your preferences going forward within a reasonable amount of time.  In some circumstances, withdrawing your consent to our use or disclosure of your personal information will mean that you cannot take advantage of some of our products or services. 

  • Reviewing, Updating or Deleting Personal information

 

If you would like to update your contact information or preferences, you may do so by accessing the “My Dashboard” tab in the Site.  You may also delete your account for the Site at any time by e-mailing your local Sales and Education Manager.

 

You have the right to request access to your personal information.  Any request will be dealt with as required by applicable law.  If your personal information is incorrect, inaccurate or outdated, you may request that it be corrected and we will correct or update such inaccurate personal information in accordance with applicable law and within a reasonable period of time following your request. 

 

  • Push Notifications and In-Application Alerts and Updates

 

We may provide you with the option to opt in to receive push notifications on your mobile device in connection with a mobile application. You may, after downloading the mobile application, opt out of receiving push notifications by adjusting the settings on your mobile device. Opting out of push notifications will not affect other communications you receive from us, such as email communications. You also may receive alerts and updates within our mobile applications. To opt out of receiving these alerts and updates, you may uninstall the applicable application from your mobile device.

Data Transfers   

 

Our affiliates and service providers may be located outside your country of residence (such as the United States) and your personal information may be subject to applicable foreign laws.  We will take all necessary steps to comply with applicable privacy laws, in particular with any legal requirements on data transfers.

 

Data Retention

 

We will keep your personal information for the purposes set out in this Privacy Policy, plus a reasonable period of time thereafter or such other time as may be required or permitted by applicable law.

How We Protect Personal information

 

We maintain appropriate technical, physical and organizational safeguards designed to ensure an appropriate level of security of your personal information, in particular to protect your personal information against accidental unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

 

Links To Other Websites

 

Our website may provide links to other websites for your convenience and information.  These websites may operate independently from us.  Linked sites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked websites.  To the extent any linked websites you visit are not owned or controlled by us, we are not responsible for the sites’ content, any use of the sites, or the privacy practices of the sites.

 

Updates To Our Privacy Policy

 

This Privacy Policy may be updated periodically to reflect changes in our privacy practices.  We will notify you of any significant changes to our Privacy Policy and indicate at the top of the Policy when it was most recently updated.

How To Contact Us

If you have any questions, comments or complaints about this Privacy Policy or about how we or our service providers treat your personal information, please contact us by email at privacy@estee.com

 


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