Effective Date: June 6, 2019

AVEDA PUREPRO WEBSITE PRIVACY POLICY

We at the Aveda Corporation (“Aveda”) and its affiliates respect your privacy and value the relationship we have with you. Your visit to this website, located at https://www.avedapurepro.com (the “Site”) is subject to this Privacy Policy and our Terms and Conditions.

This Privacy Policy describes the types of personal information we collect through the Site, how we may use that information, with whom we may share it, and the choices available to you regarding the use of the information. Our Privacy Policy also describes the measures we take to protect the security of this information as well as how you may reach us to ask us any questions you may have about our use of your personal information.

Please note that this Privacy Policy governs only information that you provide to us at the Site. It does not govern any other information or communications that may reference Aveda, e.g., communications from Aveda Online or Aveda retail stores.

Information We Collect

Use of the Site is entirely voluntary. If you register to use the Site, you will be required to provide certain information such as your work or personal email address, name, a username and a password that you create, location and business type (e.g. Salon or Spa), and job title or function.

You may choose to provide other information to us in a number of ways through the Site. The types of information we may collect through the Site includes any other content you may provide (such as photographs, videos, reviews, and comments).

If you would prefer that we do not collect any personal information from you, please do not register to use the Site or provide us with any such information. If you do not provide us with your personal information, you will not be able to register for an account. Information we collect during the registration process may be displayed to other registered users of the Site as part of your user profile.

Use of Personal Information

We may use the information you provide to:

Provide services to you
Create and manage your online account
Send you promotional materials or other communications if you so elect
Create a profile about you based on the information you provided us in order to tailor our advertisements to your interests and manage the effectiveness of our marketing efforts
Tailor ads displayed to you on our site and elsewhere based on your interests and history with us
Operate and communicate with you about the Site
Respond to your inquiries
Operate, evaluate and improve our training programs and other aspects of the business (including developing new products and 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 collect certain information about your usage or device by automated means or by using technologies such as cookies, web server logs and web beacons. We may also collect information about your usage and browsing habits using various web-based technologies.

TECHNOLOGIES WE USE

Cookies, Web Server Logs and Web Beacons

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. Please note, however, that without cookies you may not be able to use all of the features of the Site.

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.

How can you manage your cookies?

You have the right to choose whether or not to accept cookies used for certain purposes on the Site. You can opt out of receiving these cookies and disable them as indicated below. Please note, however, that without these cookies, your user experience may be impacted.

Most browsers accept cookies by default. You may also be able to change the settings to have your browser refuse certain cookies or notify you before accepting cookies. The procedures for changing your settings and cookies differ from browser to browser. If necessary, use the help function on your browser or click on one of the links below to go directly to the user manual for your browser.

To find out more about cookies, visit www.allaboutcookies.org.

Third Party Web Analytics Services

We may use third party web analytics services on this Site, such as those Google Analytics. The service providers that administer these services may use technologies such as cookies, web server logs and web beacons to help us analyze how visitors use the Site. The information collected through these means (including IP address) is disclosed to these service providers, who use the information to evaluate use of the Site. To disable the Google Analytics cookie, some browsers indicate when a cookie is being sent and allow you to decline cookies on a case-by-case basis.

How We Use the Information Collected by Automated Means

We may use the information collected on the Site through automated means for market research, data analytics and system administration purposes, such as to determine whether you’ve visited us before or are new to the Site, and 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 consumers the ability to exercise choice regarding the collection of personal information about a consumer’s online activities over time and across third party websites, to the extent the operator engages in that collection. At this time, we do not track personal information over time and across third party websites and therefore this requirement does not apply to us.

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 our 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. We do not knowingly permit such third parties to collect any personal information from our Site unless you directly provide it to us and we provide it to them with your consent.

Information We Share

We do not sell or otherwise disclose personal information about our Site visitors except as described here. We may share your personal information with:

Our corporate affiliates. For additional information regarding our corporate affiliates please see https://www.elcompanies.com/en/our-brands.

Service providers who perform services on our behalf based on our instructions. We do not authorize these service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. Examples of these service providers include entities that provide web hosting services.

Other third parties with your consent.

In addition, we, our affiliates and service providers in the US and other jurisdictions may disclose information about you (i) if we are required 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 choices in connection with the personal information we collect from you, such as how we use the information and how we communicate with you.

You may choose whether or not you would like to access the Site. You may delete your account for the Site at any time by e-mailing us at purepro@aveda.com.

Email Opt-Out

You can at any time tell us not to send you Aveda Pure Pro marketing emails by clicking on the unsubscribe link within the marketing emails you receive from us or by emailing us at purepro@aveda.com with your request.

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.

Reviewing, Updating and Modifying Personal Information

Subject to applicable law, you may have the right to request access to and receive details about the personal information we maintain about you, update and correct inaccuracies in your personal data, and have the information blocked or deleted, as appropriate. The right to access personal information may be limited in some circumstances by local law requirements. You may request to review, change or delete your personal information by sending an email to purepro@aveda.com.

Data Transfers

We may transfer the personal information we collect about you to countries other than the country in which the information was originally collected and your personal information may be processed and stored outside of your country of residence. Those countries may not have the same data protection laws as your country of residence and your personal information will be subject to applicable foreign laws. When we transfer your information to other countries, we will protect that information in the manner described in this Privacy Policy.

How We Protect Personal Information

We maintain appropriate administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, no security system is perfect and we cannot promise that information about you will remain secure in all circumstances, including the security of your data during transmission to us or the security of data on your mobile device.

Links to Other Websites

The Site 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 and without prior notice to you to reflect changes in our personal information practices. We will post a prominent notice on our website to 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 or comments about this Privacy Policy, would like to make a complaint about our handling of your personal information, or if you would like us to update information we have about you or your preferences, please contact us by email at purepro@aveda.com. We will respond to any complaint or request about our handling of your personal information in writing. If you are not satisfied with our response, you may contact your regulator.

For Residents of the EEA:

If you are a resident of the European Economic Area (“EEA”), the following additional EEA-specific provisions also apply to you:

Relevant Data Controller: The Data controller/s for the purpose of the Site:

Country	Data Controller
Austria	Estee Lauder Cosmetics GmbH Izd Tower - 20. Stock 20th Floor Wagramerstrasse 19 A-1220 Vienna, Austria
Belgium	Estee Lauder Cosmetics S.A./N.V. Airport Plaza – Kyoto Building Leonardo Da Vincilaan 19 1831 Diegem, Belgium
Czech Republic	Estée Lauder CZ, S.R. O. Ovocny Trh 2 110 00 Praha 1 Czech Republic
Denmark	Estée Lauder Cosmetics A/S Delta Park 37, 2 floor DK-2665 Vallensbaek Strand – Denmark
Finland	Estee Lauder Finland Oy Moveres Business Park Kutomotie 2 00380 Helsinki, Finland
France	ELCO SAS 48 Rue Cambon 75001 Paris, France
Germany	Estee Lauder Companies GmbH Domagkstrasse 10 D-80807 Munich, Germany
Greece	Estée Lauder Hellas S. A. Tzavella 67 & Messoghion Ave. Halandri GR-152 31 Athens, Greece
Hungary	Estee Lauder Kereskedelmi KFT Október Huszonharmadika u 8-10 Budapest, 1117, Hungary
Italy	Estee Lauder S.r.l. Via Turati, 3 Milano 20121, Italy
The Netherlands	Estee Lauder B.V. Safariweg 50 3605 MA Maarssen The Netherlands
Poland	Estee Lauder Sp.Zo.O Ul. Postepu 21 B 02-676 Warszawa, Poland
Portugal	Socosmet, Sociedade de Cosmetica, Lda. Amoreiras Square Rua Prof Carlos Alberto Mota Pinto 17-3A 1099-094 Lisbon – Portugal
Romania	Estee Lauder Romania S.R.L. 33 Arh. Mincu Ion Street Sector 1 Bucharest, Romania
Spain	Estee Lauder S.A. Poligono Industrial Las Mercedes C/Nanclares De Oca, 3 28022 Madrid, Spain
Switzerland	Estee Lauder GmbH Hardturmstrasse 11/ Puls5 Postfach 1727 Ch-8031 Zurich, Switzerland
United Kingdom & Ireland	Estée Lauder Cosmetics Limited One Fitzroy 6 Mortimer Street London W1T 3JJ – England

Legal basis for our use of the information. We will use the information you provide for the above purposes if:

it is necessary to perform a contract to which you are party (e.g., to process your payment and deliver the products you have ordered); or
we have obtained your consent; or if
we have a legitimate interest to do so (including a legitimate interest in performing marketing activities, research activities, data analytics, and internal administration functions, processing and enforcing legal claims, and conducting our business in compliance with all applicable laws, relevant industry standards and our policies).

Retention Period: We will retain your personal data as long as needed to fulfill the purposes indicated in this Privacy Policy and in any event no longer than permitted by applicable law.

Transfers of your personal information outside the EEA: Your personal information may be stored and processed in any country where Aveda Corporation or The Estee Lauder Companies Inc. has its subsidiaries and affiliates worldwide, as well as any of their subcontractors/processors in relation to such activities, either within or outside of your country of origin and/or the European Economic Area. These countries may not have the same data protections laws as the country in which you initially provided the information. When we transfer your information to other countries, we will protect that information with appropriate safeguards such as, for instance, the EU standard contractual clauses. For additional information please contact us at purepro@aveda.com.

Your rights and choices: You may withdraw any consent you previously provided to us, exercise your right of access, data portability, rectification, erasure of your personal data, object to the processing of your personal information or request us to restrict it by contacting us at . We will apply your preferences going forward. You also have the right to lodge a complaint with a supervisory authority.