Privacy Policy

Tom Ford Beauty Label Scanning Augmented Reality Experience Privacy Policy

Effective Date: April 29, 2021

Estee Lauder Inc. d/b/a Tom Ford Beauty (referred to herein as “we”, “us”, or “our”) respects your concerns about privacy and values the relationship we have with you.  This Privacy Policy describes the types of personal information processed via this Label Scanning Augmented Reality Experience (the “TFB Experience”), how this information is used and the rights of customers regarding their personal information.

For the purposes of applicable data protection laws, the data controller responsible for the processing of your personal information is Estee Lauder, Inc. d/b/a Tom Ford Beauty.

This Privacy Policy applies only to the personal information collected when you access the TFB Experience for the purpose of enabling the TFB Experience to function and display properly on your device, and for analytics purposed. 

Your personal information will be retained for the duration of your use of the TFB Experience. In addition, certain information, such as when you access the TFB Experience and what you click on, will be retained in non-identifiable format for up to six (6) months for analytics purposes. 

We may transfer personal information to 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 The Endless Collective, Beaconstac and The 8^th Wall.

We maintain appropriate technical and organizational safeguards designed to ensure an appropriate level of security of your personal information. 

For any questions or requests to exercise rights which may apply to you under applicable law such as the right to access, update or delete your personal information, to withdraw your consent you previously provided to us, to data portability where technically feasible, or to object to the processing of your personal information, you can contact us at privacy@estee.com. Subject to applicable law, you may also lodge a complaint with a data protection authority.

ADDITIONAL RIGHTS AND DISCLOSURES FOR CALIFORNIA RESIDENTS

Information We Collect

We may collect and may have collected the following categories of information about you. In some cases, the information we collect may fall within more than one category.

· Identifiers, such as device ID, IP address, or other online identifiers. 

· Online or network activity information, such as information regarding your interaction with the TFB Experience, which includes, but may not be limited to, your device and browser type, your access to the TFB Experience, what you click on throughout the experience. 

How we Collect Information

We may collect or may have collected personal information as set forth above when you access the TFB Experience.

How We Use Information

We may use or may have used the information we have about you:

· To provide you with access to the TFB Experience and to ensure the it functions and displays correctly.

· For analytics purposes, such as to understand how you use the TFB Experience, determine what browser and device you use to access the TFB Experience.

Disclosures of Personal Information

We may disclose or may have disclosed your personal information to certain categories of third parties, as described below. 

Category	Disclosed to Third Parties
Identifiers	We may disclose or may have disclosed this information to: service providers
Online or network activity information	We may disclose or may have disclosed this information to: · service providers

The disclosure of personal information for which we receive valuable consideration (i.e., the receipt of some benefit other than money) is considered a “sale”.  We do not sell the personal information we collect through the TFB Experience.

Your California Privacy Rights

You have the right to request, twice in a twelve (12)-month period, that we disclose to you the personal information we have collected, used, disclosed, and sold about you during the past twelve (12) months. In addition, you have the right to request that we delete the personal information we have collected from you (subject to certain exceptions).

You can exercise your rights by sending an email to privacy@estee.com. Before processing your request, we will take reasonable steps to verify your identity, which will include verifying that the email address from which you submit the request matches the email address we maintain on file for you. In order to ensure you are the owner of the email address, you must respond to a confirmation email that we will send to such email address. In some cases, we may ask that you provide additional information in order to verify your identity.

You may also designate an authorized agent to make a request on your behalf. The authorized agent may submit the request by sending an email to privacy@estee.com and will be required to provide proof that they have been authorized to act on your behalf. If the authorized agent does not provide such proof, you will be required to confirm your identity and the authenticity of the request.

We will not discriminate against you on account of your exercise of your California privacy rights.