Privacy Policy

Data Privacy Statement

Latest update: October 2022                                                  

Artessence US, LLC.  (the “Company”, “we”, “us”, and “our”) has created this privacy statement to demonstrate our commitment to data privacy. Your right to data privacy and data security is a primary concern. This privacy statement sets out the basis on which any information we collect from you, or that is provided to us, will be processed by us.

Please find below further information regarding the ways in which we process your personal data and your rights in relation to such data processing.

• If you are a California resident, please refer to SECTION 1 - PRIVACY POLICY FOR CALIFORNIAN CUSTOMERS
• If you are a EU or UK resident please refer to SECTION 2 – PRIVACY POLICY FOR EU AND UK CUSTOMERS

 

SECTION 1 – PRIVACY POLICY FOR CALIFORNIAN CUSTOMERS

1. Information gathering and usage

• The personal information about you that we collect includes information within the below categories of data. These categories also represent the categories of personal information that we have collected over the past 12 months. Note that the categories listed below are defined by California state law. Inclusion of a category in the list below indicates only that, depending on the services and products we provide you, we may collect some information within that category. It does not necessarily mean that we collect all information listed in a particular category for all of our customers.
• For purposes of this policy, “Affiliates” shall refer to any parent, subsidiary, or other entity (including but not limited to any parent or subsidiary of any such parent, subsidiary or other entity) connected to the Company by common ownership and control, regardless of corporate form.

Category	Purpose of processing and the source that the data is collected from	Categories of Third Parties this information is disclosed to
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.	Source ·         Directly from you or your interactions with our information technology resources ·         Subscription to campaigns and promotions   Purpose ·         To provide and personalize services ·         To comply with regulations and law	·         Affiliates ·         Service providers
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, your name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.	Source ·         Directly from you or your interactions with our information technology resources ·         Subscription to campaigns and promotions   Purpose ·         To provide and personalize services ·         To comply with regulations and law	·         Affiliates ·         Service providers
Characteristics of classes protected under federal or California law, including: familial status, disability, sex, national origin, religion, color, race, sexual orientation, gender identity and gender expression, marital status, veteran status, medical condition, ancestry, source of income, age, or genetic information.
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Source ·         Directly from you or your interactions with our information technology resources ·         Subscription to campaigns and promotions   Purpose ·         To provide and personalize services ·         To comply with regulations and law	·         Affiliates ·         Service providers
Biometric information.	Source ·         Directly from you or your interactions with our information technology resources ·         Subscription to campaigns and promotions   Purpose ·         To provide and personalize services ·         To comply with regulations and law ·         To promote products and services	·         Affiliates ·         Service providers
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.	Source ·         Directly from you or your interactions with our information technology resources, typically through web forms, cookies, and other technology   Purpose ·         To provide and personalize services ·         To collect information about your usage of products and services, and preferences ·         To comply with regulations and law ·         To promote products and services	·         Affiliates ·         Service providers
Geolocation data.	Source ·         Directly from you or your interactions with our information technology resources ·         You, typically through web forms, cookies, and other technology ·         Subscription to campaigns and promotions   Purpose ·         To provide and personalize services ·         To comply with regulations and law ·         To promote products and services	·         Affiliates
Audio, electronic, visual, thermal, olfactory, or similar information.	Source ·         Directly from you or your interactions with our information technology resources ·         Subscription to campaigns and promotions   Purpose ·         To promote products and services	·         Affiliates ·         Service providers
Professional or employment-related information.
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).
Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Source ·         Directly from you or your interactions with our information technology resource, typically through web forms, cookies, and other technology ·         Subscription to campaigns and promotions   Purpose ·         To provide and personalize services ·         To comply with regulations and law ·         To promote products and services	·         Affiliates ·         Service providers

• We also collect the below categories of sensitive personal information as defined by the California Privacy Rights Act. These categories also represent the categories of sensitive personal data that we have collected over the past 12 months. We only collect and use sensitive personal information where necessary to process your application for employment or to carry out your employment contract or as required under state and federal law. As with the chart above, the categories listed below are defined by California state law.

Category of Sensitive Personal Data	Purpose of processing and the source that the data is collected from	Categories of Third Parties this information is disclosed to
Social security, driver’s license, state identification card, or passport number.	Source ·         You   Purpose ·         To provide services ·         To comply with regulations and law	·         Affiliates ·         Service providers
Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.	Source ·         You   Purpose ·         To provide services ·         To comply with regulations and law	·         Affiliates ·         Service providers
Precise geolocation.	Source ·         Directly from you or your interactions with our information technology resources   Purpose ·         To provide services ·         To comply with regulations and law	·         Affiliates ·         Service providers
Racial or ethnic origin, religious or philosophical beliefs, or union membership.
Mail, email, and text messages contents (except where we are the intended recipient of the communication).
Genetic data.
Biometric data processed for the purposes of uniquely identifying you.
Personal information collected and analyzed concerning your health.
Personal information collected and analyzed concerning your sex life or sexual orientation.

 

2. Sales and sharing of personal information

• For purposes of the CCPA, we do not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age. We also do not “share” personal information for cross-contextual behavioral advertising.

 

3. Do not track

• Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted through web browsers.

 

4. Your rights

• Under the California Consumer Privacy Act (as modified by the California Privacy Rights Act), our customers who are California residents have the following rights:
  • The right to request deletion of the personal information we have on them
  • The right to correct inaccurate personal information we have on them
  • The right to know what personal information is being collected about them
  • The right to know whether their personal information is sold or shared and to whom
  • The right to opt out of the sale or sharing of their personal information
  • The right to limit the use and disclosure of their sensitive personal information
  • The right to not be retaliated against for requesting an opt-out or otherwise exercising their rights
• If you are a California resident and would like to make such a request, please submit the request through our webform, or contact us via the methods indicated below.
• Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a request to exercise you privacy rights. You may also make a request on behalf of your minor child. If you would like to appoint an authorized agent to make a request on your behalf, you must provide the agent with written, signed permission to submit privacy right requests on your behalf, or provide a letter from your attorney. The agent or attorney must provide this authorization at the time of request. We may require you to verify your identity with us directly before we provide any requested information to your authorized agent.
• Verification
  • For some personal information requests, we may need to verify your identity before fulfilling your request. To verify your identity, we will collect information from you, including, to the extent applicable, your name, government identification number, date of birth, contact information, your account information, answers to security questions, or other personal identifying information. We will match this information against information we have previously collected about you or against information available from consumer reports to verify your identity and to respond to your request. Information collected for purposes of verifying your request will only be used for verification and to respond to your personal information request.
  • If you maintain an account with us, we may require you to login to that account as part of submitting your request. If we are unable to verify your identity as part of your request, we will not be able to satisfy your request. For deletion requests, you will be required to submit a verifiable request for deletion and then to confirm separately that you want personal information about you deleted.
  • If you would like to appoint an authorized agent to make a request on your behalf, and that agent is not already authorized to access your account in your profile, we require you to verify your identity with us directly before we provide any requested information to your approved agent.

•  Accessibility. This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.

 

5. Security

• Security measures
• We limit access to personal data that we collect about you to our employees and third-party agents, who we reasonably believe need to have access to your information to provide you with the information or services you request from us. We have security measures in place to help protect against the loss, misuse and alteration of the information under our control. While we cannot guarantee that loss, misuse or alteration to data will not occur, we ensure that our systems adhere to market security standard so as to help safeguard against such occurrences.
• Where information is provided to us via our website, in certain areas the information passed between your browser and our system is encrypted with secure sockets layer (“SSL”) technology to create a protected connection between you and our Site to ensure confidentiality. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. We will use commercially acceptable means to protect your personal data, but we cannot guarantee its absolute security. If you have any questions about our security, you can email us.
• Children’s privacy protection
• The Company does not target and its websites are not intended for children under the age of 16. The Company will not knowingly collect personal data from children, and will delete such data upon discovery. Where the Company requires personal data pertaining to children for the purpose of providing a service, the consent of an adult with parental responsibility for that child will be required.

 

6. Opting out

• If you do not wish to receive certain communications from us you may opt out by: (1) declining the service offered or (2) informing us that you no longer wish to receive such communications. We will comply with such requests unless such communications from us are required by law or do not require your consent under applicable laws. Your opting out may restrict our ability to provide you with the full extent of our services.

 

7. Cookies

• When you visit our website(s), we use so-called “cookies” to make our website(s) more user-friendly, effective, and secure. A cookie is a small piece of data sent from a website and stored in a file on your browser. A cookie is useful for having the browser remember specific information across several pages or between visits to a website. In addition to cookies, we use scripting, which is code run on the website to collect information such as actions you’ve completed on our website or items you click on. We also use “pixels,” which are transparent image files sent from the website to your browser to help us record items like IP address and time. For the purposes of this Policy, we refer to all these technologies as “cookies.”
• We do not store any sensitive information within your cookies. Our website(s) does not read any information stored in cookies given to you from other websites, except in rare cases where the other website is a provider of information or functionality within our website and that cookie is necessary to make our website function correctly.
• Most of the cookies we use are “session cookies” which are automatically deleted as soon as you leave the site. Other cookies, so-called “persistent cookies,” remain on your computer until you delete them. Using these cookies allow us to enhance your experience in interacting with our website, such as by helping recognize your browser the next time you visit and loading previously viewed pages faster. We use cookies to offer you the best possible experience on our website.
• We also use cookies to collect browsing information in order to improve your overall experience. We use this information to track website usage and compile statistics. This helps us improve the website, so you will find it more useful and informative, and enable customized promotions you may be interested in. We may use the combination of data we collect, such as browsing information and email address, to join known devices together and provide you personalized experiences on the device you are currently using. Impression data from cookies, which indicates who has seen advertisements about our products and services on our website or third-party websites, may be used to improve our marketing practices. If you are a current customer, have logged into your account, obtain a policy from our website or provide your email address, we may use analytics software to link data we collect, such as use of our website, opening emails we send you or contacting our customer service center via phone, back to you.
• We may use browsing information we collect (including IP address, email address and data received from Google Analytics) to match with information received from third parties (including behavioral information and device identifiers) and user information to learn more about an individual or a group. These actions help us analyze interactions with our website, improve marketing efforts, inform our strategic approach and improve your experience. We also may use this information to directly market our products and services, to the extent permitted by law. We may use third parties to perform these and other activities.
• You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it. Browsers may also be set up to display a warning when a cookie is used. You may even disable your browser from accepting cookies. Disabling cookies is unique to each browser and device you use. Disabling cookies on one device will restrict the ability to tie that device to other devices you use. Parts of our website may not function properly if you disable cookies. To provide you with the best possible experience while visiting our website, please enable cookies within your browser.
• We also enable cookies to be placed or accessed on your device by third party advertising networks. These kinds of persistent cookies remember the websites you visit, and that information is shared with other parties, such as advertisers. We may use third-party advertising networks to help us deliver tailored online ads to you. To learn more about opting-out of this type of interest-based advertising, please visit the

 

8. Limit the use of cookies

• You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it. Browsers may also be set up to display a warning when a cookie is used. You can also disable your browser from accepting cookies and delete cookies that have previously been placed on your device. Disabling and deleting cookies is unique to each browser and device you use. Disabling and deleting cookies on one device will restrict the ability to tie that device to other devices you use. Instructions for deleting and disabling cookies are available from the providers of most widely used internet browsers. Parts of our website may not function properly if you disable cookies. To provide you with the best possible experience while visiting our website, please enable cookies within your browser.

 

9. Linking to third parties

• When you leave this website and go to another linked website, we are not responsible for the content or availability of the linked website. Please be advised that if you enter into a transaction on the third-party website, we do not represent either the third party or you. Further, the privacy and security policies of the linked website may differ from those practiced by us.

 

10. Contact details

• If you would like to get in touch with us with regards to your personal data or if you are a California resident who wishes to exercise your privacy rights, please contact us at:
  Email: boutique@initioparfums.com

 

11. Changes in this privacy statement

• Any changes we make to this privacy statement in the future will be [posted on this page]. We reserve the right to modify this privacy statement at any time.
• If we make material changes to this policy, we will notify you by email, or by means of a notice on our website home page.
• This website is based and administered in the United States of America. The website is governed by the laws of the United States and is not directed at users based outside of the United States.

 

 

SECTION 2 – PRIVACY POLICY FOR EU AND UK CUSTOMERS

Customer Privacy Notice

Last update: October 2022

 

1. Introduction

• This Privacy Notice (together with our terms and conditions and any other documents referred to in it) describes the type of information that we collect from you ("you/your") when you purchase a product or service from us ("Products") from an EU country or from the UK, or the use of our website: initioparfums.com the "Website", how that information may be used or disclosed by us and the safeguards we use to protect it.
• Our Website may contain links to third party websites that are not covered by this Privacy Notice. We are unable to accept responsibility for any Personal Data you may share on those third party websites. We therefore ask you to review the privacy statements of other websites and applications to understand how and why they process any of your Personal Data.
• This Privacy Notice may be updated from time to time, and the latest version will always be available on our Website. We will notify you if we make any substantial changes to this Privacy Notice.
• It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us. If you have any comments or question on this Privacy Notice, please email:
• for UK Website users: boutique@initioparfums.com
• for EU Website users: boutique@initioparfums.com

 

2. Definitions

• “Personal Data” refers to all kinds of information recorded electronically or otherwise that can be used to independently or, by the combination with other information, identify an individual’s identity or recognize an individual’s activities. This can include name, date of birth, residential address, email address, financial information, IP addresses, location data, aliases, preferences and profiles, amongst other things.

• “Special Category Personal Data” or “Sensitive Personal Data” refers to any Personal Data relating or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership or a person or any genetic data, biometric data used to identify a natural person, or information concerning health or a natural person’s sex life or sexual orientation.

• “Criminal Records Data” means anyPersonal Data relating to criminal convictions and offences or related security measures.

• The term “process” or “processing” means any activity relating to Personal Data, including, by way of example, collection, storage, use, consultation, disclosure, destruction and/or transmission.

• “Automated Decision Making” means any decision based solely on automated processing (i.e. not involving any human interaction), including profiling, which produces legal effects concerning the Data Subject or similarly significantly affects him or her or them.

• Artessence US, LLC with whom you are interacting with, including making purchases from, is a Controller of your Personal Data. This is a legal term – it means that it make decisions about how and why it is processing your Personal Data and, because of this, it is responsible for making sure it is used in accordance with the applicable data protection laws. In limited situations, your Personal Data may be shared with other members of the SBGC group (the “Group”), (acting as either separate Controller(s)) or Processors acting on behalf of the member of the Group (acting as a Controller) you are interacting with.

• “Processor” means a third party processing Personal Data solely on behalf of and under the instruction of the Controller.

 

Who we are

• Here are our details:
  Our company name is Artessence US, LLC;
  Our company registered number is [please complete];
  Our registered address is [please complete];
  Our trading name/brand name is “Initio Parfums”
  Our nominated representative who is responsible for overseeing questions in relation to this Privacy Notice is our customer service representative. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please email boutique@initioparfums.com marked for the attention of customer service representative.
• We respect your right to privacy and will only process personal information about you or provided by you in accordance with the Data Protection Legislation which for the purposes of this Privacy Notice shall mean:
• for the UK (i) the United Kingdom’s version of the General Data Protection Regulation ((EU) 2016/679) (the “UK GDPR”), (ii) the Data Protection Act 2018, and (iii) any successor legislation to the UK GDPR or the Data Protection Act 2018 and other applicable privacy laws ; and
• for the EU (i) the General Data Protection Regulation (EU 2016/679) (GDPR) and (ii) any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time.

 

The data we collect about you

• We may process different kinds of Personal Data about you which we have grouped together as follows:
• Identity Data includes first name, last name, username or similar identifier. When you contact us, either by email or via our contact us form we may collect information such as your first name, last name, email address and phone number.
• Contact Data includes billing address, invoicing address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments and other details of Products you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Website.
• Usage Data includes information about how you use our Website and Products.
• Marketing and Communications Data includes any consents to receive marketing information and any preferences you have indicated in receiving marketing from us and our third parties and your communication preferences.
• Cookies Data like many websites, we use "cookies" to enhance your experience and gather information about visitors and visits to our Website. Please see our cookie policy for information about cookies and how we use them and what kind.

• Information we receive from other sources. We may receive information about you if you use any of the other websites we operate. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on our Website. We are also working closely with third parties (including, for example, business partners, suppliers, sub-contractors, advertising networks, analytics providers, and search information providers) and may receive information about you from them.

• Analytics, which includes third-party analytics services (such as Google Analytics and Pinterest) where you have agreed to the installation of analytics cookies that produces data that allows us to evaluate your use of the Website, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to our Website and Internet usage. These third parties use cookies and other technologies to help analyse and provide us the data.

 

How we may collect and use your data

• We may use third parties, including other members of the Group, and other processors, agents and sub-contractors acting on our behalf to process your personal information by way of different methods to collect data from and about you including through:
• Direct interactions: you may give us your information by filling in forms via our Website or by corresponding with us by email or using our ‘contact us’ form or otherwise. This includes Personal Data you provide when you:
• present information to us on the Website;
• purchase or use any of our Products;
• create an account on our Website;
• subscribe to our services or publications;
• request marketing to be sent to you; or give us some feedback; and/or
• otherwise interact with us.
• Information from third parties, such as from financial institutions in respect of payments or from delivery companies in respect of deliveries
• In addition to the above, we may process your Personal Data to:
• administer a contest, promotion, survey or other site feature;
• provide information, and services that you request, or (with your consent) which we think may interest you;
• manage any accounts you may have with us;
• carry out our contracts with you or provide you with your purchased products to you;
• comply with, or evidence our compliance with our legal obligation;
• exercise, establish or defend legal rights; or
• otherwise interact with you, including responding to any correspondence from you; and
  Where you have consented to allow us to do so:
• use cookies to personalise your Website experience and to allow us to deliver the type of content and product offerings in which you are most interested;
• use cookies to present Website content effectively to you;
• receive our e-mail newsletter or information about our products. If you would no longer wish to receive promotional e-mails from us, please unsubscribe using the link provided in the emails.
• If you are a new customer, you will only be contacted if you agree to it or where necessary for the performance of a contract (or to take steps at your request prior to entering into a contract) or to comply with a legal obligation imposed on us.
• We may keep a record of those links which are used the most to enable us to provide the most helpful information, but we agree to keep such information confidential and you will not be identified from this information.
• In addition, if you don't want us to use your Personal Data for any of the other reasons set out in this section 4, you can let us know at any time by contacting us at [please complete] and we will delete your data from our systems. However, you acknowledge this may limit our ability to provide the best possible products and services to you.
• In some cases, the collection of Personal Data may be a statutory or contractual requirement, and we will be limited in the products and services we can provide you if you don't provide your Personal Data in these cases.
• If you provide personal information to us about another data subject, you are responsible for ensuring that you have their consent to provide that data for the uses set out in this Privacy Notice and for bringing this Privacy Notice to their attention.

 

5. Legal basis

• We will ensure that your Personal Data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your Personal Data if at least one of the following basis applies:\
• where you have given us your prior consent to the processing of your Personal Data for one or more specific purposes;
• where it is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
• where is necessary for compliance with a legal obligation to which we are subject, for example compliance with health and safety, tax or other statutory obligations; or
• where the Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our financial payments and your interests and fundamental rights do not override those interests.
• We generally do not rely on consent as a legal basis for processing your Personal Data other than in relation to our marketing communications or sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by clicking the unsubscribe link in any marketing email we send.
• As indicated above, with your consent we may also use your data for marketing purposes which may lead to us contacting you by email and/or SMS messages with information, news and offers on our Products. We will not do anything that we have not agreed to under this Privacy Notice, and we will not send you any unsolicited marketing or spam. We will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the EU and UK GDPR, the “Loi n° 2004-575 du 21 juin 2004 pour la confiance dans l'économie numérique” and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
• When you register on our Website, we (or a third party on our behalf) also store the personal information you provide in the user profile. All Website users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

 

6. Cookies

• General information
  Artessence US, LLC. uses cookies to personalise content and offer you a tailored experience. You can manage your cookies and learn more by clicking on ‘Set Preferences’ which appears in a pop up on entry to the Website.
  Our Website uses cookies to distinguish you from other users of our website. This enables our website to operate, helps us to provide you with a good user experience when you visit our website and also allows us to improve our website.
  A cookie (and other similar technology such as a pixel) is a small data file of letters and numbers that our website will install on your device, which allows us to identify your device when you visit our Website. Whilst the cookie does not contain any of your personal data, as it identifies your device when you visit our Website, we can identify information about you, and therefore, any information we collect may be deemed personal data.
  Further details of the different types of cookies used are provided below
• How we use cookies
  We use cookies to recognise you and your preferences, improve our website's performance and collect analytical information for ourselves, members of our group of companies and our business partners. Cookies are used on our Website  to identify which parts of our website you have visited and to allow us to make our website more relevant to you.
• Which Cookies do we use
  We use the following cookies:

Strictly necessary cookies
These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. Without these strictly necessary cookies, our website will not operate and therefore, these cookies are lawfully installed on your device without requiring your consent to do so.

Our website use the following strictly necessary cookies.

Cookie name	Purpose	Type of cookie	Expiry
_cf.bm	This cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of our website.	Http	1 day
_shopify_d	This cookie is necessary for the secure checkout and payment function on the website. This function is provided by shopify.com.	Http	session
axeptio_all_vendors    axeptio_authorized_vendors axeptio_cookies	Stores any consents to install cookies on the device	Http	1 year
cookietest	This cookie is used to determine if the visitor has accepted the cookie consent box.	Http	session
secure_customer_sig	This cookie is used to store customer credentials securely when processing a purchase on the website - the cookie is essential in making a secure on line transaction.	Http	1 year

Preference cookies
These are used to recognize you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). They will only be installed when you have given us your prior consent to install them.

Cookie name	Purpose	Type of cookie	Expiry
klaviyoOnsite	The cookie is used to manage the mailing list, if the visitor has subscribed to any newsletters or blogposts.	Html	Persistent
localization	Holds the user’s timezone.	Http	1 year
Tms-util-storage	Used in the context of the website language setting. Facilitates translation into the visitor's preferred language.	Html	Session
tms-session-storage	Used in the context of the website language setting. Facilitates translation into the visitor's preferred language.	Html	Session

Analytical or performance cookies
These cookies collect information as to how users use the website only where you have consented to allow us to install them. Any information collected is aggregated and anonymized, and is only used to allow us to understand how users use our website, to identify any problems with the website and to allow us to improve our website. They will only be installed when you have given us your prior consent to install them.

Cookie name	Purpose	Type of cookie	Expiry
kla_id	This cookie collects data on the user's behaviour. This information will be stored for internal use on our website – internal analytics is used to optimize the website or to register if the visitor has subscribed to a newsletter.	Http	2 years
landingPage	Detects and stores which landing page was presented to the user.	Http	Session

Targeting or advertising cookies
These cookies track your activities you across various website, in order to allow relevant adverts to be displayed. They will only be installed when you have given us your prior consent to install them.

Cookie name	Purpose	Type of cookie	Expiry
_fbp	Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.	Http	3 months
_landing-page	Stores visitors' navigation by registering landing pages - This allows the website to present relevant products and /or measure their advertisement efficiency on other websites.	Http	14 days
_orig_referrer	This cookie is used to collect information on a visitor. This information will become an ID string with information on a specific visitor – ID information strings can be used to target groups with similar preferences, or can be used by third party domains or ad-exchanges.	Http	14 days
_s	Collects data on user behaviour and interaction in order to optimize the website and make advertisements on the website more relevant.	Http	1 day
_shopify_s	Collects data on user behaviour and interaction in order to optimize the website and make advertisements on the website more relevant.	Http	1 day
_shopify_y	Collects data on user behaviour and interaction in order to optimize the website and make advertisements on the website more relevant.	Http	1 year
_shopify_sa_p _shopify_sa_t	Collects data on visitors' behaviour and interaction - This is used to make advertisements on the website more relevant. The cookie also allows the website to detect any referrals from other websites.	Http	1 day
_y	Collects data on visitors' behaviour and interaction - This is used to make advertisements on the website more relevant.	Http	1 year
Fr	Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers	Http	3 months
Tr	Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers	Pixel	Session

Unclassified cookies
We are presently in the process of classifying these cookies.

Cookie name	Purpose	Type of cookie	Expiry
logstate		Http	Session

• Third parties websites
  Please note that we have no control over the any third parties who provide links on our website which may include, for example, advertising networks and providers of external services like web traffic analysis services. We cannot accept liability for these third party websites linked on our website or any information you may provide them.
  This cookie policy only applies to our website and will not apply to any other websites that you have visited. Furthermore, our privacy notice only applies to any personal data that we process, and will not apply to any information you have provided on those websites, including through the use of their cookies.
  We would recommend that you to check the privacy and cookie policies of these other websites before providing any data to them.
• Cookie banner
  A cookie banner appears when you visit the website. You can give your consent to the different cookies by clicking on the "Set preferences" link. This cookie banner will disappear once your consent has been obtained. You can change your choices or preferences at any time by clicking on the cross at the bottom left of the website to re-open the cookie banner.
• How do I disable or delete cookies?
  You can deactivate personalised cookies by adjusting the sliders and/or changing your browser settings, thus allowing you to reject the installation of all or part of the cookies.
  However, if you choose to disable or delete our cookies that might prevent certain important areas and features of our service from functioning properly or you might not be able to use certain important features of our services. You can find additional information at AboutCookies.org.

 

7. With whom will your data be shared and where

Sharing of your data within the Group

• As a global company, we may transfer your Personal Data to other businesses within the Group, in France, the UK, the USA and the UAE, where necessary for the performance of a contact you have entered into, or for our operational management purposes.

• Where such transfers take place, it shall be undertaken in compliance with this Privacy Notice, and the recipients will be subject to restrictions, including those set  out below,  as to how and why they can access or process that Personal Data, including ensuring that such access or processing is undertaken only where necessary, depending on job functions and roles.

Outside the Group

• We use a company called Shopify who provide software used by us to run our business. If you visit our Website or make a purchase from us, Shopify collects and use information about you on our behalf and at our direction. For further information about Shopify and the way in which they collect information, including what information they collect and how it is used, please visit Shopify's privacy information and policy.
• We may also share your Personal Data with third parties in the following cases subject to your consent, where required under the applicable laws:
• Where we plan to sell any or all of our businesses, or our companies, we may share your Personal Data with any potential buyer, solely to allow them to determine whether they wish to proceed with the purchase.
• Where necessary to comply with a legal obligation imposed on us;
• In order to protect other people's property, safety or rights.
• We may contract with third parties to supply services to you on our behalf. These may include payment processing companies (Shopify International Limited, PayPal, Stripe), search engine facilities, advertising and marketing. In some cases, these third parties may require access to some or all of your data.
• When making a purchase on our Website, your payment details are captured and sent to Stripe or PayPal for processing. In order to process your payment your details are transmitted to the acquiring bank in order to authorise payments. We do not store credit or debit card details.

Personal Data sent outside of the EEA or UK

• For transfers of personal data to recipients located outside the European Economic Area (the “EEA”) or the UK.
• Any transfer of Personal Data from the EEA or the UK to a country outside of the EEA that has not been recognized by the European Commission or the United Kingdom as providing an adequate level of data protection within the meaning of the EU GDPR or UK GDPR (including to Group companies located in the UAE or the USA) will be made subject to appropriate safeguards, as prescribed by the EU and UK GDPR, being in place to ensure the protection of your Personal Data. For personal data sent from the UAE to France, UK or the US: the provisions of the UAE Federal Data Protection Law and its Executive Regulations, as may be applicable.
• In the absence of an adequacy decision and where appropriate safeguards are unavailable, transfers may take place on the basis of your consent. In such a situation, we will inform you of the possible risks associated with such a transfer. Alternatively, we may transfer your Personal Data where necessary (i) in connection with the performance of your employment contract, (ii) for reasons of public interest, or (iii) in connection with a legal claim.

 

8. Security

• Data security is of great importance to us, we will do what we reasonably can to keep your data secure. As such, in order to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Website. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
• We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
• Any electronic payment made by you will be encrypted, and we will not have access to information about the cards used to make such a payment. This information will be retained by the payment provider.
• We have finally implemented security measures such as a firewall to protect any data and maintain a high level of security.
• Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet and you take the risk that any sending of that data turns out to be not secure despite our efforts.
• If we give you a password upon registration on our Website, you must keep it confidential. Please don't share it.

 

9. Retention periods of your data

• We will retain Personal Data for as long as is necessary which is usually the life of our relationship and up to a period of up to six years after our relationship have ended. We may however be required to retain Personal Data for a longer period of time to ensure we comply with our legislative and regulatory requirements. We review our data retention obligations to ensure we are not retaining data for longer than we are legally obliged to.

 

10. Your legal rights

• We rely on you to provide accurate, complete and current Personal Data to us. You have the right to request to exercise the following legal rights over your Personal Data. Please note that not all these rights are absolute, and in certain situations, we may not be able to comply with a request to exercise these rights. If this is the case, we will contact you to set out the reasons why we are unable to comply with your request to exercise that right.
• You may contact us at any time in order to request access to the personal information we hold about you. We will confirm whether we are processing your Personal Data, provide details of the categories of Personal Data concerned and the reasons for our processing. We can also provide you with a copy of your personal information on request.
• Be informed. You have the right to be informed as to how and why we are processing your Personal Data. This Privacy Notice sets out, in general terms, how and why we process your Personal Data
• Rectification. If the information we hold appears to be inaccurate we will not use it, and not allow others to use it, until it is verified. You can ask us to correct or complete your Personal Data by contacting us at any time. To the extent possible, we will inform anyone who has received your Personal Data of any corrections we make to it.
• Restriction. In certain circumstances, it may be possible to require us to limit the way in which we process your personal information (i.e., require us to continue to store your Personal Data, but not otherwise process it without your consent). Such circumstances include:
• where you think the data we hold about you is inaccurate, processing can be restricted while it is being rectified;
• where you object to our processing, (which is being carried out on the grounds that it is necessary in the public interest or for our legitimate interests) processing can be restricted while we determine whether such grounds override your interests;
• where processing is unlawful but you oppose the erasure and request restriction of your data instead; or
• where we no longer need the Personal Data but you require the data in order to establish, exercise or defend a legal claim, our processing can be restricted.
• Erasure. You may ask to have the information on your account deleted or removed. We will try to do so promptly, and, to the extent possible, we will inform anyone who has received your personal information of your request.
• Receiving/transferring your Personal Data. In certain circumstances you may also ask us to send you the Personal Data we hold on you in an electronic, structured and user-friendly format, or you may ask us to send this data to another entity.
• Object. Where we are processing your personal information without your consent to pursue our legitimate interests, you may object to us processing your Personal Data. In particular, where we are using your Personal Data to contact you for marketing purposes, you have the general right to object to receive direct marketing from us at any time.
• Where our processing of your Personal Data is based on your consent, you have the right to withdraw your consent at any time. If you do decide to withdraw your consent we will stop processing your Personal Data for that purpose, unless there is another lawful basis we can rely on – in which case, we will let you know. Your withdrawal of your consent won’t impact any of our processing up to that point. Your withdrawal of your consent won’t impact any of our processing up to that point. For example, where you have consented to us processing your Personal Data to contact you for marketing purposes, you have the right to withdraw your consent at any time.
• Post-mortem directives. If you are a French user, you are entitled to issue post-mortem directives concerning the processing of your Personal Data after your death.
• If you wish to exercise any of your rights please contact [please complete with the contact details of the Controller or DPO or an equivalent function in charge of receiving questions on Personal Data] in the first instance. We have a template form (below) to assist you to make such requests, but you do not have to use it to make such requests.
• Where necessary, we may ask you for additional information to confirm your identity. Upon receipt of your request, or proof of identity, we will seek to respond to your request within one calendar month. However, in certain situations, we may need to extend this deadline to 3 calendar months. if this is the case, we will contact you within the first month following receipt of your request/proof of identity to explain the reasons for the extension and the new deadline.
• No fee usually required. You will not normally have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive to cover our administrative costs involved in complying with your request. Alternatively, we could refuse to comply with your request in these circumstances.
• If we are unable to comply with your request to exercise any of these rights, either in full or in part, we will set out the reasons why when we respond to your request.

 

12. Complaints

If you believe that the rights indicated here have not been complied with, you have the right to lodge a complaint with your local supervisory authority (i.e., for UK users: the Information Commissioner’s Office (“ICO”) having its address at: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. More information can be found on the ICO website at https://ico.org.uk/).

 

13. Links to other sites

Please note that our terms and conditions and our policies will not apply to websites other than us.initioparfums.com that you may visit via a link from this Website.

We have no control over how your data is collected, stored or used by these other websites and we advise you to check the privacy notices and cookie policies of any such websites before providing any data to them.

 

14. Changes

If we change our Privacy Notice, we will post the changes on this page so please check this page for our current policy.

 

15. Terms and Conditions

Please also visit our Website’s terms and conditions establishing the use, disclaimers, and limitations of liability governing the use of our Websites.

 

SCHEDULE – Data Subject Access Request Form

We, Artessence US, LLC, operate in a jurisdiction that grants you the right to access your personal data, including the right to obtain confirmation that we process your personal data, receive certain information about the processing of your personal data and obtain a copy of the personal data we process.

You may exercise them by communicating with us in any way including:

• In writing by post addressed to [please complete];
• electronically via email to [please complete];
• making a verbal request to one of our employees, either over the telephone or face to face; or
• by using the form set out below.

We expect to respond to your request within one month of receipt subject to, where reasonably required, confirmation of your identity unless one or more exception(s). applies. You do not have to use this form in order to make a data access request but using this form should make it easier for you to make sure you have provided us with all relevant information, and for us to process your request promptly.

In certain situations, we may need to extend this deadline for our final response to your request to a maximum of 3 months from receipt of your request or proof of identity. If this is the case, we will notify you of this within the first month, together with details of the reasons why we have extended this deadline and the new deadline date.

In addition to exercising your right of access to your personal data, you may also have the right to request correction or erasure of your personal data, or restrict or object to certain types of data processing, withdraw your consent to any processing you have given or request that you (or a nominated third party) is given an electronic copy of certain types of personal data we process.

Requester name (data subject) and contact information

Please provide your information. We will only use the information you provide on this form to identify you and the Personal Data you are requesting access to, to respond to your request and to keep a record of your request and our response.

First and last name:
Any other names that you have been known by (including nicknames and previous surnames):
Home address:
Date of birth:
Telephone number:
Email address:

 

Proof of data subject’s identity

We may request proof of your identity before we can respond to your access request.

To help us establish your identity, you must provide identification that clearly shows your name, date of birth and current address. We accept a photocopy or a scanned image of your passport or other photo identification such as a driving licence or national identity card as proof of your identity.

Please also attach a copy of a bank or credit card statement or utility bill showing your current address and dated within the last three months. If you have changed your name, please provide the relevant documents evidencing the change.

We may request additional information from you to help confirm your identity and your right to access, and to provide you with the personal data we hold about you. We reserve the right to refuse to act on your request if we are unable to identify you.

Information to which your request relates

To help us process your request quickly and efficiently, please provide as much detail as possible about the personal data or processing activity to which your request relates. Please include time frames, dates, names, types of documents, file numbers, or any other information to help us locate your personal data.

For example, you may specify that you are seeking access to your personal data held in relation to the following:

Email or other electronic communications (specify the approximate dates, times and correspondents).

Billing information.

Transaction histories.

We will contact you for additional information if the scope of your request is unclear or does not provide sufficient information to allow us to respond to your request, (for example, if you request “all information about me”). We will begin processing your request upon receipt of your request (or where we have requested it, as soon as we have verified your identity and have all the information we need to locate the personal data that falls within the scope of your request).

In response to your request, we will provide you with the information we are required to provide, including information on:

• The purposes of processing.
• Categories of personal data processed.
• Recipients or categories of recipients who receive personal data from us.
• How long we store the personal data, or the criteria we use to determine retention periods.
• Any available information on the source of the personal data if we do not collect it directly from you.
• Whether we use automated decision-making, including profiling, meaningful information about the auto-decision logic used, and the significance and consequences of this processing.

Your right to:

• request correction or erasure of your personal data;
• restrict or object to certain types of processing with respect to your personal data; and
• make a complaint to the Local Supervisory Authority.

If we are unable to provide you with access to your personal data because disclosure would infringe the rights and freedoms of third parties, we will notify you of this decision, and provide you with such Personal Data we can that does not infringe such rights.

Applicable law may allow or require us to refuse to provide you with access to some or all the personal data that we hold about you, or we may have destroyed, erased or made your personal data anonymous in accordance with our record-retention obligations and practices. If we cannot provide you with access to your personal data, we will inform you of the reasons why, subject to any legal or regulatory restrictions, when we respond to your request.

Acknowledgment

I confirm that the information provided on this form is correct and that I am the person whose name appears on this form. I understand that:

• Artessence US, LLC may need to confirm my proof of identity and may need to contact me again for further information.
• Artessence US, LLC may request additional information from me to assist it in responding to my request.
• I am entitled to one free copy of the personal data I have requested (in most cases, i.e. other than where the request is manifestly unfounded or excessive), and acknowledge that, for any further copies of the same personal data I request Artessence US, LLC may be entitled to refuse such a request or charge a reasonable fee based on administrative costs.

Please confirm how you would wish to receive the response to your request, including, where requested, any personal data you are seeking access to:

 

………………………………………….

 

………………………………………

Signature

………………………………………

Date