Privacy Notice

Who Is Collecting It?

Any Personal Data provided to or collected by and controlled by Covergirl, the Data Fiduciary.

This Privacy Notice applies to Personal Data collected by Covergirl in connection with the services and products we offer. References to Covergirl in this Notice means COVER GIRL LABORATORIES PVT. LTD, or any company directly or indirectly owned and/or controlled by COVER GIRL LABORATORIES PVT. LTD.

This Privacy Notice also applies to Covergirl's marketing content, including offers and advertisements for Covergirl products and services, which we (or a service provider acting on our behalf) send to you on Third-Party websites, platforms and applications based on your site usage information. These Third-Party websites generally have their own Privacy Notice and Terms and Conditions. We encourage you to read them before using those websites.

Key Terms You Should Know

• Personal Data - Any information that can identify a data subject directly or indirectly, such as a name, identification number, location data, online identifier, or factors specific to physical, physiological, genetic, mental, economic, cultural or social identity.
• Data Fiduciary / Data Controller - Any person or entity which alone or jointly with others determines the purposes and means of the processing of Personal Data.
• Processor - A person or entity which processes Personal Data on behalf of the controller.
• Consent - Any freely given, specific, informed and unambiguous indication signifying agreement to the processing of Personal Data.
• Cookies - A small text file stored on a user device that may be retrieved by a web server, allowing servers to track browser activities and connect web requests into a session.
• IP Address - A unique address that identifies a device on the Internet or a local network.
• Profiling - Processing of Personal Data to evaluate, analyse or predict aspects concerning performance, economic situation, health, preferences, interests, behaviour, location or movements.
• Special Categories of Personal Data - Personal Data revealing racial or ethnic origin, political opinions, religious beliefs, financial data, genetic data, biometric data, health data, or data relating to a child.

What Personal Data Is Being Collected?

You are not required to provide us the Personal Data that we request, but if you choose not to do so, we may not be able to provide you with our products or services, or with a high quality of service or respond to any queries you may have.

We may collect Personal Data from a variety of sources, including Personal Data you give us directly, Personal Data we collect automatically, and Personal Data we collect from other sources.

Ways in which we collect your Personal Data

• Personal Data you give us directly - We collect data about how you use our services and products. We also collect Personal Data you provide when you sign up for a marketing newsletter, complete a survey, register for an account to buy our products, or use features such as our Formula Finder. We may ask for your name, gender, date of birth, address, email address, telephone number, and care-related preferences. We will take your explicit consent when collecting special categories of personal data.
• Personal Data we collect automatically - We receive and store certain types of Personal Data whenever you interact with us online. We use Cookies and tracking technologies to obtain Personal Data when your web browser accesses our websites. Examples include IP Address, device ID, location data, browser type, operating system, and purchase history.
• Personal Data we collect from other sources - We collect Personal Data from trusted partnerships with third-parties and where we operate Covergirl accounts on Third-Party platforms. We also receive information about your interactions with our advertising and from third-party data enrichment providers.

When and why we collect special categories of personal data

Certain categories of Personal Data, such as health-related care information, financial data, or biometric data are classified as "special categories of data" or "Sensitive Personal Information" and benefit from additional protection.

We limit the circumstances where we collect and process these special categories of data. Covergirl sometimes collects data related to your shade preferences, allergies, or pregnancy status to suggest better products and send tailored recommendations. We only collect and use this Personal Data where you have provided us with your Consent.

How do we protect children's privacy?

We understand the importance of taking extra precautions to protect the privacy and safety of children using Covergirl products and services.

Covergirl's website is designed and intended for use by adults. Where required by applicable laws, we will obtain Consent from a person with guardian responsibility before we collect Personal Data from a child.

If we discover that we have collected Personal Data from a child without required Consent, we will delete that Personal Data as soon as practical.

What Purpose Do We Use Your Data For?

We collect, process and disclose your Personal Data only for specific and limited purposes, such as to assess and handle complaints, develop and improve our products and services, and provide personalised product recommendations and communications.

We do not collect, store, or process your payment instrument details (such as card numbers, UPI IDs, or bank account information). Payments made on our platform are processed directly by Third-Party payment service providers.

• To process and answer your inquiries or contact you regarding your questions and/or requests;
• To develop and improve our products, services, communication methods and the functionality of our websites;
• To manage your account, membership in our programs, platforms or applications;
• To communicate information to you and manage your registration and/or subscription to our newsletter or other communications;
• To authenticate the identity of individuals contacting us by telephone, electronic means or otherwise;
• For internal training and quality assurance purposes;
• To provide personalised product recommendations, communications and targeted advertising.

Profiling

Covergirl uses your Personal Data to build profiles by analysing your online browsing, searching and buying behaviour and your interactions with our brand communications.

For example, if you regularly view products for a specific concern on our website and have opted in to receiving emails from us, we may send you updates on relevant products or tailor web content when you visit.

Based on profile information, we may also show you advertising that we think you will find relevant on our website or partner publisher networks, where you have consented to such processing.

How We Use Cookies

We use traffic log Cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs.

Overall, Cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline Cookies. Most web browsers automatically accept Cookies, but you can usually modify your browser settings to decline Cookies if you prefer. Please also see our Cookie Policy for more detail.

Whom Will It Be Shared With?

• Third-Party service providers - Companies that host or operate our websites, process payments, analyse data, provide customer service, postal or delivery services, and administer promotions. They have access to Personal Data needed to perform their functions but may not use it for other purposes.
• Other third-parties - Your Personal Data may be used by us or shared with sponsors, advertisers, advertising networks, analytics companies or other third-parties in connection with marketing, promotional, data enrichment and other offers.
• Business transfers - Your Personal Data may be transferred as part of a sale, purchase, merger, or reorganisation involving Covergirl or its assets, subject to applicable law and this Notice.
• Legal disclosure - We may transfer and disclose your Personal Data to comply with legal obligations, respond to lawful requests by public authorities, detect and protect against fraud, or protect the rights, property, safety, or security of third-parties, visitors, Covergirl, or the public.

International Data Transfers

Covergirl may share Personal Data across international borders for purposes described in this Privacy Notice but will make sure that the Personal Data is protected in a similar manner. Your data will only be transferred if permitted and in accordance with applicable local and international regulations.

How Do We Protect Your Personal Data?

Covergirl takes the security of your Personal Data very seriously. We take every effort to protect your Personal Data from misuse, interference, loss, unauthorised access, modification or disclosure.

Our measures include implementing appropriate access controls, investing in information security capabilities, and ensuring we encrypt, pseudonymise and anonymise Personal Data wherever possible.

Access to your Personal Data is only permitted among our employees and agents on a need-to-know basis and subject to strict contractual confidentiality obligations when processed by third-parties.

How Long Do We Keep Your Personal Data For?

We will keep your Personal Data for as long as we need it for the purpose it is being processed for. For example, where you make a purchase online with us we will keep the data related to your purchase so we can perform the contract and handle any complaints or queries relating to the purchase.

If we collect identifiable data for targeting purposes, we retain it till the purpose remains relevant and of your interest. If you withdraw your Consent, we employ measures to permanently delete your Personal Data within a reasonable time, unless required for other valid purposes under law.

We will actively review the Personal Data we hold and delete it securely, or anonymise it, when there is no longer a legal, business or consumer need for it to be retained.

What Are Your Rights?

Where we process your Personal Data, you have several rights over how the data is processed and can exercise these rights at any time by contacting us at legal@covergirllabs.in.

• The right to be informed - You have the right to clear, transparent information about how we use your Personal Data and your rights.
• The right to access, update and rectification - You have the right to access, correct or update your Personal Data at any time.
• The right to erasure / to be forgotten - Under certain circumstances, you have the right to request that we delete your data.
• The right to object - Under certain circumstances, you have the right to object to certain types of processing, including processing for Direct Marketing.
• The right to withdraw Consent - If you have given Consent for processing, you have the right to withdraw it at any time.
• Rights to Nominate - You may nominate another individual to exercise control or rights to your Personal Data in the event of your death or incapacitation, as prescribed under law.
• The right to Grievance Redressal - You may raise grievances pertaining to your Personal Data with our designated contact at legal@covergirllabs.in.
• The right to lodge a complaint with a Supervisory Authority - You have the right to lodge a complaint with the relevant data protection regulator in your country.

How Do You Contact Covergirl?

We are committed to protect your personal information collected and processed by us. If you have any query or grievance with respect to the processing of information by us, you can reach out to our designated contact person at legal@covergirllabs.in.

When a privacy question or access request is received, our dedicated team triages the contact and seeks to address your concern. Where your issue is more substantive, more information may be sought from you. If you are dissatisfied with the reply received, you may refer your complaint to the relevant Supervisory Authority.

How Do We Keep This Notice Up To Date?

We will update this Privacy Notice when necessary to reflect customer feedback, our practices, scope of processing, and changes in our products and services. When we post changes to this statement, we will revise the "last updated" date at the bottom of this Notice.

You are encouraged to periodically visit this page to review the Privacy Notice and any changes to it. Your continued use or access after any modification(s) to this Privacy Notice will be deemed as your acceptance to such modification(s).

Additional Privacy Terms or Notices

In addition to this Privacy Notice, there may be specific campaigns or promotions which will be governed by additional privacy terms or notices. We encourage you to read these additional terms or notices before participating in any such campaigns or promotions.