PRIVACY POLICY

UPDATED: October, 2022

 

Our Commitment to Our Consumers

We are committed to building a lasting and meaningful relationship with you, our consumer, and we recognize that this relationship must be built on mutual trust. We are a member of the Gloent Group USA family of brands and this privacy policy sets forth how we collect, use, and safeguard information you entrust with us. Gloent Group collects data to provide you the best products, beauty experiences, and personalization from our brands.

Everything we do, and the data we collect, is in pursuit of giving you a better beauty experience. 

•  With personalized products, services and offers
•  We respect your privacy and choices. You can opt-out at any time
•  We do not sell your data
•  We require partners to abide by the law and protect your information
•  We will continue to evolve and update our privacy and security practices because retaining your trust is important to us.

Our detailed privacy policy below describes the types of information we collect from you directly, from your interactions with us (on our sites, mobile apps, digital tools (collectively, “Sites”) and advertising), how we use it, how we protect it, and your rights as our consumer. This policy is for consumers and visitors of our Sites in the United States only. Visitors from other countries should visit the Gloent Group brand site for your part of the world. If you have any questions or concerns, please contact us by one of the options listed at the end of this notice.

Your use of this Website constitutes your acceptance of this Privacy Policy and your consent to the practices described below. You are not authorized to use this Website unless you agree with this Privacy Policy.

This privacy policy does not cover information that you submit on third party websites, apps, social platforms (“Platforms”). For example, if you post something on Facebook, Twitter, or You Tube, that information is governed by the privacy policies on those Platforms.

1. Collection of Information
2. Use of Information
3. Sharing of Information
4. Transfer of Information
5. Protection of Information
6. A note about Children
7. Managing Your Information
8. Other Sites
9. Your California Rights
10. Changes to Our Privacy Policy
11. Contact Us

 

1. Collection of Information

Information You Provide

We may obtain personal information about you on our sites or at offline events. You may choose to provide personal information when you create an account, make a purchase on our sites, subscribe to our electronic newsletter, participate at our offline event or contact us for customer service. The types of information you may provide to us include the following:

 

• Name
• Date of birth and/or age
• Username
• Contact information (e.g., postal address, telephone number, mobile phone number, email address)
• Payment information (e.g., PayPal™ account number, payment card number, expiration date, billing address)
• Skincare concerns
• Content you may provide to us or public information posted on our Website (e.g., photographs, videos, reviews, comments and responses)
• Information Automatically Collected

 

When you use our sites, we may collect certain information about your activities on our sites by automated means, such as cookies, IP addresses, browsing history and service history, as follows:

 

Transaction Information: We collect information in connection with each transaction you engage in via our sites or stores, including product details, purchase price, and other transaction details.

 

Device and Log Information: We and our third-party service providers may automatically collect device and log information, such as an IP address or other unique identifier information for the computer, mobile device, technology, or other device (collectively, "Device") you use to access our sites or on third party websites that publish our advertising, browser type, Internet service provider, the referring/exit pages, your operating system and date/time stamp of your visit. We may use your Device information to, among other things, administer the sites, help diagnose problems with our servers, improve business operations, analyze orders and trends, track users’ web page movements, help identify you and your shopping cart, deliver advertising, and gather broad demographic information.

 

Location Data: If you access our sites using a mobile device or application, we may access, collect, or monitor information regarding the geographic location of your mobile device. We may also determine your general geographic location using your IP address. You may control whether location data is shared with us through your mobile device, application, or browser settings, provided that certain features on our sites may not function properly if your location data is disabled.

 

Social Platforms: You also can engage with our brands, use chat features, applications via social media platforms, such as Facebook (including Instagram) or Google. When you engage with our content on or through social media or other third-party platforms, plug-ins, integrations or applications, these platforms may ask your permission to share certain information with us (e.g. name, gender, profile picture, likes, interests, demographic information). Such information is shared with us subject to platform privacy policy. You can control the information that we receive by changing your privacy settings offered by the relevant social media platform.

 

Cookies: We and our third-party service providers may collect information from you by using cookies. Cookies are small amounts of information which we store on your computer. Unless you have indicated your objection when disclosing your details to us, our system will issue cookies to your computer when you log on to our sites. Cookies make it easier for you to log on to and use our sites during future visits by remembering information about your preferences or allowing you to preserve your shopping cart contents between site visits or devices. They also allow us to monitor website traffic and to personalize the content of our sites for you. You may set up your computer to reject cookies by activating the settings on your browser, although, in that case, you may not be able to use certain features on our sites. Please refer to the "Help" file of your Internet browser to learn how to either block all cookies or receive a warning before a cookie is stored.

 

Clear GIFs: We and our third-party service providers may collect information from you using clear GIFs, such as pixels, tags and web beacons. These are tiny electronic images that may be used in our sites or emails and help deliver cookies, visit counts, and understand usage and campaign effectiveness. We may also use clear GIFs to understand whether our emails are read or opened. We use learning from this information to improve our messages, reduce frequency of messages to you or determine interest in content we share.

 

Other Technologies: We may utilize new technologies as they are developed in a manner that is consistent with this Privacy Policy and industry standards.

 

Information from Third Parties

We may also obtain information from other sources. For example, we may collect information about you from other websites that sell our products, from other users, such as individuals who send you a gift through our sites, and from social networks in accordance with their authorization procedures. We may also receive information from our retail partners or other companies that collect or aggregate information from publicly available databases or if you consented to allow them to use and share your information. This might be de-identified information about purchasing patterns, location of shoppers and sites that are of interest to our consumers.

 

2. Use of Information

We may use the personal information that we collect for various purposes, including to:

 

• Provide you with products, information, and services;
• Fulfill and deliver the products and services you request, process transactions and send you related information, including confirmations and invoices;
• Process payment and access your purchase history;
• Contact you regarding your purchases;
• Communicate with you for account management and promotional purposes;
• Other matters related to your purchases and activities on our sites;
• Conduct, assess and improve our business operation, including: performing data analytics about our products and customers; detecting, investigating and preventing security incidents, fraud and illegal activity; maintaining business systems and records; enhancing the functionality of our Website or making other technological improvements; and remaining in compliance with applicable laws and policies;
• Ensure the Website displays correctly on your Device;
• Respond to your comments, questions and requests and provide customer service; and
• Carry out any other purpose described to you at the time the information is collected.

 

We may also contract with third-party advertising agencies, including the companies not affiliated with us, to send you information and promotional materials about our products based on the personal information we collect from you.

We may also use the information in other ways for which a specific notice will be provided to you at the time of collection

 

3. Sharing of Information

We may share your personal information with our corporate affiliates, such as GLOENT GROUP CO., LTD and their subsidiaries and affiliates, for purposes of technical support and other business co-operations. We may share your information with third-party service providers that perform services on our behalf according to our instructions, such as fulfilling orders, delivering packages, sending postal mails or e-mails, analyzing customer data, providing marketing assistance, processing credit card payments, investigating fraudulent activities, conducting customer surveys, and providing customer service. These third parties may include Internet service providers, shipping carriers, payment processors, data analytics providers, operating systems and platforms, and technology vendors. We do not authorize these third-party companies to use or disclose the information except as necessary to perform services on our behalf or to comply with legal requirements.

 

In addition, we may share de-identified, aggregated information (i.e., the information that is not directly connected to your identity) about our customers with advertisers and marketing partners in order to gain insights about the market and improve our business performance. We may also contract with third party companies to collect information about your use of our sites and other websites through technologies such as cookies, so that we may provide advertisements that are more relevant to your needs and interests based on your internet activity history. Those advertisements may appear either on our sites, or on other websites.

 

We may disclose your personal information to law enforcement or other government authorities when required by law or when we believe such disclosure is necessary to prevent physical harm or financial loss or to assist an investigation of any illegal activity, suspected or actual.

 

There may be business or legal reasons to disclose your personal information. For example, we may share your personal information with another company that buys some or all of our assets or shares, and that company may use and disclose personal information for purposes similar to what is described in this policy. We may also share and disclose your information with prospective business partners to evaluate a potential business transaction such as a merger or a joint venture.

 

We will always take steps to ensure that any of your information used by all third parties is properly protected in accordance with this policy and applicable laws. We will not otherwise share, sell or distribute any of the information you provide to us outside the scope described herein without your consent.

 

4. Transfer of Information

Our sites are intended for visitors and customers located in the United States and is governed by and operated in accordance with the laws of the United States only. However, we may transfer the personal information we collect to the entities located in the countries other than the country in which the information is originally collected, including South Korea, where such entities administer and/or operate certain functions or services on our behalf, such as technical support, marketing assistance, data analytics and business administration. Those countries may not have the same data protection laws as your country of residence, but we take reasonable measures at all times to protect the personal information in transmitting, retaining and processing the information as described in this policy. We will refuse to transfer personal information if we believe that the information will not receive reasonable protection. By accessing our sites, or otherwise providing information to us, you expressly consent to the processing, transfer, and storage of information in and to the U.S. and other countries, where you may not have the same rights and protections as you do under local law.

 

5. Protection of Information

We use technical, administrative, and physical safeguards and procedures which are reasonably designed to help protect your personal information against unlawful or unauthorized access, disclosure, misappropriation, alteration, or loss. We use encryption, passwords, and physical security measures to help protect your personal information. However, the transmission of information via the Internet cannot be completely secure and we cannot guarantee the privacy or security of your data transmitted to our sites. Any transmission of your personal information is at your own risk.

 

6. A Note About Children

Gloent Group USA’s sites are not directed to children under 13. We do not knowingly collect, use or disclose personally identifiable information from anyone under 13 years of age. If we determine upon collection that a user is under this age, we will not use or maintain his/her Personal Information without the parent/guardian's consent. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 13, we will make reasonable efforts to delete such information from our records. If you believe that we might have any information from or about a child under age 13, please contact us through one of the methods listed in the Contact Us section at the end of this notice.

 

7. Managing Your Information

You have the following rights and choices in providing your information and choosing how we communicate with you:

 

You may view or update the information you provide to us by logging into your online account and accessing the “My Account” page on our sites. You may also ask us to delete your information and withdraw your consent at any time by contacting us at BarneysBeauty@gloentgroup.com.

You may opt out of receiving email marketing promotions by clicking on the “Unsubscribe” link at the bottom of any promotional e-mails you receive. To the extent you are receiving text messages us, you may opt out of receiving text messaging by replying to any message we send you with the word "STOP" or contacting us at the phone numbers above. To the extent you receive notifications from any of our applications, you may opt out of receiving push notifications on your mobile device through your account and device settings.

If you are unable to remove the content you posted on our sites, you can request that we help you take down such publicly-posted content by contacting us at BarneysBeauty@gloentgroup.com.

Please note that while text messaging opt out/unsubscribe requests are processed immediately upon our receipt, we are not responsible for any carrier delays. Carriers are not liable for delayed or undelivered messages. Additionally, please allow up to 10 business days to process marketing email opt out/unsubscribe requests. If you make a purchase through our sites or stores, you may opt back into marketing communications from us until you opt out/unsubscribe once again. You may opt back in to receiving text messaging by providing us with explicit permission to send you text messages during the order checkout or other sign-up process.

 

Notwithstanding the above, we may need to retain limited information about you in order to fulfill any order requests made by you, for business, tax, retention and litigation purposes or to fulfill other legal or regulatory obligations. As such, we may still continue to send you non-marketing communications by email, such as transactional or operational communications, even if you have opted out/unsubscribed from our marketing communications.

 

8. Other Sites

The Sites may contain links to third party sites that are not owned or operated by Gloent Group USA. This includes links from advertisers, sponsors and/or partners that may use our logo(s) as part of a co–branding or co–marketing agreement. We do not control, recommend, or endorse, and are not responsible for these sites or their content, products, services or privacy policies or practices. These other sites may send their own cookies or other tracking technologies to your device, they may independently collect data or solicit Personal Information and may or may not have their own published privacy policies. You should also independently assess the authenticity of any site which appears or claims that it is one of our Sites (including those linked to through an email or social networking page). The Sites may make available chat rooms, forums, message boards, and news groups. Remember that any information that you disclose in these areas becomes public information and is not subject to the provisions of this Privacy and Cookie Notice.

 

9. Your California Rights

The California Consumer Privacy Act (CCPA) provides California residents with specific rights regarding their personal information. This section describes your rights and how you can submit your request to us. We do not sell personal information.

 

Access to Information

You have the right to request that we disclose information about our collection and use of your personal information over the past 12 months, including:

• Categories of personal information we collected
• Categories of sources for the personal information we collected
• Our business purpose for collecting personal information
• The categories of third parties with whom we share that personal information
• The specific personal information we collected about you

 

Deletion

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny a deletion request where retaining the information is necessary for us or our service providers. For example, data may need to be kept to:

• Complete a sales transaction for which we collected the personal information (such as the sale of our beauty products to you)
• Track consumer complaints or product issues
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity
• Comply with a legal obligation
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us

 

Submitting a Request

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of a California resident who wishes to make a request.

We may not be able to respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will ask you for the email information that you used to interact with us or sign up for a loyalty, email, or to make purchases along with other information you submit (such as contact information like name, address, phone number) and the information we have in our systems, to help verify your identity or authority to make the request and confirm that your information is in our system. Information provided to submit a request will only be used for request purposes.

You may designate an agent to submit requests on your behalf. We will need the agent to provide us with your signed permission to act on your behalf. We may also require you to verify your identity with us directly and confirm that you provided the agent permission to submit the request on your behalf.

You, or a person registered with the California Secretary of State that you authorize to act on your behalf, may request the following information or exercise any of the above rights by emailing us at BarneysBeauty@gloentgroup.com or request this portal.

 

Timing

We will respond to your request within 45 days. If necessary, we may need an additional period of time, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.

We do not charge a fee to process or respond to a verified consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will provide explanation and a cost estimate prior to completing the request.

You may only make a request for access or data portability twice within a 12-month period.

 

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

 

10. Changes to Our Privacy Policy

We may revise this Privacy Policy periodically and without prior notice to you. We encourage you to review our Privacy Policy periodically so that you remain up-to-date on our current practices and any changes so you can always be aware of what information we collect, use and disclose.

 

11. Contact Us

If you have any questions about our privacy or security practices, or if you would like to request access to or correction of your personal information, you can contact us at the following:

 

GLOENT GROUP INC.

ATTN: Barneys New York Beauty Online Privacy

18400 San Jose Ave,

City of Industry, CA 91748

 

Your right to access or correct your personal information is subject to applicable legal restrictions. We may take reasonable steps to verify your identity before granting access or making corrections.

If we need, or are required, to contact you concerning any event that involves your personal information, we may do so by e-mail, telephone, or mail.

 

Updated: October, 2022