Kiehl's University Privacy Policy

We have created this Privacy Policy to provide you with information about how we collect, use, share and protect information through our Kiehl's University platform ("Kiehl's University") to herein as "We," "Us" or "Kiehl's"). This notice applies to Kiehl's Associates who are currently employed by L'Oreal, Kiehl's or a third-party retail store selling Kiehl's products.

Your use of the Site constitutes your acceptance of this Privacy Policy and consent to the practices described. This Privacy Policy is incorporated by reference into the Kiehl's University Terms of Use.

As used in this Privacy Policy, "Personal Data" means any information relating to an identified or identifiable natural person.

When you set up an account, you are required to provide your name and email address and select a password (collectively, "Account Information"). We may also collect information that you provide us through your participation in surveys or through the comments and feedback you post on the Site ("User Content").

Device and Connection Information: We and our third-party service providers collect information about your computer, phone, tablet, or other devices you use to access the Site. We and our third-party service providers may also collect your Site usage information, including but not limited to, your browser type, device type, IP address, operating system, application version, the pages served to you, the time you browse, preceding page views, and your use of features or applications on the Site.

Cookies: Like many web sites, we use "Cookies," which are data files placed on a web browser when it is used to visit the Site to facilitate site navigation and to personalize your experience. Cookies may also be used to associate you with social networking sites like Facebook and Twitter and, if you so choose, enable interaction between your activities on the Sites and your activities on such social networking sites.

If you would prefer not to accept cookies, you can change your browser settings to notify you when you receive a cookie and allow you to choose whether or not to accept it; or set your browser to automatically not accept any cookies. However, please be aware that some features and services on our Site may not work properly because we may not be able to recognize and associate you with your account if you choose not to accept cookies. In addition, the offers we provide when you visit us may not be as relevant to you or tailored to your interests. To learn more about cookies, please visit http://www.allaboutcookies.org.

Pixels or Web Beacons: We use pixel tags or web beacons, which are transparent graphic images, placed on a web page or in an email and indicate that a page or email has been viewed or tell your browser to get content from another server.

We may use the information that we collect about you, including User Content that you choose to provide to us, for a varitety of purposes such as:

We may share the information we collect from you with L'Oreal USA and its affiliates. We will not disclose your Personal Data to third parties outside of the L'Oreal family of brands unless the disclosure is for one or more of the following limited purposes:

Third Parties Providing Services On Our Behalf: We share your information with third parties that perform functions on our behalf (or on behalf of our partners) such as service providers that host or operate our Site, provide analytics and site usage information.

Business Transfers: We may share information with other entities and affiliates of our parent company. As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or our assets, or assets related to the Site, Personal Data, User Content, usage information, and any other information that we have collected may be disclosed to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.

Legal Disclosures: We may transfer and disclose information, including your Personal Data, Account Information, User Content, usage information and device identifiers, (including IP address), to third parties to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our Terms of Use or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to our Site or the public.

Access and Rectification of their Personal Data: Upon your request, we will confirm whether Personal Data is held or processed by us and for what purpose. Additionally, upon request, we will provide to you a copy of your Personal Data, free of charge, in an electronic format. If your Personal Data is incorrect, you have the right to request rectification or correction.

Right to be Forgotten: Except when required by any regulatory body, Personal Data held by us that is no longer relevant to the original purposes for processing will be erased upon request. Additionally, if applicable and relevant legal requirements for data erasure are present, we will erase Personal Data in the event that you withdraw consent to process such information to the extent we are not required to maintain such Personal Data by any regulatory body.

Data Portability: Upon your request, and where possible, we will provide the Personal Data previously provided by you in machine readable format or transmit such data to another entity.

Recourse, Enforcement and Liability: If you have concerns about the privacy or processing of your Personal Data by us, please email your concern to [email protected] so that we may promptly review and address your concerns.

Under California law, website and online service operators are required to disclose how they respond to web browser "do not track" signals. Kiehl's does not currently take actions to respond to "Do Not Track" signals as a uniform standard for such response has not yet been established [PH5].

California law requires website and online service operators to disclose whether third parties may collect personal information about their users' online activities over time and across different sites when the users use the operator's website or service. Third parties that have content or services on our Site such as a social feature, analytics service, or an advertising network partner, may obtain information about your browsing or usage habits but this information does not include personal information. We do not knowingly permit such third parties to collect any Personal Information from our Site unless you directly provide it to us and we provide it to them with your consent.

If you are a minor under 18 and have an Account, you may ask us to remove any User Content that you posted on the site by writing to us and providing as much detail as possible (i.e. date and caption) as to the post(s) you want removed. We will begin to process your request within 30 days. Please note that processing your request does not ensure complete or comprehensive removal of User Content that you posted.

We may use Personal Data in countries other than where you are located to fulfill the purposes outlined in this Privacy Policy. Although the data protection laws in these countries may vary, Kiehl's endeavors to ensure that Personal Data will be afforded no less protection to its transfer.

By using the Site, or providing us with any information, you (a) acknowledge that the Site is subject to the laws of the United States, (b) consent to the collection, processing, maintenance and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen, and (c) waive any claims that may arise under those laws.

The Site is not directed to children under 16. We do not knowingly collect, use or disclose Personal Data from anyone under 16 years of age. If we determine upon collection that a user is under this age, we will not use or maintain his/her Personal Data 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 16, we will make reasonable efforts to delete such information from our records.

Retention: We may retain your personal data for as long as it is necessary to fulfill the purpose for which it was collected, or as required or permitted by applicable laws.

Security: We maintain a risk-based approach to physical, administrative, and technical security measures to protect the confidentiality, availability, and integrity of your Personal Data.

Protecting your Personal Data is a shared responsibility. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Please note, we may change information on the Site and/or this Privacy Policy, at any time without prior notice to you, and any changes will be effective immediately upon the posting of the revised Privacy Policy on the Site. Kiehl's will use your Personal Data in a manner consistent with the Privacy Policy in effect at the time you submitted the information, unless you consent to the new or revised policy. We encourage you to periodically review this page for the latest information on our privacy practices.

If you have any questions or concerns regarding this Privacy Policy, please contact us at [email protected].