PRIVACY POLICY

Date of Last Update: 27 October 2022

Welcome to www.evelom.co.uk (the "Site"), a website operated in the United Kingdom by Space Brands Limited, a company incorporated in England and Wales with company registration number 07932315, VAT number 131022286 and whose registered office is located at First Floor, 175-176 Tottenham Court Road, London W1T 7DE, United Kingdom ("Space Brands", "we", "us" or "our").

Space Brands values its customers and respects their privacy. Any information we collect about you is held with the utmost care and security. Your visit to our Site and your use of any of the services or features we provide is subject to our terms and conditions of which this Privacy Policy forms part. This policy (together with our Website Terms of Use, Cookie Policy and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting this Site or using any services or features offered on this Site you acknowledge the practices described in this Privacy Policy, in particular:

  • The processing of your personal data in accordance with this Privacy Policy as described in Section 3 of this Privacy Policy; and
  • The transfer of your personal data outside of the EEA or the UK as described in Section 5 of this Privacy Policy.

We do not knowingly or intentionally collect any information from children under the age of 13. If you are under the age of 13 you may look at our Site but you may not make a purchase, register or submit any personal information to us. If we become aware that we have inadvertently received personal information from a visitor under the age of 13 on the Site, we will delete the information from our records.

For the purposes of applicable laws, the data controller is Space Brands Limited, a company incorporated in England and Wales with company registration number 07932315, VAT number 131022286 and whose registered office is located at First Floor, 175-176 Tottenham Court Road, London W1T 7DE United Kingdom.

This Privacy Policy does not cover information that you submit on other websites, even if we communicate with you on those websites. For example, if you post something on Facebook, Twitter, Instagram or YouTube, that information is governed by the privacy policies on those websites and is not governed by this Privacy Policy.

  1. Information we collect from you

1.1 Information you give to us. You may give us information about you by filling in forms on our Site or by corresponding with us by telephone, e-mail, post or otherwise. This includes information you provide when you register to use our Site (which you must do if you would like to use some of the services and features we offer), subscribe to our services or place an order on our Site. This information may include your name, address, telephone number, e-mail address and debit or credit card information (if you wish to place an order on our Site). When you register with us you can view your personal information in 'My Account'. You can access 'My Account' directly to amend any personal details, for example if you change your address. If you forget your password, simply click on the 'forgotten password' link on the register or login page and an e-mail containing your decrypted password will be sent to the e-mail address that you originally provided. You may also provide other personal information (such as suggestions, messages or other materials – “User Content”) that you post on our social media accounts, email, share or otherwise make available to us.

1.2 Information we collect about you. With regard to each of your visits to our Site, we may automatically collect the following information:

  • technical information including the Internet Protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
  • information about your visit including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any telephone number used to call our customer service number.

1.3 Information we receive from other sources. We may receive information about you if you use any of the other websites we (or any member or brand within our Group) operate or other services we provide. 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 this Site. We are also working closely with third parties (including, for example sub-contractors in technical, payment and delivery services, advertising networks, marketing services, analytics providers, search information providers, and credit reference agencies) and may receive information about you from them.  

  1. Cookies

Our Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookie Policy [hyperlink].

  1. Use made of the information

We use information held about you in the following ways:

3.1 Information you give to us. We will use this information in relation to:

(a) Administration of our Site and performance of our contract with you

The information you give to us is necessary to enable us to:

  1. fulfil your order (including acknowledging your order and communicating with you if there is any issue regarding the fulfilment of your order);
  2. make sure your order is delivered correctly.

 

Our lawful basis for the purposes listed above is that the collection and processing is necessary for the performance of a contract to which you are a party.

 

  1. Maintain your account,
  2. conduct accounting, billing, reporting and audit; conduct authentication and identity checks; conduct credit, debit or other payment card verification and screening;
  3. carry out debt collection; and legal and administrative purposes.

Our lawful basis for processing your personal information for the purposes listed above is that it is necessary for the purpose of our legitimate interests in communicating with our customers and operating our business.

(b) Providing customer service in pursuit of our legitimate interest as a retailer

We ask for your contact details such as your e-mail address, telephone number and order details to enable us to:

  1. answer any questions you have about using our Site;
  2. notify you about the status of your order, and
  3. provide other customer care services such as identifying your requirements and shopping preferences. To provide those customer care services we may use your data for statistical and market analysis; studies, research and development by us, or a third party we appoint as a data processor. We may anonymise your personal data for the use of it by these parties.

Our lawful basis for processing your personal information is that it is necessary for the purpose of our legitimate interests in communicating with our customers and operating our business.

(c) Direct marketing

In order to improve your shopping experience with us we want to keep you up-to-date on our latest products, promotional offers and events. We will only contact you with marketing materials if you have consented to this, or as otherwise permitted by law.

Our lawful basis for processing your personal information is either that (a) you have provided your consent to the use of your information for direct marketing purposes; or (b) it is necessary for the purpose of our legitimate interest in marketing our products.

Profiling and behavioural analysis: We may use the information you provide and the information we collect about you to build a picture of your interests so that we (or a third party appointed by us) may tailor our communications to you to ensure they are relevant and of interest to you and so that when you visit our Site we can tailor your experience so that it is easier to shop with us.

Opt-out of direct marketing: You can at any time tell us not to send you marketing communications (i) by e-mail by clicking on the unsubscribe link within the marketing e-mails you receive from us; (ii) by SMS by following the "STOP" instructions provided with the message, or (iii) by postal mail by following the instructions that may be included in a particular promotion. If you have registered with us, you may also opt out of receiving postal mail from us by logging into your account and amending your preferences.

(d) Our service

To notify you about changes to our service.

Our lawful basis for processing your personal information is that it is necessary for the purpose of our legitimate interests in communicating with our customers and operating our business.

(e)  Our Site

To ensure that content from our Site is presented in the most effective manner for you and for your computer, and so that we can enhance your experience of using our Site.

Our lawful basis for processing your personal information is that it is necessary for the purpose of our legitimate interests in managing the Site.

3.2 Information we collect about you. We will use this information in relation to:

(a) Administration of our Site

To administer our Site and for internal operations including troubleshooting, data analysis, testing, research, statistical and survey purposes. We may collect information from visitors to our site and analyse it to build up a picture of how people use our website. This helps us to improve the service we offer you.

Our lawful basis for processing your personal information is that it is necessary for the purpose of our legitimate interests in administering our Site.

(b) Site improvement

We will process personal information in order to improve our Site and ensure that content is presented in the most effective manner for you and your computer.

Our lawful basis for processing your personal information is that it is necessary for the purpose of our legitimate interest in communicating with our customers and operating our business.

(c) Providing customer service in pursuit of our legitimate interest as a retailer

The information we collect from you will:

  1. allow you to participate in interactive features of our service when you choose to do so;
  2. allow us to measure or understand the effectiveness of advertising we serve to you and others; and
  3. allow us, or third parties appointed by us to make suggestions and recommendations to you and other users of our Site about goods or services that may be of interest to you or them if you have agreed to be contacted by us for these purposes or as otherwise permitted by law.

Our lawful basis for processing your personal information is that it is necessary for the purpose of our legitimate interests in providing a high level of customer service to our clients.

(d) Security of our Site

We will process personal information as part of our efforts to keep our Site safe and secure.

Our lawful basis for processing your personal information is that it is necessary for the purpose of our legitimate interests in keeping the Site and your information safe.

3.3 Information we receive from other sources. We may combine the information we collect from you and the information you provide to us with information we receive from other sources, such when you use a third party app or feature (such as on Facebook or Instagram) through which you allow us to collect (or the third party to share) information about you. We use Facebook Custom Audiences and Google Ads Audiences to deliver targeted advertisements to individuals who visit our website.

We may use this combined information for the purposes set out above in this section 3 (depending on the types of information we receive), and when processing any personal information, we will rely upon the associated lawful basis described above in this section 3.

  1. 4. Disclosure of your information

4.1 We may share anonymised, aggregated versions of your personal information with the members and brands within our Group. In addition, we may share your personal information with any member or brand within our Group. Please visit www.yatsenglobal.com for more information about our “Group” and brands.      

4.2 From time to time we retain the services of other carefully selected and monitored companies and individuals to perform functions on our behalf in connection with the successful operation and continuous improvement of this Site. These companies and individuals are appointed as data processors. We may share your information with selected third parties including:

(a) Suppliers and sub-contractors for the performance of any contract we enter into with them or you (e.g. in order to process your order and maintain your account, including the authorisation and validation of credit or debit card transactions, the provision of delivery services, the analysis of data.). These companies or individuals may be provided with access to your personal details in order to fulfil their function but may not use such information for any other purpose.

(b) Advertisers, marketing agencies, social media agencies and platforms (such as Facebook and Instagram), software providers and advertising networks we appoint to assist us and who require the data to select and serve relevant adverts or other promotional activities to you on our behalf. Online retargeting is a form of online advertising that allows us and some of our advertising partners to show you advertising based on your browsing patterns and interactions with our websites. For example, when you have visited our website then moved to another site, you may start seeing our adverts displaying special offers or reminding you of the products you were browsing on our website. The technology behind these adverts is based on cookies. More information about how we use cookies and how you can, if you wish, turn off cookies is included in our Cookie Policy. This processing constitutes profiling under applicable data protection laws. We process your personal data in this way as it is in our legitimate interest to offer you a personalised experience on our sites and to provide you with personalised advertising and marketing.

(c) Analytics and search engine providers, such as Google that assist us in the improvement and optimisation of our Site.

4.3 We do not provide your personal details to other companies or individuals for their marketing purposes unless you have indicated that you wish to receive information about other companies' products, offers and services.

4.4 We may disclose your personal information to other third parties:

(a) In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

(b) If Space Brands (its holding company, or the holding company of its holding company, and their subsidiaries, as defined in section 1159 of the UK Companies Act 2006) or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

(c) If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use or terms and conditions of supply and other agreements; or to protect our rights, property, or safety (or the rights, property, safety of our customers, or others). This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

  1. Where we store and process your personal data

5.1 The data that we collect from you may be transferred to and stored at a destination outside of the country in which it was originally collected. This may include transfers outside of the European Economic Area ("EEA") or the UK (including to the USA). The reason for this transfer is that some of the operations undertaken in order to complete our contract with you or to enhance your experience with us are located outside of the EEA or the UK, for instance it may be processed by staff working outside of the EEA or the UK who work for us or for one of our suppliers or service providers. Such staff may be engaged in, amongst other things, the fulfilment of your order, the processing of your payment details and the provision of support services including marketing and analytics. We may also transfer your data outside of the EEA or the UK when we transfer your data to any brand within our Group, third party service providers or other third parties as specified in Section 4.1, 4.2 and 4.4, respectively, of this Policy. Such transfers may be required to conclude our contract with you or exercise our legitimate interests as a retailer.

5.2 We will take all steps reasonably necessary to ensure that your transferred data is treated securely and in accordance with this Privacy Policy and applicable law. Where necessary, this will include adopting appropriate safeguards such as model clauses approved by (i) the European Commission or (ii) the Secretary of State or the Information Commissioner’s Office (as applicable) in order to ensure that any transferred personal information receives an adequate level of protection. You should be aware that personal information stored outside the country where it was collected may be available to government authorities of the countries where it is stored, under applicable data disclosure laws of those countries. We use the latest strong encryption technology to ensure that all transactional information is protected to the highest standard. Transactional information includes your personal contact information together with any other names and addresses you provide when you place an order for delivery to another address, and your purchasing history.

5.3 If you have entered your details required for the ordering process, our Site will retain your Eve Lom account details such as your name, address, e-mail address and purchasing history. Each time you log into your Eve Lom account to create a new order you must re-enter your credit card details. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

5.4 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

  1. Third party websites

Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

  1. Data Retention and Destruction

We store data for as long as it is necessary to provide products and services to you and others and so long as we are legally required to do so. Information associated with your account will be kept until your account is deleted, unless we no longer need the data to provide products and services, or until any legal requirement to keep it no longer exists. When we no longer need personal data, we securely delete and destroy it.

  1. Rights of Data Subjects

As a data subject and in accordance with applicable laws you have the right to the following:

  • a right of access to a copy of the information comprising their personal data;
  • a right to object to processing that is likely to cause or is causing damage or distress;
  • a right to prevent processing for direct marketing;
  • a right to object to decisions being taken by automated means;
  • a right in certain circumstances to have inaccurate personal data rectified, blocked, erased or destroyed;
  • a right in certain circumstances to have your personal data erased;
  • a right to data portability; and
  • a right to claim compensation for damages caused by a breach of applicable laws.

You may exercise these rights by sending a written request by e-mail through the “Contact Us” page on our website at www.evelom.co.uk

 

You also have the right to complain to your data protection regulator. In the UK this is the Information Commissioner’s Office, who can be reached at: https://ico.org.uk/global/contact-us/.  If you are not happy about the handling of your personal information, then we would encourage you to contact us first, so that we can try to resolve matters directly with you.

 

  1. Changes to our Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our Privacy Policy.

  1. Contact

Questions, comments or requests regarding this Privacy Policy are welcomed and should be addressed by email through the “Contact Us” page on our website at www.evelom.com

  1. Non-waiver

No failure to exercise and no delay on the part of Space Brands in exercising any right, remedy, power or privilege of Space Brands under this Privacy Policy and no course of dealing between us shall be construed or operate as a waiver, nor shall any single or partial exercise of any right, remedy, power or privilege preclude any other or further exercise thereof or the exercise of any other right, remedy, power or privilege on the part of Space Brands.

  1. EU Data Protection
Representative of controllers or processors not established in the European Union (Article 27 GDPR):
ePrivacy GmbH
Große Bleichen 21
20354 Hamburg
Germany
https://www.eprivacy.eu