PRIVACY AND COOKIE POLICY

Effective Date: November 6, 2018

Estee Lauder A.G. Lachen (“TravelBeautifully.com, we, us, or our”), the data controller(s) for this Policy, respect your concerns about privacy and value the relationship we have with you. This Privacy and Cookie Policy describes the types of personal data we collect about our users, how we use this information, with whom we share it, and the rights of our users regarding our use of the information. We also describe the measures we take to protect the security of the information, how long we retain it and how our users can contact us about our privacy practices and how to exercise their rights.

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Information We Collect & Process

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We may obtain personal data about you during your use of the Site. When you visit the Site, we may collect this information by automated means, using technologies such as cookies, web server logs and web beacons as set out in further detail below.

We will process your personal data to the extent necessary, only if we have a legitimate interest to do so, including to provide the Site; respond to your inquiries; operate, evaluate and improve the Site (including improving or developing new features and functionality, analyzing the Site, performing internal data analytics, and other internal functions); comply with applicable legal requirements, relevant industry standards and our policies; and other internal and other purposes that are appropriate or authorized by applicable law.

Information We Collect by Automated Means

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When you visit this Site, we collect certain information by automated means, using technologies such as cookies, web server logs and web beacons. As set forth in more detail below, we may collect information about your usage and browsing habits using various web-based technologies.

Technologies We Use

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Cookies

Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser.

Most browsers accept cookies by default. You may also be able to change the settings to have your browser refuse certain cookies or notify you before accepting cookies. The procedures for changing your settings and cookies differ from browser to browser. If necessary, use the help function on your browser.

There are different types of cookies, for example:

  • First Party Cookies: Cookies served directly by Estee Lauder A.G. Lachen or its affiliates.
  • Third Party Cookies: Cookies served by third parties, for example by data analytics companies.
  • Session Cookies: Cookies that last for different periods of time, including those that only last only as long as your browser is open and those which are deleted automatically once you close your browser.
  • Permanent Cookies: Cookies that remain after your browser is closed. These cookies will, for example, recognize your device when you reopen your browser and browse the internet again.
  • The following describes the different categories of cookies that we may use:

  • Necessary cookies: These cookies are necessary to provide you with some of the features of the Site, such as supporting log in forms. These cookies do not identify you as an individual.
  • Functional cookies: These cookies allow us to personalize our website for you and remember your preferences such as your log in information, the region from which you logged in and what pages you have viewed. These can be set by us or third parties which provide services to the pages you are visiting. The information these cookies collect may include personal data that you have provided.
  • Performance cookies: These cookies allow us to monitor how the Site is used and how it performs and therefore improve your user experience. For example, we receive information on the number of visitors to the Sites, or which pages are the most popular. We only use the information we receive from these types of cookies in aggregated form. These cookies do not identify you as an individual. These cookies may be served by third parties, such as Google Analytics.
  • Targeting cookies: We work with third parties such as data analytics companies to serve promotional content to users based on location information of current users. We do not decide which cookies are set or how your data is used by these third parties. These cookies uniquely identify the browser and device from which you are accessing the Site, therefore they may collect personal data.

List of Cookies

You have the right to choose whether or not to accept cookies used for certain purposes on the Site. Please note, however, that without certain cookies, your user experience may be impacted.

Cookie Name Cookie Expiration Description
ak_bmsc 2 Hours This performance cookie is used by Akamai to speed the delivery of web content to end users.
AMCV_esteelauder 2 Years This performance cookie is used by Akamai for collecting region ID details.
bm_sv 2 Hours This performance cookie is used by Akamai to protect the site against malicious users.
client.isMobile 1 Year This functional cookie checks if the end user is accessing the site from mobile and redirects the end user to mobile site.
s_cc 1 Year This performance cookie is used by Adobe Site Catalyst to determine whether cookies are enabled in the browser.
persistent_user_cookie 5 Years This persistent cookie is used to collect web surfing behavior or end user preferences for the site.
S_pers 30 Mins This performance cookie is used by Adobe Site Catalyst. It stores persistent analytic information handled by the Adobe Analytics library.
has_js 1 Year This is a functionality cookie used by Drupal to determine whether or not the visitors’ browser has JavaScript enabled.
LOCALE 1 Year This is a functionality cookie used to store language preferences for visitor browser.

Web Server Logs and Web Beacons

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In conjunction with obtaining information through cookies, our web servers may log details such as your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone in which your device is located. The web server logs also may record information such as the address of the web page that linked you to our Site and the IP address of the device you use to connect to the Internet.

To control which web servers collect this information, we may place tags on our web pages called “web beacons.” These are computer instructions that link web pages to particular web servers and their cookies.

Third Party Web Analytics Services

We may use third party web analytics services on this Site, such as Google Analytics. The service providers that administer these services use technologies such as cookies, web server logs and web beacons to collect information (such as IP address) and use that information to help us analyze how visitors use the Site. These vendors may use cookies placed on this Site (such as the Google Analytics cookie) and cookies placed on third-party websites (such as Google advertising cookies), or other third-party identifiers, together, to analyze our Site visitors.

You may deactivate the ability of these analytics services to analyze your browsing activities on this Site. To disable Google Analytics, please download the browser add-on for the deactivation of Google Analytics provided by Google at http://tools.google.com/dlpage/gaoptout?hl=de . To learn more about privacy and Google Analytics please consult the Google Analytics overview provided by Google at: http://www.google.com/intl/en/analytics/privacyoverview.html.

California Do Not Track Notice

For California Residents: Under California law, website and online service operators are required to disclose how they respond to web browser “do not track” signals or other similar mechanisms that provide individuals the ability to exercise choice regarding the collection of personal information about an individual’s online activities over time and across third party websites. We currently do not change our tracking practices in response to “do-not- track” signals or other similar mechanisms. California law also 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 the 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. These third parties do not change their tracking practices in response to “do-not- track” signals from your web browser and we do not obligate these parties to honor “do-not- track” signals. To learn more about browser tracking signals and “Do Not Track,” please visit http://allaboutdnt.org.

Information We Share

We do not sell, rent or otherwise disclose personal data we collect about you, except as described here. We may share your personal data with:

  • Our affiliates for the purposes described in this Privacy and Cookie Policy.
  • Service providers who perform services on our behalf based on our instructions. We do not authorize these service providers to use or disclose the information except as necessary to perform services on our behalf for the purposes listed in this Privacy and Cookie Policy or comply with legal requirements. Examples of these service providers include entities that provide web hosting services.
  • Other third parties with your consent
  • In addition, we and our affiliates and other service providers may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.

    We also reserve the right to transfer personal data we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal data you have provided to us in a manner that is consistent with our Privacy and Cookie Policy. Following such a sale or transfer, you may contact the entity to which we transferred your personal data with any inquiries concerning the processing of that information.

    Your Rights and Choices

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    You have certain rights and choices in connection with the personal data we collect from you.

    • Withdrawing Consent
    • You may withdraw any consent you previously provided to us at any time with effect for the future by contacting us as indicated below. This will not affect the lawfulness of our use of your information based on your consent before its withdrawal.

    • Reviewing, Updating or Deleting Personal Data or Restricting or Objecting to their Use
    • Subject to applicable law, you have the right to request access to and rectification or erasure of the personal data we maintain about you, or to request the restriction of our use of this information, as appropriate. You also have the right to object at any time to the use of your personal data for direct marketing purposes by using the opt-out solution described above. For all other purposes, you may object at any time to the use of your personal data, on grounds relating to your particular situation, in accordance with applicable law. These rights may be limited in some circumstances under applicable law. We may take reasonable steps to verify your identity before granting access or making corrections. You may exercise these rights by contacting us as indicated below.

    • Other Rights
    • Subject to applicable law, you have the right to receive, in a structured, commonly used and machine-readable format, the personal data that you have provided to us about you, with your consent or based on a contract to which you are party. You also have the right to have this information transmitted to another data controller, where it is technically feasible. You may exercise this right by contacting us as indicated below. You also may lodge a complaint with a data protection authority.

      Data Transfers

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      We may transfer the personal data we collect about you to our affiliates and third party service providers to countries other than the country in which the information was originally collected (including the United States), where necessary to fulfill the purposes described in this Policy and your personal data may be processed and stored outside of your country of residence. Those countries may not have the same data protection laws as your country of residence and your personal data will be subject to applicable foreign laws. United States laws have not been recognized by the European Commission as providing an adequate level of data protection. When we transfer your information to other countries, we will protect that information in the manner described in this Privacy and Cookie Policy. We have also implemented appropriate safeguards to ensure such a level of data protection when transferring your personal data, including the conclusion of data transfer agreements incorporating the European Commission’s Standard Contractual Clauses, and our U.S. service providers are certified to the EU-U.S. Privacy Shield as set forth by the U.S. Department of Commerce and the European Commission regarding the collection, use and retention of personal data transferred from the European Economic Area to the United States, or other applicable data transfer mechanisms. You may obtain a copy of these data transfer mechanisms by contacting us as indicated below.

      Data Retention

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      We keep the information you provide for the duration of our relationships, plus a reasonable period in order to be able to run regular deletion routines or to take into account the applicable statute of limitation period or if required under mandatory applicable law.

      How We Protect Personal data

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      We maintain appropriate technical and organizational safeguards to ensure an appropriate level of security of your personal data, in particular to protect your personal data against accidental, unlawful or unauthorized destruction or accidental loss, alteration, unauthorized disclosure, use or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing. However, no security system is perfect and we cannot promise that information about you will remain secure in all circumstances, including the security of your data during transmission to us or the security of data on your mobile device.

      Links To Other Websites

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      Our Site may provide links to other websites for your convenience and information. These websites may operate independently from us. Linked sites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are not owned or controlled by us, we are not responsible for the sites’ content, any use of the sites, or the privacy practices of the sites.

      Updates To Our Privacy and Cookie Policy

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      This Privacy and Cookie Policy may be updated periodically to reflect changes in our data protection practices. We will post a prominent notice on our website to notify you of any significant changes to our Privacy and Cookie Policy and indicate at the top of the Policy when it was most recently updated.

      How To Contact Us

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      If you have any questions or comments about this Privacy and Cookie Policy, or if you would like to exercise your rights, please contact us by email at travelbeautifully@estee.com. You also may write to:

      The Estée Lauder Companies | Travel Retail Worldwide
      767 Fifth Avenue, 41st Floor, New York, NY 10153



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