Privacy

Effective Date: July 29, 2016

DASS (“we, us, or our”) respects your concerns about privacy and values the relationship we have with you. This Privacy Policy describes the types of personal information we collect about our customers, including our online or how we use the information, with whom we share it, and the choices available to our customers regarding our use of the information. We also describe the measures we take to protect the security of the information and how our customers, including can contact us about our privacy practices.

Information We Collect

We may obtain personal information about you from various sources. We may collect this information when you provide it at one of our stores, on our website, via our social media pages, when you download one of our mobile applications (either via Apple iOS or Android) onto your mobile devices, at one of our events or when joining the DASS E-List loyalty program. Our products are available for sale in many department stores. Unless otherwise indicated at the time that you provide your personal information, any personal information collected in these department stores is not provided to us. This Privacy Policy does not address any data collection by our retail partners. When you visit this site, our social media pages, or use services or features of one of our mobile applications, we may also collect certain information about your device or usage by automated means, including using technologies such as cookies, web server logs and web beacons.

Information You Provide

You may choose to provide personal information to us in a number of ways, such as when you participate in an offer or promotion, including DASS E-List, when you make a purchase on our site or in our stores, via our social media pages or through one of our mobile applications. The types of personal information you may provide to us includes:

·    Contact information (such as name, postal address, email address, mobile or other phone number, and mobile service provider)

·    Age and date of birth

·    Gender

·    Username and password

·    Payment information (such as your payment card number, expiration date, delivery address and billing address)

·    Purchase history

·    Product preferences

·    Your physical characteristics and skincare concerns

·    Contact information for friends or other people you would like us to contact

·    Content you provide (such as photographs, videos, reviews, articles, survey responses and comments)

·    Information provided to us through social media networks or one of our mobile applications when you visit our social media pages or use one of our mobile applications (such as your name, profile picture, likes, location, friend list and other information described on the social media network or in application sign-up page, or your geo-location details when using one of our mobile applications)

·    Your DASS E-List membership identification number (for the DASS E-List program)

How We Use The Information

We may use the information you provide to:

·    Send you promotional materials or other communications (such as general DASS Lauder communications and specific DASS E-List communications)

·    Provide services to you

·    Process your payment and/or gift card transactions

·    Create and manage your online account, including access to your online and in-store purchase history

·    Assist with product selection and replenishment, including through our customer registry

·    Administer the DASS E-List 

·    Respond to your inquiries (including requests and inquiries related to DASS E-List)

·    Tailor ads displayed to you on our site and elsewhere to your interests and history with us

·    Communicate with you about, and administer your participation in, special events, contests, sweepstakes, programs (such as DASS E-List), surveys and other offers

·    Operate and communicate with you about our social networking or mobile applications

·    Operate, evaluate and improve our business (including developing new products and services; managing our communications; analyzing our products; performing data analytics; and performing accounting, auditing and other internal functions)

·    Comply with applicable legal requirements, relevant industry standards and our policies

We also may use the information in other ways for which we provide specific notice at the time of collection.

Information We Collect by Automated Means

When you visit this site, view or click on our online advertisements (including our advertisements on third party websites), visit our social media pages or download and use one of our mobile applications, we also collect certain information about your usage or device by automated means or by using technologies such as cookies, web server logs and web beacons. For example, if you use one of our mobile applications, we may collect your IP address, your unique device identifier (or other device identifier) and/or geo location data in order to offer you certain features or functionalities within that mobile application. As set forth in more detail below, we may also collect information about your usage and browsing habits using various web-based technologies.

For your convenience, our mobile applications may also include functionality that allows you to remain logged in to the application so that you do not have to reenter a password each time you want to access the application. IF YOU CHOOSE TO REMAIN LOGGED IN, YOU SHOULD BE AWARE THAT ANYONE WITH ACCESS TO YOUR MOBILE DEVICE WILL BE ABLE TO ACCESS AND MAKE CHANGES TO YOUR MOBILE ACCOUNT AND MAY BE ABLE TO MAKE PURCHASES THROUGH YOUR ACCOUNT. For that reason, if you choose to remain logged in to the application on your mobile device, we strongly recommend you enable the Passcode Lock security feature on your mobile device to protect against unauthorized access to and use of your mobile device and your account in the application.

Technologies We Use

Cookies, Web Server Logs and Web Beacons. 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. Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. Please note, however, that without cookies you may not be able to use all of the features of our website.

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 webpages 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, our social network pages, or our mobile applications, such as those of Adobe Site Catalyst and/or Google Analytics.  The service providers that administer these services use technologies such as cookies, web server logs and web beacons to help us analyze how visitors use the site. The information collected through these means (including IP address) is disclosed to these service providers, who use the information to evaluate use of the website. You may deactivate the ability of these analytics services to analyze your browsing activities on this site. To learn more about web analytics services, and exercise your choice with respect to their collection of information on this site:

·  For Adobe Site Catalyst, please
·  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=en. 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.

Targeted Advertising

We also may contract with third-party advertising networks that collect IP addresses and other information through the use of cookies, web server logs and web beacons on our websites and emails; on third-party websites and emails; and on our advertising placed on third-party websites. They use this information to provide advertisements about products and services tailored to your interests (including for companies not affiliated with us). You may see these advertisements on our websites and other websites. This process also helps us manage and track the effectiveness of our marketing efforts. To learn more about advertising networks and to opt out of interest-based advertising, visit the Digital Advertising Alliance at www.aboutads.info/choices or the Network Advertising Initiative at www.networkadvertising.org/choices.

How We Use the Information Collected by Automated Means

We may use the information collected through automated means on this site for market research, data analytics and system administration purposes, such as to determine whether you’ve visited us before or are new to the site, to tailor ads displayed to you on our site and elsewhere and for compliance with our legal obligations, policies and procedures, including compliance with relevant industry standards and the enforcement of our Terms and Conditions. We also may use the information in other ways for which specific notice is provided at the time of collection.

California Do Not Track Notice

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 consumers the ability to exercise choice regarding the collection of personal information about a consumer’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 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. 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 rent lists, or sell or otherwise disclose personal information we collect about you, except as described here. We may share your personal information with:

·  Our corporate affiliates. For additional information regarding our corporate affiliates please see http://www.elcompanies.com/.

·  Third party 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 or comply with legal requirements. Examples of these service providers include entities that process credit card payments, fulfill orders and provide web hosting, advertising and marketing services.

·  Other third parties with your consent (e.g., some of our Facebook applications may share information collected through those apps with your Facebook friends or other Facebook users).

In addition, we 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 information 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 information you have provided to us in a manner that is consistent with our Privacy Policy. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.

Text Messaging

If you so elect, you may provide your mobile phone number to Estée Lauder. By submitting your mobile phone number, you consent to receive text message alerts from Estée Lauder containing product and event information, cosmetics tips or promotions that may be sent using automated dialing systems (“Text Messages”). Your consent to receive Text Messages is not otherwise required to purchase any goods or services from us. You may not consent to receive Text Messages on behalf of someone else or provide someone else’s phone number. You agree to enter into, sign and receive your consent to receive Text Messages electronically. Print this page using your Internet-connected computer or device and web browser to retain a copy of your consent. You can contact us as set forth under “How to Contact Us” below to request a free copy of your consent.

You may receive approximately five recurring texts per month. We do not charge a fee for you to receive Text Messages from us, however, your mobile service provider may charge you for sending and/or receiving text messages and air-time, as well as any other standard applicable rates charged by your mobile service provider. Participating Carriers are:

·    ACS Wireless

·    Cox Wireless

·    Pocket Wireless

·    Alltel

·    Cricket Communications

·    Revol Wireless

·    All West Communications

·    Element Mobile

·    Silver Star PCS

·    Appalachian Wireless

·    Farmers Mutual Telephone Co.

·    Simmetry Wireless

·    AT&T

·    GCI Wireless

·    Snake River PCS

·    Bluegrass Wireless

·    Golden State Cellular

·    South Central Communications

·    Boost

·    Illinois Valley Cellular

·    Sprint

·    Boost Unlimited

·    Immix

·    Sprocket Wireless

·    Breakaway Wireless

·    Inland Cellular

·    Strata Networks

·    Carolina West Wireless

·    iWireless

·    Syringa Wireless

·    Cambridge Telephone Company (CTC)

·    Metro PCS

·    Thumb Cellular

·    Cellcom

·    Midwest Wireless

·    T-Mobile

·    Cellular South

·    Nex-Tech Wireless

·    United Wireless

·    Cellular One of East Central Illinois

·    Nextel

·    Union Wireless

·    Cellular One of Montana

·    Northwest Missouri Cellular

·    U.S. Cellular

·    Cellular One of NEPA

·    nTelos

·    Verizon Wireless

·    Centennial Wireless

·    Nucla-Naturita Telephone Co.

·    Viaero Wireless

·    Chat Mobility

·    Panhandle Telecommunications

·    Virgin Mobile US

·    Cellular 29

·    Pioneer Cellular

·    West Central Wireless

·    Cincinnati Bell

·    Plateau Wireless

Text Messages are distributed via third party mobile network providers and, therefore, we cannot control certain factors relating to message delivery or guarantee availability or performance of this service, including liability for transmission delays or message failures.

We may also obtain the date, time and content of your messages in the course of your use of Text Messages. We will use the information we obtain in connection with our Text Messages in accordance with this Privacy Policy.

From time to time you may be asked to provide your mobile phone number to DASS in connection with special text messaging programs, which are in addition to the general DASS marketing text messaging program. That text messaging program may have additional or different terms and conditions from those set forth above, which will be presented you at the time that you opt-in to receive those text messages. In general, in order to stop receiving text messages from a specific DASS text messaging program, you can text STOP to the five digit short code for the text messaging program from which you no longer wish to receive message (i.e., the five digit number from which its text messages are being sent). You will then receive confirmation of your opt-out of that text messaging program. This will only opt you out of the specific text messaging program associated with that five digit short code. You will remain opted in to any other DASS text messaging programs that you have signed up for.

Push Notifications and In-App Alerts and Updates

When you download one of our mobile applications, we may provide you with the option to opt in to receive push notifications from us on your mobile device in connection with that mobile application. These push notifications may include promotional communications regarding our products and services. You may, after downloading the applicable mobile application, opt out of receiving push notifications by adjusting the settings on your mobile device. Opting out of push notifications will not affect other communications you receive from us, such as email communications. You also may receive alerts and updates within our mobile applications regarding our products and services or your accounts with . To opt out of receiving these alerts and updates, you may uninstall the applicable mobile application from your mobile device.

Your Rights and Choices

We offer you certain choices in connection with the personal information we collect from you, such as how we use the information and how we communicate with you. To update your preferences, ask us to remove your information from our mailing lists or submit a request, please contact us in the manner specified below.

Email Opt-Out

You can at any time tell us not to send you marketing communications by email by clicking on the unsubscribe link within the marketing emails you receive from us or by contacting us as indicated below. You also may opt out of receiving marketing emails from DASS by clicking here.

You may opt out of receiving E-List emails that are not necessary to provide you with E-List membership services by following the instructions provided in the email. Although you may opt out of E-List marketing emails, operational emails will still be sent to you. Examples of these include, but are not limited to, a welcome email, periodic point status update email, or other communications that relate to your account. In order to stop receiving all E-List emails, you must terminate your E-List membership.

Postal Mail Opt-Out

You can ask DASS to stop sending you marketing communications by postal mail by following the instructions that maybe included in a particular promotion. You also can request that we refrain from sending you promotional postal mail by contacting us as indicated below.

Text Message Opt-Out

In general, in order to stop receiving text messages, you can text STOP to the five digit short code for the text messaging program from which you no longer wish to receive message (i.e., the five digit number from which the text messages are being sent). You will then receive confirmation of your opt-out of that text messaging program. Please note that this will only opt you out of the specific text messaging program associated with that five digit short code. You will remain opted in to any other Estée Lauder text messaging programs that you may have signed up for.

To unsubscribe from the DASS general marketing text messaging program you can text “STOP” from your device.

Social Networking Application Opt-Out

To remove or delete our social media applications from your social networking account, follow the instructions from the social network:

When you use one of our mobile applications, we may ask you for your geo-location. You may choose not to share your geo-location details by adjusting your mobile device’s location services settings. To decline from sharing your geo-location details, follow the instructions on your mobile device on changing the relevant settings; otherwise, please contact your service provider or device manufacturer.

Withdrawing Consent

You may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your personal information. We will apply your preferences going forward. In some circumstances, withdrawing your consent to our use or disclosure of your personal information will mean that you cannot take advantage of some of our products or services.

Reviewing, Updating and Modifying Personal Information

Subject to applicable law, you may have the right to request access to and receive details about the personal information we maintain about you, update and correct inaccuracies in your personal data, and have the information blocked or deleted, as appropriate. The right to access personal information may be limited in some circumstances by local law requirements. We may take reasonable steps to verify your identity before granting access or making corrections. You may request to review, change or delete your personal information by sending an email to custsrv@donshaw.com.

Data Transfers

We may transfer the personal information we collect about you to countries other than the country in which the information was originally collected and your personal information 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 information will be subject to applicable foreign laws. When we transfer your information to other countries, we will protect that information in the manner described in this Privacy Policy.

Children's Privacy

If you are under thirteen years of age, you may browse our site. However, you may not provide personal information to us and you may not download any of our mobile applications. This site is not directed to children under the age of thirteen and we do not knowingly collect personal information from children under the age of thirteen on the site. If we become aware that we have inadvertently received personal information from a visitor under the age of thirteen on the site, we will delete the information from our records.

How We Protect Personal Information

We maintain appropriate administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. 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

Our website 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 Policy

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a prominent notice on our website to notify you of any significant changes to our Privacy Policy and indicate at the top of the Policy when it was most recently updated.