Privacy Policy

Effective Date: August 13, 2025

 

  1. Introduction

 

  1. VB Beauty (US) LLC (the "Company", "we", "us" or "our") respects your privacy and is committed to safeguarding your privacy and reasonably and transparently handling your personal data. This Privacy Policy (“policy”) outlines how we collect, use, share, and protect your information when you visit our website https://victoriabeckhambeauty.com, use our services, or make purchases from us.

 

This policy governs our global operations and encompasses specific measures intended to comply with data protection laws relevant to our audience including but not limited to users in the United Kingdom (UK), European Union (EU), and United States, including those in California, Nebraska and Texas (collectively, "Data Protection Legislation").

 

  1. This policy is our data promise to you. Please read it carefully. Among other things, it explains:

 

  • what personal data we may collect about you in connection with: (i) providing you with our goods and services; (ii) your online interaction with us (including via our website, email or social media channels); (iii) our in-person interactions with you (such as in-store); and (iv) any other channels related or ancillary to the foregoing; (collectively, the "Channels");
  • how we collect, store, disclose, transfer, protect and otherwise process that information and for what purposes; and
  • other important information, such as the lawful bases by which we process your personal data, how long we might retain your personal data, and the rights you have in relation to personal data we hold about you.

 

  1. This policy supplements (and its terms apply in addition to) any other terms of use or other terms and conditions agreed between you and the Company from time to time.

 

  1. In this policy, terms defined in Data Protection Legislation, including "data subject", "personal data" or “personal information”, and "processing", have the same meaning when used in this policy. The words "include", "including", "such as" and similar words and phrases shall be construed to mean "including without limitation".

 

  1. This policy is intended to be communicated to you in a concise, transparent, intelligible and easily accessible manner, but we appreciate that you may have queries or want to seek clarification as to its terms. If so, please email beauty@victoriabeckhambeauty.com and we will endeavour to respond as soon as possible.

 

  1. The Company reserves the right to make changes to this policy in order to reflect any changes in Data Protection Legislation and best practices from time to time. The Company will endeavour to notify you of such changes but you are advised to check for an updated version of this policy at Privacy Policy each time you interact with us through the Channels.

 

  1. The personal data we process

 

  1. How we collect your personal data

 

We collect personal data about you through the Channels, including when you:

  • access and use our website (including by way of cookies and other tracking technologies – please refer to paragraph 2.3(Cookies and Other Tracking Technologies) below for more information);
  • register for an account on our website or subscribe for other services, contests, special events or our mailing list;
  • sign up for our loyalty program;
  • create an account;
  • purchase a product from us;
  • request technical support or other customer care support;
  • participate in polls, surveys, quizzes and questionnaires;
  • contact us (whether in writing, by email, by telephone or otherwise);
  • post content on our social media pages; or
  • otherwise interact with us through the Channels.

 

  1. Information We Collect

 

We collect various types of personal data, including:

 

  • Contact Information: Full name, email address, telephone number, postal address and other information provided by you. This information is collected when you create an account, subscribe for email marketing or text message, make a purchase, or contact us.
  • Payment Information: Credit/debit card number, expiration date, security code (credit verification code (CVC) or credit verification value (CVV)), billing address, and order and transaction details. This information is collected when you purchase our products.
  • Account Information: Username, password (which is encrypted),  beauty interest (including skin tone), reviews, and purchase history and shopping or consuming histories. This helps us manage your account and provide personalised services.
  • Social Media Information: If you post a photograph or video on social media and tag us or if you post a comment on our social media pages, we will collect the photograph, video or content of that message. Please note that if you choose to post a photograph or video on social media and tag us or post a comment on any of our social media pages, any information you post will be visible to any other visitors to that social media page. We are not responsible for any personal information you include in such posts or for any use of such information by any other visitor to the social media page.
  • Technical Data: IP address, browser type, device type, operating system, referring URLs,  browsing history (e.g., pages viewed), search queries, geographic location, access times and dates and other technical information such as protocol status and substatus, bytes sent and received, and server information. This data is collected automatically via cookies and similar tracking technologies.
  • Usage Data: Information about how you use our website and services and the actions you take on our website, including pages visited, time spent on pages, and click stream.
  • Marketing Data: Your preferences for receiving marketing communications from us and your responses to marketing campaigns.

 

We do not process:

 

  • any special categories of personal data (including details about your religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). However, if you provide us with photographs or videos, it may be possible to infer your racial or ethnic origin. Company will only use and disclose such information as necessary to fulfill the purposes of collection or as permitted under Data Protection Legislation and we will not sell or share such information;
  • any information about criminal convictions and offences; or
  • any information about children under the age of 18, and you should not provide us with any such information through any of the Channels.

 

  1. Cookies and Other Tracking Technologies

 

  1. Cookies

 

A cookie is a small file of letters and numbers stored on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a better experience when you browse our website and also allows us to improve our website.

 

Some data collected by cookies is collected on an anonymous and/or aggregated basis. Where we use cookies that contain personal data, we will only process that personal data as set out in this policy.

 

Our website uses some or all of the following cookies:

 

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. Without these cookies, certain aspects of our website may not be available to you.
  • Analytical/performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by enabling  users to find what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of region).
  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

 

We may also use third-party cookies, like Google Analytics, for example, which sets cookies on our website to help analyze how visitors use our website. You can visit https://www.google.com/settings/ads to learn more about Google’s use of cookies. If you would like to opt-out from the use of your information by Google Analytics, you may use Google Analytics’ opt-out browser add-on designed for this purpose.

Your browser may give you the ability to block all or some cookies by activating a setting in your browser's options. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

 

Except for essential cookies, all cookies will remain unless the cookie cache is cleared (unless otherwise indicated in the table above).

 

To manage all cookies on our website, including those that are served by us, you can change your browser settings or change your preferences through our website’s cookie management tool here. For additional information on how to manage all cookies please visit http://www.allaboutcookies.org/. Please note that disabling, blocking or deleting cookies in your browser settings may impact your ability to fully use our website.

 

  1. Web Beacons and Pixels

 

A web beacon / pixel is an HTML code snippet embedded in a website or email that collects information about user behaviors and interactions with the website or email.

 

We may utilize web beacons / pixels both on certain aspects of our website and in HTML-formatted email messages to you. Web beacons / pixels may be used for the purpose of, among other things, measuring the success of our marketing campaigns, compiling statistics about our website usage and tracking the activities of users of our website and email recipients. For instance, we may use pixels from Meta on our website to enable us to create targeted advertisements and measure the effectiveness of our advertisements. For additional information on interest-based advertising, please see paragraph 3 (Interest-Based Advertising).

 

 

  1. Interest-Based Advertising

 

We may collect information about your online activities on our website to provide you with advertising about products tailored to your individual interests. We also may obtain information for this purpose from third-party websites on which our advertisements are served.

 

You may see certain advertisements on other websites because we work with advertising partners (including advertising networks) to engage in remarketing and retargeting activities. Our advertising partners allow us to target our messaging to users through demographic, interest-based and contextual means. These partners track your online activities over time and across websites, including our website, by collecting information through automated means, including through the use of third-party cookies, web server logs and web beacons/pixels. They use this information to show you advertisements that may be tailored to your individual interests. The information our advertising partners may collect includes data about your visits to websites that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our website and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts. For example, we utilize certain of our advertising partners’ targeted advertising services to show you our advertisements on other websites based on your prior visits to our website and other online activity.

 

Provided that a company participates in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising, you may opt out of interest-based advertising generally through the Network Advertising Initiative website or by visiting http://www.aboutads.info/choices/ (web-based advertising) or http://www.aboutads.info/appchoices (for mobile advertising). You may also manage your tracking technology preferences through our website’s cookie management tool here. To learn more, please visit the websites operated by the Network Advertising Initiative and Digital Advertising Alliance at www.networkadvertising.org/choices. Opting-out does not mean that you will stop receiving advertisements from us. It means that you still stop receiving advertisements from us that have been targeted to you based on your visits and browsing activity across websites over time.

 

  1. The purposes for which we process your personal data

 

We use the personal data referred to in paragraph 2 (The personal data we process) above for the purposes of (if and as applicable):

 

  • providing the Channels to you;
  • personalising content on the Channels;
  • sending you promotional and marketing materials, notifications, updates and exclusive news (including when you subscribe to our newsletters or opt-in to receive promotional text messages from us), providing interactive features on website, identifying product and shopping preferences using information we collect from you and about you;
  • providing you with access to our products and services and fulfilling product orders;
  • Internal training and other internal operational uses to improve our services and customer experience (including improving our marketing and promotional efforts, analysing Channel usage statistics, improving content and product offerings and customising the content and layout of our stores and website);
  • responding to any correspondence from you including enquiries, comments, complaints and technical problems;
  • administering any polls, services, quizzes, newsletters, questionnaires, contests, or special events which you may have subscribed for;
  • administering our loyalty program;
  • recording your purchase history and creating, managing and administering your account with us;
  • market research and demographic studies;
  • for customer service, security, to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of our website;
  • carrying out our business activities in circumstances where you ought reasonably to have an expectation that we will process your personal data for a particular purpose (including but not limited to audits, developing new products, enhancing our website, improving our products and services, identifying website usage trends, determining the effectiveness of our promotional campaigns and as may be provided for in our Terms of Use or other arrangement between us); and
  • as we believe to be necessary or appropriate: (i) under applicable law; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to enforce this policy and our Terms of Use; (v) to protect our operations; (vi) to protect our rights, privacy, safety or property, and/or that of you or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.
  • We may process your personal data for the purposes set out in paragraph 4 (The purposes for which we process your personal data) ourselves or in conjunction with our third-party service providers in accordance with paragraph 7 (Sharing information with affiliates and third parties).

 

  1. The lawful bases by which we process your personal data

 

We process your personal data based on the following legal grounds, which apply to users in the UK, EU, and other relevant Data Protection Legislation:

 

  • Consent: We may use your information with your consent. In these instances, we will ask you to grant us consent to use your information. You are free to grant or deny permission. If you deny permission, we will not be able to process your information to conduct the activity to which the consent relates. For example, by accepting the terms of this policy, you give the Company your express, freely given consent to process any of your personal data in accordance with the terms of this policy. You may withdraw your consent (in whole or in part) at any time by contacting support@victoriabeckhambeauty.com. The withdrawal of your consent shall not affect the lawfulness of processing based on consent before withdrawal or the lawfulness of processing based on other lawful grounds as set out below. If you have granted us consent to use your information, we will use it only for the purposes specified when we request your consent. This includes use for our marketing campaigns. If you sign up for our newsletter or to receive text messages from us, you allow us to use your email address or telephone number for marketing related to our website and products. We will use your personal data to send you emails or text messages containing newsletters, promotions and special offers. You may unsubscribe from such emails or text messages at any time by clicking the unsubscribe button in such emails and replying “STOP” to such text messages.
  • Contractual Necessity: in order to perform any agreement between us (including pursuant to our Terms of Use or for us to fulfil an order placed by you). For example, if you use our website or if you purchase our products, we use your information to provide to you the features and functionality of our website and our products, including for customer service;
  • Legal Obligation: to comply with any applicable law or regulation or any regulatory requests (e.g., retain certain information according to tax or commercial laws, respond to your requests to exercise your rights under Data Protection Legislation); or
  • Legitimate Interests: for the purposes of the legitimate interests pursued by us or third parties except where such interests are overridden by your interests or fundamental rights and freedoms. These legitimate interests include the purposes identified above in paragraph 4 (The purposes for which we process your personal data) but also include other general commercial interests and our internal administrative purposes.

 

  1. What if you refuse to provide us with any personal data?

 

  1. Where we need to collect personal data by law, or under the terms of an agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

 

  1. Whilst we may be able to provide you with certain products and services notwithstanding your refusal to submit personal data, this may limit your ability to participate in some activities or features or your use of certain online services.

 

  1. We may lawfully obtain information from third parties or public sources and we may process that information where it is an essential component of the products and services we offer you.

 

  1. Sharing information with affiliates and third parties

 

We will not disclose any of your personal data with third parties except as set out in this policy or as otherwise notified to you or agreed between you and us from time to time. We may share personal data with our group companies, including our subsidiaries, affiliates and other related companies  (together, "Affiliates") for our internal business purposes.

 

From time to time, we will also disclose personal data with our third party service providers who we engage to provide services which facilitate our business and who may need to process your personal data to the extent necessary to provide those services. Such service providers may include:

 

  • email service providers;
  • retail management, payment processing and point of sale services;
  • credit reference and fraud prevention services (as well as law enforcement and fraud prevention agencies more generally);
  • professional service providers, such as marketing agencies, advertising partners and website hosts;
  • logistics companies;
  • professional advisors, including accountants, auditors, lawyers, insurers, and bankers, where necessary to obtain advice or otherwise protect and manage our operations and business interests;
  • address verification services;
  • integration platform providers;
  • Other third parties approved by you, such as social media sites which you link to your Victoria Beckham Beauty account (if and when we offer that feature) or share content via or third parties who administer any competitions or surveys on our behalf which you voluntarily partake in; and any similar or replacement third parties from time to time.

 

Additionally, as noted above, we may share information collected through tracking technologies set on our website with our website analytics and digital advertising service providers, such as Google Analytics. Where videos are embedded on our website, some of our service providers may also collect video viewing information and your device ID or other identifier. You can manage the tracking technologies deployed on our website, including those that are served by us, by changing your browser settings or change your preferences through our website’s cookie management tool here.

 

We may disclose your personal information with third parties where we are required to do so by law or regulation (such as in connection with an investigation of fraud or other legal enquiry) or in connection with other legal proceedings (including where we believe that your actions violate applicable laws, our Terms of Use, or any usage guidelines for specific products or services, or threaten the rights, property, or safety of our Company, our users, or others).  We may also disclose your personal information as needed to support external auditing, compliance and corporate governance functions.

 

We may disclose personal data in connection with, or during negotiations of, certain corporate transactions, including the divestiture, merger, consolidation, sale of company assets, financing, bankruptcy, or acquisition of all or a portion of our business by another company.

 

Company does not share your personal information with third parties for those third parties’ direct marketing purposes.

 

  1. International transfers of personal data

 

Your personal data may be transferred to and processed in countries outside your residence, including to our servers and those of our third-party providers located in the United States and other jurisdictions. We will transfer your personal data in compliance with applicable Data Protection Legislation through the use of adequate safeguards to protect your data.

 

  1. Your rights as a data subject

 

Subject to any conditions or requirements set out in the relevant Data Protection Legislation, you may have some or all of the following rights in relation to the personal data we hold about you:

 

  • Right to Access: The right to obtain confirmation as to whether your personal data is being processed, as well as the right to request access to the personal data we hold about you along with certain information, including the purposes of the processing, the categories of personal data concerned and the recipients or categories of recipients to whom the personal data have been or will be disclosed.
  • Right to Rectification: The right to request correction of inaccurate or incomplete data. If you have an account with us, you can update and amend your personal profile through the "My Account" section of the website. You can deactivate your account, or amend any personal data which cannot be modified online, by emailing us at support@victoriabeckhambeauty.com. If you do not have an account, you can exercise this right by emailing us at support@victoriabeckhambeauty.com.
  • Right to Erasure: The right to request deletion of your personal data under certain circumstances, such as when it is no longer necessary for the purposes for which it was collected.
  • Right to Restrict Processing: The right to request the restriction of processing your data under certain conditions, such as when contesting the accuracy of the data.
  • Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to transfer it to another controller.
  • Right to Object: The right to object to processing based on public interest or legitimate interests. In this case, we will stop processing your personal data, except for where we have compelling legal grounds for the processing which override your interests, rights and freedoms, or for the exercise or defense of possible legal claims.  You also have the right to object to processing based on direct marketing. If you object to processing for direct marketing purposes, we will cease processing your data for such purposes.
  • Right to Withdraw Consent: The right to withdraw consent for processing activities based on consent, where applicable.
  • Right to Lodge a Complaint: You have the right to make a complaint at any time to the relevant data protection authority if you believe that our processing of your personal data violates applicable Data Protection Legislation, which in the UK is the Information Commissioner's Office (ICO) (www.ico.org.uk).

 

To exercise these rights, please contact us at support@victoriabeckhambeauty.com.

 

  1. Storage and retention of your personal data

 

As a minimum, we will store your data for as long as is reasonably necessary to provide you with the goods and services that you have requested from us, but in most cases we will retain certain of your personal data for as long as is reasonably necessary taking into consideration factors such as:

 

  • our need to perform any agreements between you and us (including order fulfilment);
  • our need to answer any queries or resolve any problems you may have;
  • your continued consent to receive marketing and other emails and communications from us;
  • our continued provision of our services to you; and
  • our need to comply with legal requirements (e.g. relating to record keeping).

 

If you tell us that you would like to delete your account, we will take steps to delete all the personal data we hold about you once it is no longer necessary for us to hold it (e.g. to fulfill any outstanding orders, resolve disputes, or as is permitted by applicable law or regulation).

 

For as long as we do store your data, the Company maintains reasonable safeguards to attempt to protect the security, integrity, and privacy of the information you have provided. Notwithstanding our efforts to keep your personal data secure, no system can be 100% reliable. To the fullest extent permitted by law, we cannot be held liable for any loss you may suffer if a third party procures unauthorised access to any data you provide through the Channels. In addition, you are responsible for maintaining the strength and confidentiality of your login credentials.

 

We will promptly notify you if we have reason to believe that there has been a personal data breach by us (or your personal data held by us) which could adversely affect your rights and freedoms.

 

  1. Links to Third Parties

 

Our website may link or redirect to other websites or online services that are beyond our control. Such links or redirections are not endorsements of such websites or online services or representation of our affiliation with them in any way and such third-party websites or online services are outside the scope of this policy. If you access such third-party websites, please ensure that you are satisfied with their respective privacy policies before you provide them with any personal data. We cannot be held responsible for the activities, privacy policies or levels of privacy compliance of any website or online service operated by any third party.

 

Some aspects of our website may allow you to interface with social media, such as Facebook, Instagram and YouTube. We will attempt to identify these aspects of our website to you, for example, by identifying them with the applicable third-party logos or trade names. By using these interfaces, you will allow us to access information about you from those other online services, including information and other content that you submit to those online services. If you interface with us through your social media account, we may contact you or enable you to share your experience and content via your social media account, which information may be publicly viewed by other users of those services. For a description on how such social media services and other third-party platforms, plug-ins, integrations, and applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings with that service or platform.

 

 

  1. Text/RCS Message Consent And Opt-Out   

 

You may be able to sign up to receive and send text messages from the Company concerning our products, services, status of your order(s), customer support, tips, and promotions that may be sent using automated dialing systems (“Text Messages”). When you opt in to receiving Text Messages from us, you are expressly authorizing us to contact you at the phone number you used to opt in, and you are agreeing that we may communicate with you by sending Text Messages in accordance this paragraph 12 (Text/RCS Message Consent And Opt-Out). By opting in to receiving Text Messages from us, you are also consenting to receive such messages via Rich Communication Services (“RCS”) through an automated dialing systems. RCS operates over the Internet or by using mobile data and provides for certain features that are not available through SMS, such as not limiting messages to 160 characters, providing read receipts, sending high-resolution images and videos, providing suggested replies. Your participation in receiving Text Messages from us is completely voluntary and consent is not required to purchase goods or services.

 

Even after you consent to receive Text Messages, you may opt out of receiving Text Messages at any time directly on your mobile device by sending a text message with the word “STOP” to the phone number that you no longer want to send you Text Messages, or you can contact support@victoriabeckhambeauty.com and specify that you wish to opt-out from Text Messages communication. The opt-out keyword “STOP” needs to be sent from the phone number where you want to stop receiving messages. If you have more than one phone number enrolled, you will need to follow this process with each phone number or contact us at support@victoriabeckhambeauty.com for assistance.

 

Message frequency varies per month and depends upon your relationship with us. Just as with other communication tools, some individuals may communicate with us more often than others. If you feel you are receiving more Text Messages than desired, you can let us know or opt out of receiving Text Messages by replying with the word “STOP”, and that number should no longer be able to send you communications. Alternatively, you can contact beauty@victoriabeckhambeauty.com for assistance or opt-out directly in your account on our website.

 

You understand and agree that depending on the terms of your mobile phone contract, charges may incur for Text Messages. Message and data rates may apply. You are solely responsible for all charges related to Text Messages, including charges from your mobile service provider. You should check the applicable rates with your mobile service provider. We do not charge you for sending or receiving Text Messages.

 

Data collected from you in connection with this Text Messages service may include your mobile phone number, your carrier’s name, the data, time, content of your messages and other information you provide us. We may use this information to contact you and to provide the services you request from us. Personal data obtained through the RCS program will not be shared with any third parties for those third parties’ marketing or advertising reasons, and will not be used or shared with any third parties except as necessary to document your consent to receive Text Messages, to send Text Messages to you and to comply with any applicable laws and regulations, including disclosing your mobile information to our service provider that sends Text Messages on our behalf. We will not sell any personal data obtained as part of our Text Messaging communications with you, and we do not permit our third-party suppliers, vendors, or contractors to sell any personal data obtained in the course of our business relationship related to our Text Message communications with you.

 

The Company is not responsible or liable for undelivered or delayed messages. Carriers are not liable for delayed or undelivered messages.

 

If your phone number changes, you should let us know right away to avoid Text Messages being sent to your old number. Ideally, you should follow the opt out process described above before you change your phone number. You will also need to re-opt in to receive Text Messages from us to your new number.

 

To the extent permitted by applicable law, you agree that we will not be liable for failed, delayed, or misdirected delivery of any Text Messages sent by us through our service provider, any errors in such messages, and/or any action you may or may not take in reliance on the information set forth in the messages.

 

For additional information, text “HELP”, or contact support@victoriabeckhambeauty.com.

 

  1. Do Not Track

 

Our website does not currently take any action when it receives a Do Not Track request. Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on Do Not Track, visit www.donottrack.us.

 

  1. Children

 

We do not knowingly collect or maintain personal data from any person under the age of 18. No parts of our website are directed to or designed to attract anyone under the age of 18.

 

  1. Nevada Residents

 

Under Nevada law, Company does not sell your personal data. However, if you are a Nevada resident, you may submit a request that we not sell any personal data we have collected about you by contacting us at support@victoriabeckhambeauty.com.

 

  1. California Residents

 

The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CPRA”) provides California residents with specific rights regarding their personal data. The below describes such rights and how you may exercise such rights, and our information practices, including the categories of personal data we collect, use, retain, disclose, sell or share, and how and why we collect, disclose, sell or share such information. This paragraph 16 (California residents) applies only to our users who are California residents.

 

Consumer Rights

Right to Know

You have the right to request that we disclose what personal data we collect, use, disclose, sell or share. Specifically, you may request that we disclose to you the following:

  1. The categories of personal data we have collected about you.
  2. The categories of sources from which the personal data is collected.
  3. The business or commercial purpose for collecting, selling or sharing personal data.
  4. The categories of third parties with whom we disclose personal data.
  5. The specific pieces of personal data we have collected about you.

 

You may also request that we disclose to you:

  1. The categories of personal data that we have sold or shared about you and the categories of third parties to whom the personal data was sold or shared, by category or categories of personal data for each third party to whom the personal data was sold or shared.
  2. The categories of personal data that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

 

Right to Delete

You have the right to request that we delete any personal data about you which we have collected from you. If it is necessary for us to maintain your personal data for certain purposes, we are not required to comply with your deletion request. If we determine that we will not delete your personal data when you request us to do so, we will inform you and tell you why we are not deleting it. 

 

Right to Opt-Out of Sale or Sharing of Personal Data

You have the right to direct a business that sells or shares personal data about you to third parties not to sell or share your personal data. We do not sell your personal data for monetary consideration. However, we do use cookies and other tracking technologies (e.g., pixels) for targeted advertising purposes. The collection of data through certain tracking technologies for our targeting advertising purposes may be considered a “sale” and is considered “sharing” under the CPRA. To opt-out of having your information sold and shared with third-party website analytics and digital advertising service providers for this purpose, please visit “ Do Not Sell or Share My Personal Information”.

 

Right to Correct Inaccurate Personal Data

You have the right to request a business that maintains inaccurate personal data about you to correct that inaccurate personal data, taking into account the nature of the personal data and the purposes of the processing of the personal data.

 

Right to Limit Use and Disclosure of Sensitive Personal Data

You have the right to direct a business that collects sensitive personal data about you to limit its use of your sensitive personal data (1) to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services; (2) for certain business purposes; and (3) as authorized by the implementing regulations of the CPRA. Company does not collect any sensitive personal information as defined under the CPRA. However, if you provide us with photographs and videos, it may be possible to infer your racial or ethnic origin. Company will only use and disclose such information as necessary to fulfill the purposes of collection or as permitted under the CPRA and we will not sell or share such information.

 

No Discrimination

You have the right not to be discriminated against because you exercised any of your aforementioned rights.

 

How to Submit a Request

To exercise the rights described above, you must submit a verifiable request to us. You can do so by emailing support@victoriabeckhambeauty.com.

 

To submit a verifiable request, you will be asked to provide certain information to help us verify your identity. The information we ask you to provide to initiate a request may differ depending upon the type of request, the type, sensitivity and value of the personal data that is the subject of the request, and the risk of harm to you that may occur as a result of unauthorized access or deletion, among other factors.

 

You may designate an authorized agent to make a request on your behalf by providing the agent with signed written permission to do so.

 

If we cannot verify your identity or authority to make the request, we will not be able to comply with your request. We will inform you if we cannot verify your identity or authority. We will only use personal data provided in a verifiable request to verify the requestor’s identity or authority to make the request. 

 

How We Collect, Use, Disclose, Sell and Share Personal Data

Company has collected the following categories of personal information and used, disclosed, sold or shared such information in the twelve (12) months prior to the effective date of this policy:

  • Identifiers, such as name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, address, telephone number, credit card number, debit card number, or any other financial information, physical characteristics or description.
  • Commercial information, such as records of products purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
  • Geolocation data.
  • Electronic, visual or similar information, such any photographs or videos you post on social media and tag us.

 

Each of the above categories are disclosed for a business or commercial purpose as described above in Section 4 (The purpose for which we process your personal data) to the third parties listed in Section 7 (Sharing information with affiliates and third parties).

 

The following categories of personal information were sold or shared in the twelve (12) months prior to the effective date of this policy:

 

  • Identifiers, such as unique personal identifier, online identifier, Internet Protocol address, or other similar identifiers.
  • Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
  • Geolocation data.

 

Such information is sold to or shared with our third-party website analytics and digital advertising service providers.

 

We share or sell such information:

  • to provide our website to you and to improve our website;
  • to personalize content on our website;
  • to send you promotional and marketing materials, notifications, updates and exclusive news, and identify product and shopping preferences;
  • to improve our marketing and promotional efforts, analyse website usage statistics, improve content and product offerings and customise the content and layout of our website;
  • for market research and demographic studies;
  • for security, to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of our website;
  • to carry out our business activities in circumstances where you ought reasonably to have an expectation that we will process your personal data for a particular purpose (including but not limited to audits, developing new products, improving our products and services, identifying website usage trends, determining the effectiveness of our promotional campaigns and as may be provided for in our Terms of Use or other arrangement between us);
  • as we believe to be necessary or appropriate: (i) under applicable law; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to enforce this Privacy Policy and our Terms of Service; (v) to protect our operations or those of any of our affiliates; (vi) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.

 

Company collects the personal data described above from or through the following categories of sources:

  • You, directly and indirectly, including when you access our website or when you purchase our products, register an account with us, sign up for our loyalty program, subscribe to our newsletter or otherwise contact us; and
  • Service providers, including those that provide website analytics services to help us understand the activities taken on our website.

 

As noted above, Company will retain the personal data described above for as long as necessary to fulfill the purpose for which it was collected or as required by applicable laws or regulation.

 

Financial Incentive – Loyalty Program

Company offers various financial incentives, such as discounts and other benefits for customers who sign up to receive our marketing emails, refer a friend or join our loyalty program (the “Loyalty Program”). When you participate in a financial incentive, we collect personal data from you, such as identifiers (like your name and email address) and commercial information (like your purchase history). You may opt-in to the Loyalty Program at any time at https://victoriabeckhambeauty.com/pages/the-v-suite-loyalty-program. Our Loyalty Program page located at: https://victoriabeckhambeauty.com/pages/the-v-suite-loyalty-program describe the material terms of the Loyalty Program. You may revoke your decision to opt-in to the Loyalty Program at any time by contacting us at support@victoriabeckhambeauty.com.

 

In some cases, we may provide additional terms and conditions for a financial incentive, which we will present to you when you sign up. We value your personal data as the value of the offer or discount provided to you, and the value of your personal data is reasonably related to the value of the offer or discount presented to you.

 

Personal Information of Minors

Company does not have actual knowledge that it sells or shares personal information about minors under the age of 18.

 

  1. Nebraska and Texas Residents

 

This paragraph applies only to our users who are Nebraska and Texas residents and supplements the details provided in our policy and contains the information that the relevant state laws require us to make available to you.

 

The categories of personal data we process about you is set forth in paragraph 2 (The personal data we process). The purposes for processing such personal data are set forth in paragraph 4 (The purposes for which we process your personal data). We disclose the personal data we process about you with the third parties set forth in paragraph 7 (Sharing information with affiliates and third parties).

 

If you are a resident of Nebraska or Texas, you have the rights to:

  • Confirm whether or not we are processing your personal data and access such personal data;
  • Correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of your personal data;
  • Delete personal data provided by or obtained about you;
  • Obtain a copy of your personal data we process, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance, where the processing is carried out by automated means; and
  • Opt out of the processing of personal data for purposes of:
  • Targeted advertising;
  • The sale of personal information; or
  • Profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. We do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

 

You may exercise these rights by emailing support@victoriabeckhambeauty.com.

 

The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal data; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

 

We reserve the right to verify your identity in connection with any requests regarding personal data to help ensure that we provide the information we maintain to the individuals to whom it pertains and allow only those individuals to exercise rights with respect to that information. We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you. 

 

In the event we deny your request, you may appeal our denial by contacting us in the same manner by which you submitted your request.

 

We process your personal data for the purposes of targeted advertising, and under Nebraska and Texas laws, our processing may qualify as a “sale”. We share the information set forth in paragraph 2.3 (Cookies and Other Tracking Technologies) with our third-party website analytics and digital advertising service providers. To opt-out of such sharing of information with our third-party website analytics and digital advertising service providers, please visit “Do Not Sell or Share My Personal Information”. If you are an authorized agent making a request to opt-out on behalf of a consumer, we may require and request that you provide us with written permission signed by the consumer to verify that you are authorized to make such request.

 

 

14. Questions and complaints 

 

For all questions or complaints about this policy, we would appreciate the chance to deal with your concerns before you approach the relevant data protection authority. Please contact us in the first instance via support@victoriabeckhambeauty.com.

005804.00002/154574367v.6