1 July 2020

SEPHORA NEW ZEALAND LTD, a Groupe LVMH subsidiary, located at 146-152 Queen St Auckland 1010 (hereinafter ‘ Sephora ’,‘ we ’ or ‘our ’), attaches great importance to the protection of personal data relating to its applicants (hereinafter ‘ you ‘).

Sephora respects your concerns relating to the protection of your privacy and your personal data. This Applicants Privacy Notice (hereinafter referred to as the “Privacy Notice”) describes how we use information about you collected when you apply to join Sephora.

This Privacy Notice contains information regarding the nature and the use we make of your personal data, as well as your rights relating to this use.

This Privacy Notice is therefore an important resource for you, helping to ensure that you have a positive and confident experience of Sephora’s handling of your personal data and enabling us to provide accurate and complete answers to any questions you may have and to take account of your wishes in this area.

In order to give this requirement to ensure protection of your personal data - and that of our clients - the priority it deserves, Sephora has decided to designate a Data Protection Officer (hereinafter ‘ DPO ’), who may be contacted at the following address :

Modification of the Privacy Notice

We may occasionally wish to modify the terms of this Applicant Information Notice. In such an event, we shall notify you of this by changing the date indicated at the beginning and end of this document, which is permanently available for consultation through your applicant space. We would encourage you to consult the Applicant Information Notice on a regular basis, in order to keep abreast of the procedures implemented by Sephora for processing your personal data, as well as the methods by which you can send us inquiries regarding our use of the data.

Why do we collect your personal data ?

Sephora collects and processes your personal data for the following purposes:

(i) management of your application for employment; We process your personal data for this particular purpose because that processing is necessary in order to assess your employment application (including checking any references, checking accuracy of information provided, and determining your suitability for the role for which you have applied);

(ii) management of, and notification to you of, other job openings for which you may be suited. The processing of your personal data for this purpose is based on your consent as resulting from the sharing options you have notified us with;

(iii) if you become an employee of Sephora, for the personnel records for you that we maintain and we may also keep this information for the purposes of verifying all the information you provided during the application process is true and accurate;(iv) compilation of statistics regarding Sephora employment processes, candidates, opportunities, interviews, and other relevant measures;   The processing of your personal data for this purpose is necessary for the protection of our legitimate interest to continuously improve our recruitment practices; and

(v) We may also process your personal information to the extent necessary for the protection of our legitimate interest of being able to defend ourselves in case of a dispute and to comply with any of our legal obligations.

What type of personal data do we process ?

We only process data that is strictly necessary for the purposes described in paragraph 2.

We collect your personal data from you when you send your curriculum vitae, whether online or in paper form, or when you apply for employment by indirect means, for example via an agency or recruitment firm, and more generally throughout the Sephora recruitment process.

Categories of your personal data that we may collect, process and use includes:

data relating to your identity such as: surname and forename, physical and postal addresses, telephone number ;

data relating to your educational and professional background, such as: training, professional experience, references, distinctions, certifications ;

Contact details, including physical and postal addresses, telephone numbers and email address

Data relating to and on your application (such as referral source, candidature status, offer approval…) and your career expectations;

Results of any assessments and/or occupational testing

Information about your entitlement to work in New Zealand (or any other country you are applying to work in) ;

Publicly available information about you, such as on social media channels including LinkedIn; and

Data enabling connection to, and identification on, our recruitment platforms (such as user ID, connection data).

The information we collect that are required in order to process your application are marked with an asterisk on the forms presented for you to complete on our online recruitment platform. If you do not complete the fields marked as mandatory, we shall be unable to process your application. In the case of other forms of application, if Sephora has been unable to receive the information required in order to process your application, Sephora reserves the right to re-contact you in order to collect the missing information.

Who can access your personal data ?

Within the Groupe Sephora, your personal data are only accessible to those authorised personnel to the extent needed in order to carry out their respective duties.

More specifically :

Within the company :

Employees in Sephora’s HR department ;

Employees in Sephora’s recruitment department

Employees in the Sephora services issuing job offers

Sephora’s IT department, for the purposes of security and maintenance ;

Outside the company :

The relevant HR departments of the entities of the Groupe Sephora subsidiaries and / or of Groupe LVMH (parent company in France and subsidiaries worldwide) responsible for international careers and talent management ;

Service providers working for Sephora and involved in achieving all or some of the purposes set out in paragraph 2 (including data processors, and job boards, recruitment agencies, labour companies if you apply through them)

In particular, we rely on third party data processors to provide you with our recruitment platform and job application. These third-party processors are only allowed to process (including storing) your personal data on our behalf and upon our explicit written instruction.

In addition, for purposes connected to maintenance of the IT systems, your personal data may be accessible to Sephora IT services employees or to the employees of external providers of certain IT services. These employees shall only be able to access your data in order to carry out security and maintenance activities on the IT systems. They shall carry out their duties in accordance with Sephora’s instructions and in total compliance with the legislation on personal data.

Where are your personal data stored and processed?

We process your personal data first and foremost within New Zealand.

   As Sephora is part of an international group, in order to process your personal data for the purposes outlined in paragraph 2 above, your personal data (as described in paragraph 3) may be transferred to organizations within Groupe Sephora or the Groupe LVMH (parent company in France and subsidiaries worldwide) and to external service providers helping Sephora entities in dealing with recruitment which may be located worldwide, including more specifically, regarding Groupe Sephora entities, in the following countries/regions : Monaco, Turkey, Serbia, Switzerland, Russia, Kuwait, Saudi Arabia, United Arab Emirates, Qatar, Bahrain, China, Singapore, Hong Kong SAR, Thailand, Malaysia, Indonesia, New Zealand, Australia, India, Philippines, Brazil, Canada and the United States of America, to organizations within Groupe LVMH (parent company and subsidiaries)., and to external service providers. Given the fact that some of these countries does not ensure an adequate level of protection of personal data as in the European Union, Sephora shall in accordance with applicable regulations, ensure the protection of your personal data.  Such safeguards will be the consequence of:

The country of the recipient having legislation in place which is considered equivalent to the protection offered within the EEA and/or New Zealand;

The Binding Corporate Rules (or ‘ BCR ’) applicable in each of LVMH Group subsidiaries ; and

The contractual arrangements with our external service providers.

How long do we store your personal data ?

Except as provided below, Sephora keeps your data for a maximum period of 2 years after the last contact between Sephora and yourself. In this way we will be able to re-evaluate your application and contact you if a suitable role becomes vacant and Sephora believes it may interest you.

If you are offered and accept employment at Sephora, we may keep data you provide on the general personnel record that we maintain for you in accordance with applicable law, including the requirements under the Employment Relations Act 2000.

At the end of these periods, your personal data are deleted.

Your rights

You have the right to request confirmation of whether or not we hold personal data about you, and to access such data that we hold about you.

You have the right to request that any personal data pertaining to you that is inaccurate, be corrected free of charge. If you submit a request for correction, such request has to be accompanied by proof of the flawed nature of the data for which correction is asked.  If we do not make the correction requested, you may ask us to attach to the personal data a statement of the correction requested but not made.

You have the right to withdraw your earlier given consent for the processing of your personal data.

You have the right to request that personal data pertaining to you be deleted if these data are no longer required in the light of the purposes outlined in Article 2 above or if you withdraw your consent for processing the data. However, we will evaluate a request for deletion against:

- overriding interests of Sephora or any other third party;

- Any legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.

Instead of deletion you can also ask that we limit the processing of your personal data if you contest the accuracy of the data, or the processing is illegitimate, or the data are no longer needed for the purposes mentioned in Article 2.

You may exercise your right to object to the processing of personal data that relates to you on grounds of your specific situation, unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

You are also entitled to request a copy of the personal data you have directly provided to us through automated means in a format that is structured, commonly used and machine-readable.

Furthermore, you have the right to issue advance instructions regarding use or disposal of your personal data after your death.

We would invite you to exercise these rights by writing to the following agency collecting and holding your personal data:

Sephora New Zealand Limited, a Groupe LVMH subsidiary, 146-152 Queen St Auckland 1010

Additionally, you can also contact the DPO at this email address:

Finally, you have the right to lodge a complaint with the New Zealand Office of the Privacy Commissioner. We would however suggest that you first send us any claims via the DPO, so that we can deal with your questions and work together to find solutions that will resolve any issues you may have.

Notification of changes

We will keep you informed of any modifications to our Privacy Notice.

This Privacy Notice was last updated and revised on the 1 July 2020.