APPLICANTS PRIVACY NOTICE DANEMARK

September 2026

SEPHORA Danmark ApS, Organization number 33863225, Kampmannsgade 2, 1604 København V  (hereinafter ‘ Sephora ’,‘ we ’ or ‘our ’), attaches great importance to the protection of personal data relating to its employees, apprentices, interns, work-experience students, temporary works and representatives (hereinafter ‘ you ‘). 

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

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

  

This Applicants Fact Sheet 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:  SEPHORA Danmark ApS, Organization number 33863225, Kampmannsgade 2, 1604 København V. 

 

1. Modification of the Fact Sheet

We may occasionally wish to modify the terms of this Fact Sheet. In such an event, we shall notify you of this by changing the date indicated at the beginning of this document, which is permanently available for consultation through your applicant space (We are Sephora or any other communication resource relating to Sephora recruitment). We would encourage you to consult the Applicant Sheet 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. 

 

2. 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 to take steps at your request prior to entering into a contract;  

(ii) assistance of the recruiting managers for analysis and evaluation of parts of your application through an artificial intelligence (AI) tool, for the job offers using our interactive recruitment process. The processing of your personal data for this purpose is necessary for our legitimate interest in assessing candidates in a consistent and structured manner while managing a high volume of applications fairly and efficiently. Using this interactive process is optional: you may instead apply by sharing your CV, which will be reviewed on the same terms. You may object to the processing at any time; 

(iii) management of the job offers 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;  

(iv) compilation of statistics regarding Sephora employment opportunities. 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) 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 our legal obligations.  

These processing arise from Sephora’s fulfilment of its statutory and contractual obligations and from Sephora’s legitimate interests in its capacity as a recruiter. 

 

3. 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 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. 

We collect the personal data that you include in your answers given as part of our AI-assisted interactive recruitment process, to generate analytical indicators and an assessment score. 

For your information there follows a list of the categories of your personal data that we may process, depending on the purposes to be achieved by this processing: 

  • Personal details and identity information, such as: surname and first name, address, telephone number, email address, photograph; 
  • Information regarding your educational and professional background, such as: qualifications, work experience, references, awards, CV; 
  • Data relating to your application (such as source of referral, application status, offer approval, etc.) and your career expectations; 
  • Data relating to publicly available information about your profile on social media platforms (e.g. LinkedIn), if you apply via this channel; and 
  • Connection data relating to the application platform, such as user ID, etc. 
  • Data enabling connection to IT devices. 

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 these mandatory fields, we shall be unable to process your application. In the case of other forms of application, if Sephora has been unable to identify the information required in order to process your application, Sephora reserves the right to re-contact you in order to collect the missing information. 

 

4. What is the legal basis and how do we use the information we collect?

Below you will find the purposes for which your personal data is processed and the reasons why such processing is necessary for us. 

Purposes of processing 1 : Processing and managing job applications  

  • Reasons why the processing of your personal data by our services is necessary : Necessary to take appropriate steps prior to entering into a contractual relationship with the applicant, in particular with regard to their ability and willingness to fill the position in question. 
  • Legal basis :   Implementation of pre-contractual measures 

Purposes of processing 2: Partial analysis and assessment of certain applications using an AI tool 

  • Reasons why the processing of your personal data by our services is necessary: To assist recruitment managers with an initial analysis of applications submitted to branches via the interactive, AI-supported recruitment process. This tool is used exclusively for specific recruitment activities; during the online recruitment process, the applicant decides whether to continue their application via the AI-supported interactive process or to share their CV. 
  • Legal basis: Legitimate Interest 

Purposes of processing 3: Searching for and identifying suitable profiles in relation to job vacancies 

  • Reasons why the processing of your personal data by our services is necessary: Managing offers that may be suitable for the candidate, based on the communication preferences explicitly selected by the candidate. 
  • Legal basis: Consent 

Purposes of processing 4: Compilation of statistics on career opportunities at Sephora  

  • Reasons why the processing of your personal data by our services is necessary: Compilation of statistics for the ongoing improvement of the recruitment service on the basis of Sephora’s legitimate interest.  
  • Legal basis: Legitimate interest 

Purposes of processing 5: Defence in the event of a dispute 

  • Reasons why the processing of your personal data by our services is necessary: To the extent necessary to defend our interests in the context of a potential legal dispute. 
  • Legal basis: Legitimate interest 

Sephora may also process your personal information to the extent necessary to protect its interests in the event of a dispute and to comply with legal obligations.

 

5. Who can access your personal data ? 

Within the Groupe Sephora, your personal data are only accessible to those individuals who need to use it 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 ; 
    •  Sephora’s IT department, for the purposes of maintenance ; 
  • Outside the company : 
    • Groupe LVMH’s HR department ; 
    • The HR departments of the Groupe Sephora subsidiaries and / or of Groupe LVMH; and   
    •  Service providers working for Sephora and involved in achieving all or some of the purposes set out in paragraph 2. 

In particular, for purposes connected to maintenance of the IT systems, your personal data may be accessible to Sephora 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 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. 

If and when an AI tool is used, as described above, these limitations also apply to the service provider in charge of providing and supporting the AI-assisted interactive recruitment process platform, acting as data processor. This service provider implements the appropriate technical and organisation measures to ensure the fairness, transparency and relatability of its AI system, including regular audits, bias monitoring and mandatory human oversight. 

 

6. Where are your personal data stored ? 

We process your personal data primarily within the European Economic Area (EEA). 

As Sephora is part of an international group, your personal data (as described in paragraph 3) may be transferred to organizations within Groupe Sephora (parent company and subsidiaries) located outside the European Union, and more specifically in the following countries: Monaco, Turkey, Serbia, Switzerland, Russia, Kuwait, Saudi Arabia, United Arab Emirates, Qatar, Bahrain, China, Singapore, Hong Kong, 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. 

These transfers are carried out within the context of management of recruitment within Groupe Sephora and Groupe LVMH for the purposes set out in paragraph 1 above. The processing activities carried out are: organization, reading, inputting, adaptation or modification, extraction, use, communication, deletion and destruction of your personal data. 

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 as follows : 

  • within Groupe Sephora, through adoption of Binding Corporate Rules (or ‘ BCR ’) applicable in each of its subsidiaries ; and 
  • with its external service providers, through the implementation of standard contractual clauses published by the European Commission. 

Copies of these documents may be obtained by sending an email to the following address: hr@sephora.dk; DPO@sephora.dk 

 

7. How long do we store your personal data ? 

Sephora keeps your data for a maximum period of 6 months after the last contact between Sephora and yourself. In this way we will be able to re-evaluate your application if a similar post becomes vacant and Sephora believes it may interest you. 

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

If you use the AI-powered interactive recruiting platform, your personal data will be retained for a maximum period of 6 (six) months and then deleted. Personal data related to your assessment score will be retained for a maximum period of 6 (six) months and then deleted or properly anonymized. 

 

8. Your rights 

As specified in the legal provisions applicable in this area, you have the right to access data relating to you, and if applicable to request their rectification and deletion. 

You may exercise your right to object to the processing of personal data that relates to you on grounds of your specific situation, or to seek a restriction on the processing of your data. 

You are also entitled to request a copy of your personal data 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 address: hr@sephora.dk or by contacting the DPO at this address: DPO@sephora.dk 

Finally, you have the right to lodge a complaint with the local data authorities in Denmark or Sweden. 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. 

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. 

As part of your AI-supported interactive recruitment assessment, you have the right to: 

(i) object, at any time and on grounds relating to your particular situation, to the processing of your Personal data in the AI-assisted interactive recruitment evaluation. If you object, we will stop that processing, provided there is no compelling legitimate grounds overriding your interests, and you may proceed with your application by uploading your CV to the Website; 

(ii) request human intervention (please note that all applications are reviewed by a qualified human decision-maker);  

(iii) challenge your AI-assisted interactive recruitment evaluation, including any intermediate or final outcome that you believe is inaccurate, unfair or discriminatory; 

(iv) obtain meaningful information about the logic involved in the AI-assisted interactive recruitment evaluation, including the main criteria used by the system and the factors that may have influenced your assessment; 

(v) request clarification on how your data was used by the AI-assisted interactive recruitment evaluation; 

 

9.  Notification of changes 

We will keep you informed of any modifications to our Applicants Fact Sheet.   

 

10. Specific Reference to the Use of the AI Tool 

We may collect the personal data included in your responses as part of our AI-assisted interactive recruitment process, solely in some store recruitment processes and provided you do not object to this processing after being duly informed. We also inform you that:  

  • the use of the AI tool is not mandatory, and choosing not to use it will not prevent your application from being considered through an alternative procedure using your CV; 
  • the AI tool does not autonomously make hiring or candidate rejection decisions; 
  • the tool does not automatically modify its assessment parameters or adapt its selection criteria based on candidates’ responses; 
  • the AI-assisted recruitment tool generates a score based on the responses provided by the candidate during the interactive assessment process, with the purpose of reflecting certain indicators relating to the competencies and skills defined by Sephora for the relevant position and according to a tested scoring method; 
  • this score serves solely as a support element in the evaluation of the application and is made available to recruitment personnel together with the candidate’s detailed responses. Recruiters carry out an individual assessment of each application. They may depart, in whole or in part, from the score generated by the tool, and they make the final decision to proceed with an interview of the candidate; 
  • the score does not independently determine any decision and does not produce any automatic effects on the candidate’s application. There is no minimum score requirement, automatic classification, or automatic exclusion of candidates based on the score obtained; 
  • the assessment is based exclusively on the information entered by the candidate and on the analysis of their responses, without the use of video recordings, images, facial expressions, body language, or any biometric data. The tool does not use, nor is it intended to infer, any special categories of personal data within the meaning of Article 9 of Regulation (EU) 2016/679, including data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data used for the purpose of uniquely identifying an individual, data concerning health, or data concerning a person’s sex life or sexual orientation. Furthermore, the tool does not use emotion recognition systems or social scoring mechanisms and does not incorporate parameters based on protected characteristics such as age, sex, gender, ethnicity, disability, or health status; 
  • in all cases, Sephora and its service provider implement measures designed to identify and mitigate risks of direct or indirect discrimination and to promote equal opportunities among candidates. Periodic reviews and controls are carried out to detect and address any potential bias in the operation of the tool.