1 July 2020

Sephora Asia Pte Ltd, Sephora Digital SEA Pte Ltd and Sephora Singapore Pte Ltd, Groupe LVMH subsidiaries, located at 391A Orchard Road, #16-00, Ngee Ann City Tower A, Singapore 238873 (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 Sephora manages your Personal Data in accordance with the Personal Data Protection Act 2012 (the "PDPA") 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 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 Information Notice on a regular basis, in order to keep abreast of the procedures implemented by Sephora for collecting, using and disclosing your Personal Data, as well as the methods by which you can send us inquiries regarding our use of the Personal Data.

Why do we collect your Personal Data?

Your Personal Data will be collected and used by us for the following purposes, and we may disclose such Personal Data to the relevant third parties discussed at section 4 below where necessary for these purposes:

management of your application for employment: We collect, use and disclose your Personal Data for this particular purpose because that collection, use and disclosure is necessary in order to facilitate the creation of your account on this portal and to correspond with you on further queries and for the purposes of scheduling interviews; 

management of the job offers for which you may be suited: We  collect, use and disclose your Personal Data for this purpose is based on your consent as resulting from the sharing options you have notified us with, including without limitation, to assess your suitability for a current or future role, to process an offer letter and employment contract, and to apply for a work pass where necessary; and

compilation of statistics regarding Sephora employment opportunities; We collect, use and disclose your Personal Data as a part of our analytical and statistical studies to continuously improve our internal business processes and recruitment practices.

Sephora may also collect, use and disclose your Personal Data to the extent necessary to protect and enforce our legal rights and obligations in the event of a dispute, and to comply with all applicable policies, laws and regulations.

What type of Personal Data do we collect, use and disclose?

We only collect, use and disclose Personal Data that is strictly necessary for the purposes to which you have consented to, as described in section 2 of this Notice. In this Notice, "Personal Data" refers to any data, whether true or not, about an individual who can be identified (i) from that data; or (ii) from that data and other information to which we have or are likely to have access.

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 may also obtain such data from publicly-available sources.

Examples of such Personal Data that we may collect, use and disclose include:

your contact details;

data relating to your civil status and identity, such as your surname and forename, address, telephone number;

data relating to your educational and professional background, such as any trainings you have undertaken, your professional experience, references, distinctions and/or certifications;

data relating to your language proficiencies;

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

the results of any assessments and/or occupational testing which you have undergone;

information about your entitlement to work in the EU or in the country where you applied;

publicly available information of your profile on social media channels (such as Linkedin); and

data enabling us to connect you to our recruitment platform (such as user ID, connexion data…).

The information we collect that are required in order to process your application are marked with an asterisk on the forms presented to you to complete on our online recruitment platform. If you do not complete the fields marked as mandatory, we will not be able 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 contact you again to obtain the further missing information.

We will seek your consent before collecting any additional personal data and before using your Personal Data for a purpose which has not been notified to you (except where permitted or authorised by law).

Who can access your Personal Data?

Within the Groupe Sephora, your Personal Data will only be accessible to authorised personnel, and only to the extent necessary to carry out their respective duties.

More specifically, we may disclose your Personal Data for the purposes outlined in section 2, to the following parties:

Within Sephora:

Employees in Sephora’s HR department;

Employees in Sephora’s recruitment department;

Employees in the Sephora services issuing job offers; and/or

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

Outside Sephora:

The relevant HR departments of the entities of the Groupe Sephora subsidiaries and/or of Groupe LVMH responsible for international careers and talent management; and/or  

Service providers working for Sephora and involved in achieving all or some of the purposes set out in section 2.

We also rely on, and may therefore disclose your Personal Data to various third party data processors to provide you with our recruitment platform and job application. These third-party data processors are only allowed to process your Personal Data on our behalf and with our explicit written instructions.

In addition, for purposes connected to the maintenance of our 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 collected, used and disclosed?

We collect, use and disclose your Personal Data first and foremost within Singapore.

As Sephora is part of an international group, in order to collect, use and disclose your Personal Data for the purposes outlined in section 2 above, your Personal Data (as described in section 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 outside Singapore.

Specifically, we may transfer your Personal Data to the 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 our external service providers located outside of Singapore.

We are mindful that some of these countries does not ensure an adequate level of protection of Personal Data as required under the PDPA. Therefore, before transferring your Personal Data to these external jurisdictions, we will take steps to ensure that your Personal Data continues to receive a standard of protection that is at least comparable to that provided under the PDPA. Such safeguards will include:

Ensuring that the country of the recipient has legislation in place which is considered to provide protection equivalent to that provided under the PDPA; and

Entering into contractual arrangements with our external service providers, which provide for the recommended contractual clauses published by the Personal Data Protection Commission on the transfer of personal data outside Singapore.

How long do we store your Personal Data ?

Sephora keeps your data for a maximum period of 2 years after the last contact between Sephora and yourself. This will allow us to re-evaluate your application if a similar position becomes vacant and Sephora believes it may interest you.

At the end of the relevant 2-year period, we will cease to retain your Personal Data.

Your rights

You have the right to request access to any Personal Data relating to you.

You have the right to request that any Personal Data pertaining to you that are inaccurate, be corrected free of charge. If you submit a request for correction, such request should be accompanied by proof of the flawed nature of the data for which correction is asked.

You have the right to withdraw your earlier given consent for the collection, use and disclosure 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 section 2 above or if you withdraw your consent for the collection, use and disclosure of your Personal Data. However, we will evaluate a request for deletion against:

The overriding interests of Sephora or any other third party; and

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 collection, use and disclosure of your Personal Data if you contest the accuracy of the data, or the collection, use and disclosure is illegitimate, or the data are no longer needed for the purposes mentioned in section 2.

You may exercise your right to object to our collection, use and disclosure of Personal Data that relates to you on grounds of your specific situation, unless we demonstrate compelling legitimate grounds for the collection, use and disclosure 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.

We would invite you to exercise these rights by writing to the following address: 391A Orchard Road, #16-00, Ngee Ann City Tower A, Singapore 238873 or by contacting the DPO at this address:

Finally, you have the right to lodge a complaint with the Personal Data Protection Commission. 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.