April 2020

SEPHORA KOZMETİK A.Ş. (hereinafter ‘ Sephora ’,‘ we ’ or ‘our ’), as the data controller, 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 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.

Modification of the Fact Sheet

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 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 and what are the legal grounds for collection of 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 take steps at your request prior to entering into a contract, to contact with you and to evaluate your suitability with the relevant job offer. The processing of your personal data for this purpose is based on the legal ground of “provided that it is directly related to the execution or performance of a contract, requirement of the processing of personal data of the parties to the contract”;

(ii) management of the job offers for which you may be suited ; The processing of your personal data for this purpose is based on your “explicit consent” as resulting from the sharing options you have notified us with ; and

(iii) 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 provided not to damage your fundamental rights and freedoms” to continuously improve our recruitment practices.

Sephora may also process your personal information to the extent necessary for the protection of our legitimate of being able to defend ourselves in case of a dispute and to comply without our legal obligations based on the legal ground of “being mandatory of processing data for granting, using or protecting a right”.

What type of personal data do we process and method of collection of personal data ?

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 and your application information, 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, or during our interview or contact.

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:

Identity: data relating to your civil status and identity, such as  surname and forename;

Professional experience:

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

- Results of any assessments and/or occupational testing;

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

Contact details: (such as address, telephone number, email),

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

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

Transaction security: data enabling connection to recruitment platform (such as user ID, connexion data…).

Sensitive personal data (disability status within health data category and criminal record within criminal conviction and security measures data category): Your sensitive personal data can only be processed based on your “explicit consent”.

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 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.

Who can access your personal data and your personal data is transferred to whom ?

Within 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 residing abroad responsible for international careers and talent management based on your “explicit consent” for the purposes of management of your application for employment, management of the job offers for which you may be suited, compilation of statistics regarding Sephora employment opportunities; and  

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

In particular, we rely on third party processors to provide you our recruitment platform and job application. These third-party processors are only allowed to process 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 Turkey.

   As Sephora is part of an international group, based on your “explicit consent” in order to process your personal data for the purposes outlined in article 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. How long do we store your personal data ?

Sephora keeps your data for a maximum period of 24 months after the last contact between Sephora and yourself. If you grant your “explicit consent” from the sharing options for keeping your data in our database, Sephora keeps your data unless you withdraw your “explicit consent”. 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.

Your rights

As a personal data owner, in the event that send us your requests regarding your rights by the methods set out below, we will conclude your request free of charge as soon as possible depending on the nature of your request and within thirty days at the latest. However, if the transaction requires a separate cost, the fee determined by the Personal Data Protection Board will be based on. Within this context, you have the following rights, as data owner;

•        to learn whether your personal data were processed or not,

•        if your personal data were processed, to request information on this subject,

•        to learn the purpose of processing of your personal data, and whether or not they were used in compliance with the purpose,

•        to learn the third persons to whom your personal data were transferred at home or abroad,

•        if your personal data were processed inaccurately or incompletely, to request correction of the data, and to request that the procedure performed within this scope be notified to the third persons to whom your personal data were transferred,

•        if, although the personal data were processed in compliance with the Law and any other related statutory provisions, the reasons that required processing of data are no longer applicable, to request that the personal data be deleted or destroyed, and within this scope, and if your personal data were inaccurately or incompletely processed, to request that the procedure performed be notified to the third persons to whom your personal data were transferred,

•        to object to any results that are detrimental to you as a consequence of the analysis of your personal data exclusively through automated systems,

•        To request reimbursement for any kind of loss incurred due to unlawful processing of your personal data.

Notification of changes

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

This Applicants Fact Sheet was last updated and revised on the [please insert date].