Privacy Policy

Last Revised and Effective Date: 3 November 2023

Bellazuri Limited and our subsidiaries and affiliates (collectively, “Bellazuri”, “we”, “us” or “our”) care about the processing, confidentiality, and safety of your personal data.

The aim of this Privacy Policy is to provide you with information about how we collect, use, share, and safeguard your personal data. This Privacy Policy also tells you about your rights and choices with respect to your personal data, and how you can reach us to get answers to your questions. You can jump to particular topics by going to the headings below:

  1.  What is personal data?
  2.  What personal data do we collect and when do we collect it?
  3.  For what purpose is your personal data collected and used?
  4.  Who are the recipients of your personal data?
  5.  International transfers of personal data
  6.  How do we protect your personal data?
  7.  What are your choices and how can you exercise them?
  8.  Cookies and Similar Tracking Technologies
  9.  Contact Details
  10.  Miscellaneous

I.  What is personal data?

Personal data is information that either identifies you or is about you as an individual. 

II.   What personal data do we collect and when do we collect it?

We collect information about you in a variety of ways depending on how you interact with us and our products and services, including through our websites, media channels, online and mobile applications, advertisements, and in selected stores.

  • The following provides examples of the type of personal data that we collect from you and how we use that information.

Context

Information We Collect

Primary Purpose for Collection and Use of Information

Create a customer account

If you create a customer account on our websites, apps, or in one of our stores, we collect your name, email address, and the month and day of your birthday, if you choose to provide it. Within your customer account, you can also store additional information such as mailing address, phone number, and payment methods. We also collect information relating to the actions that you perform while you are logged into your account.

We have a legitimate interest in providing account related functionalities to our customers and managing access to customer accounts. Customer accounts can be used for faster and simpler checkout, to save your personal preferences and order history, and receive updates about your order details.

Order goods from our websites

If you place an order on one of our websites, we collect your name, email address, phone number, shipping address, billing address and payment details (payment card number, expiration date, CVV/CVC, etc.). By agreeing to the Terms and Conditions of our website, you are deemed to freely give your payment details and consented to the collection of such data.

We use your information to perform our contract with you to process your orders and to provide you with the products or services you have requested.

Make purchases in our stores

If you make a purchase in one of our stores, we may collect your name, email address, billing address and payment details (payment card number, expiration date, CVV/CVC, etc.). By agreeing to the Terms and Conditions of our website, you are deemed to freely give your payment details and consented to the collection of such data.

We use your information to perform our contract with you to provide you with the products you have requested.

Shade finder and other similar online beauty services

You may choose to upload a photo or video (via your webcam). Unless otherwise noted, we only use photographs to identify skin tone and/or make cosmetic recommendations.

We have a legitimate interest in offering beauty related services, such as recommendations to match cosmetic products with skin tone.

Sign up for our mailing list

When you sign up for one of our mailing lists, we collect your email address, phone number, or postal address, depending on your selection.

We share information about our products, services, offers, news and events with those individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products or services.

Participate in surveys

If you choose to participate in a survey or satisfaction questionnaire, we collect information that you provide through the survey. If the survey is provided by a third-party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information.

We have a legitimate interest in understanding your opinions and collecting information relevant to our organization.

Contact us

If you contact us, such as via our website, customer service center, or social network pages, we collect your name, contact information (email and/or phone number) as well as any other information you provide to us in order to reply.

We have a legitimate interest in managing customer relations with respect to any requests for information or complaints that we receive. We also have a legitimate interest in responding to inquiries related to support, employment opportunities, and other requests.

Report potential adverse reactions

If you contact us to notify us of an undesirable reaction concerning any of our products, we collect your name, contact information, as well as any other information you provide to us, including specific health data if you choose to provide it.

We have a legitimate interest in receiving, processing, following up, and responding to, your reports as part of our cosmetic vigilance obligations. In some jurisdictions, we are also required by law to record information related to product safety and adverse event reports. We have a legitimate interest in complying with all legal requirements to collect information in the countries in which we operate.

Interact with us on social networks

If you interact with us through our official page on social networks, or if you publish content on a social network or participate in online forums, we collect any content that you choose to provide, which may include your social media handle or account profile.

We have a legitimate interest in communicating with you, understanding your opinions, and providing tailored services and products.

Take part in an event, sweepstakes, contest, or promotion

If you take part in an event, sweepstakes, contest, or other similar promotion, we collect information about you including your name and contact information.

We have a legitimate interest in operating and managing participation in our events, sweepstakes, contest, and other similar promotions. In some jurisdictions, we are also required by law to collect information about those that enter into our sweepstakes. We have a legitimate interest in complying with all legal requirements to collect information in the countries in which we operate.

III.   For what purpose is your personal data collected and used?

In addition to the purposes and uses described above, we use data in the following ways:

  • To identify you when you visit our websites or our stores.
  • To streamline the checkout process, to provide products and services, and to process returns.
  • To secure online transactions, prevent fraud and payment incidents, and manage debt collection (see our terms and conditions for more details).
  • To manage and optimize customer experience by improving our knowledge of our customers.
  • To propose appropriate, tailored services, particularly when we enhance our products and services.
  • To conduct statistical analyses to develop management, measuring and reporting tools in order to adjust and improve our sales, marketing and product manufacturing.
  • To send marketing and promotional materials, including information relating to our products, services, sales, or promotions.
  • To manage our relationships as well as for internal administrative purposes.

Although the sections above describe our primary purpose in collecting your personal data, in many situations we have more than one purpose. For example, if you complete an online purchase, we collect your personal data to perform our contract with you, but we also collect your personal data as we have a legitimate interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about your order. As a result, depending on the requirements of applicable privacy laws, our collection and processing of your personal data is based in different contexts upon your consent, our need to perform a contract, our legal or regulator obligations, and/or our legitimate interest in conducting our business.

IV.   Who are the recipients of your personal data?

In addition to the specific situations discussed elsewhere in this Privacy Policy, we may share personal data, only with your consent and upon our satisfaction that the persons with whom your personal data is shared possess sufficient mechanism for its protection, in the following situations:

  • Affiliates. We may share personal data with our corporate affiliates (e.g., parent company, subsidiaries, and brands) when those entities are processing personal data on our behalf. 
  • Business Transaction. If another company acquires, or plans to acquire, our company, business, or our assets, we will share personal data with that company, including at the negotiation stage for the purposes of evaluating or completing the transaction. 
  • To Provide a Product or Service You Request. We may share your personal data to comply with your request for the shipment of products to or the provision of services by a third-party intermediary.
  • Other Disclosures with Your Consent. We may ask if you would like us to share your personal data with other third parties who are not described elsewhere in this Privacy Policy.
  • Other Disclosures without Your Consent. We may share personal data with third parties in response to subpoenas, warrants, court orders, or other requests from legal or regulatory authorities; in connection with any legal process; or to comply with relevant legal, regulatory or treaty obligations. We may also share your personal data in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or act regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.
  • Public Forums. Some of our websites provide the opportunity to post comments or reviews in a public forum. If you decide to submit information on these pages, that information may be publicly available.
  • Partner Promotion. We may offer contests, sweepstakes, or other promotions with third party partners. If you decide to enter a contest, sweepstakes, or promotion that is sponsored by a third party partner the information that you provide will be shared with us and with them. Their use of your information is not governed by this privacy policy.
  • Service Providers. We share your personal data with service providers. Among other things, service providers help us to administer and maintain our websites, send communications, provide technology solutions at counters in our stores, conduct surveys, assist with customer service, provide technical support, process payments, provide ant-fraud services, manage regulatory alerts or notifications, provide marketing solutions, assist in order fulfillment, and organize events.
  • Social Media Platforms and Other Third-Party Services. Some of our websites contain certain features such as widgets, buttons, content, or other similar services that are provided by third parties (e.g., YouTube, Facebook, Twitter, Instagram, and/or Pinterest). If you choose to use or interact with these features, certain information may be shared with or collected by those third parties. For more information about what information is shared or collected, and how it is used, see the applicable company’s privacy policy.

V.   International transfers of personal data

Your personal data may be processed, stored, shared, transferred, or disclosed by us with our affiliate entities or with other third parties for the purposes described in this privacy notice. We do this in order to operate effectively, efficiently, and securely in facilitating transactions and providing products and services to our clients, to improve and support our processes and business operations and to comply with our legal and regulatory obligations. This may involve processing, storing, sharing, transferring, or disclosing your personal data cross border to other jurisdictions. 

Where recipients of your personal data are in jurisdictions that are outside Uganda, we will ensure that the transfer of your personal data is subject to your express consent and have obtained the relevant regulatory approvals. 

For further information on transfers of your personal data, please contact our Data Protection Officer on info@bellazuri.com

VI.   How do we protect your personal data?

We take the privacy and security of your personal data very seriously. To protect your data, we have put in place a range of appropriate technical, physical and organisational measures to safeguard and keep your personal data confidential, for example, by using contracts with appropriate contractual confidentiality, data protection and security terms in our arrangements with third parties. 

We train and require staff who access your personal data to comply with our data privacy and security standards. We require our service providers, or other third parties we engage with and to whom we disclose your personal data to implement similar confidentiality, data privacy and security standards and measures when they handle, access or process your personal data. 

Some of our websites permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.

VII. How long do we retain your personal data?

Typically, we retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements, unless a longer retention period is required or permitted by law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we obtained the information and whether we can achieve those purposes through other means, as well as applicable legal requirements.

VIII. What are your choices and how can you exercise them?

You may have the following choices regarding your personal data:

  • Access to Your Personal Data You may request access to your personal data, including a copy of your personal data, by following the instructions described in the Contact Details section below. In certain limited circumstances, you may also request to receive access to your personal data in a portable, machine-readable format. If required by law, upon request, we will grant you reasonable access to the personal data that we have about you.
  • Changes to Your Personal Data. We rely on you to update and correct your personal data. Most of our websites allow you to modify or delete your account profile. Note that we may keep historical information in our backup files as permitted by law. If our website does not permit you to update or correct certain personal data, you may contact us at the address described in the Contact Details section below to request corrections to information that is inaccurate or incomplete.
  • Deletion of Your Personal Data. You may request that we delete your personal data by following the instructions described in the Contact Details section below. If required by law, we will grant a request to delete personal data, but you should note that in many situations we must keep your personal data to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
  • Objection to Certain Processing. You may object to our use or disclosure of your personal data by contacting us at the address described in the Contact Details section below.
  • Revocation of Consent. If you revoke your consent for the processing of personal data, then we may no longer be able to provide you services. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described in the  Contact Details section below.
  • Right to Opt-Out of Targeted Advertising You may opt-out of online tracking based targeted advertising (e.g., cookies) by clicking the cookie settings link here or the “Do Not Share” link on our homepage. Please note that if you change browsers or computers, or if you clear your browser’s cache, you may need to click the link again to apply your preference. You may also opt-out of other forms of targeted advertising by submitting a request as described below.
  • Online Tracking. We do not currently recognize the “Do Not Track” signal.
  • Promotional Emails. If, at any time, you no longer wish to receive details of our offers, news and events, you can unsubscribe using the hypertext link provided for this purpose in each mail we send you. If you decide not to receive promotional emails, we may still send you service-related communications.
  • Promotional Text Messages. If you receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying “STOP.”

Please note that not all of the rights described above are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your request if the law permits or requires us to do so, or if we are unable to adequately verify your identity. We will not discriminate against individuals who exercise any of their privacy rights under applicable law. If you disagree with how we handled a request, you may appeal our decision by contacting us at the address described in the Contact Details section below with the subject line “Appeal.”

To protect your personal data, we must be able to verify your identity before we can process your request to exercise any of the choices described in this section. We may conduct the verification process by email or phone, and we will ask you to provide information such as your name, contact information, and any additional relevant information based on your relationship. We will then match this to the information we maintain in our records.

In some circumstances, certain individuals may designate an authorized agent to submit requests to access or delete personal data. We will require verification that the authorized agent has permission to make such a request.

IX.   Cookies and Similar Tracking Technologies

We use a variety of technologies such as cookies, web beacons, clear GIF, pixels, internet tags, and browser/web logs to gather information when you visit or interact with our websites, mobile apps, and email communications. Cookies are small text files that are placed on your computer or mobile device by websites you visit. We use this information for a variety of purposes, such as to make our websites work properly, to make a user’s experience more efficient, to understand how visitors interact with our websites, and to for advertising purposes. For more information about how our websites use cookies and to update your preferences, click the Cookie Settings link.

X.   Contact Details

You can exercise any of the rights described above in the “What are your choices and how can you exercise them?” section above directly with Bellazuri or if you have any questions with respect to this privacy policy by sending an email to our Data Protection Officer on info@bellazuri.com

If you are submitting a request on behalf of another person, you must provide proof that you have been authorized by the individual to act on his or her behalf. In certain circumstances, we may ask the individual to verify his or her own identity directly with us. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

XI.   Miscellaneous

The following additional information relates to our privacy practices:

  • Third Party Applications/Websites. Our websites may include links to websites or applications that are owned or operated by third parties. Please note, we have no control over the privacy practices of websites or applications that we do not own. For example, some of our websites utilize the YouTube API Services to provide video content. When you interact with the YouTube functionality available through one of our websites, you will be subject to agree to the YouTube Terms of Service and Privacy Policy. We encourage you to review the privacy policies of any third-party website or application for details about what information is collected and how it is used and/or shared.
  • Changes To This Privacy Policy. We may change our privacy policy and practices over time. You can check the legend at the top of this page to see when this Privacy Policy was last revised. To the extent that our Privacy Policy changes in a material way, the policy that was in place at the time that you submitted personal data to us will generally govern that data unless we receive your consent to the new privacy policy.