PRIVACY AND COOKIE POLICY

1. INTRODUCTION
   • Avroy Shlain website (referred to as the “Website”) is owned and operated by Avroy Shlain Cosmetics Proprietary Limited (registration number: 1992/002125/07) (“Avroy Shlain”).
   • This privacy notice (the “Privacy Notice”) applies to all persons using the Website. By accessing the Website, the person that accesses the Website (the “User”) accepts and agrees to this Privacy Notice and expressly consents to the use and disclosure of their personal information in accordance with the provisions of this Privacy Notice. If the User does not agree to the provisions of this Privacy Notice, the User may not access or use this Website.
   • Avroy Shlain reserves the right to amend this Privacy Notice or add provisions to it at any time. By continuing to access and/or use this Website, the User agrees to the amended versions of the Website.
2. INFORMATION COLLECTED
   • Avroy Shlain collects personal information in various instances, including when:
     • the User submits an inquiry;
     • uses the website.
   • If a User accesses the Website without giving Avroy Shlain any personal information, Avroy Shlain may still gather certain non-personal information, including information regarding the User’s Website activities.
   • If the User registers with the Website, Avroy Shlain will collect and use the User’s personal information. This information may include, without limitation, the User’s name and contact details, financial information, transaction history and details of the User’s visits to the Website.
3. PURPOSE OF PERSONAL INFORMATION IS USED
   • The purposes for which Avroy Shlain uses personal information includes, but is not limited to:
     • communicating with the User;
     • providing the User with or specialised advertising or promotional material based on the User’s preferences where such preferences have been shared on our website.
   • Without limiting the generality of the aforesaid, the Website uses analytics to monitor and analyse web traffic and User behaviour on the Website. The analytics used include Google Analytics and Google AdWords.
   • Google Analytics is a web analysis service provided by Google LLC. Google utilises the data collected to track and examine the use of its application, which helps websites understand how to customise pages in order to improve user experience. This service uses cookies to track the actions of a User, including the time spent on the Website and the pages visited. No personal data about a User is collected using a Google Analytics account, and this means Avroy Shlain cannot identify who was on the Website. Users can learn more about Google Analytics from the official Google Analytics page.
   • Avroy Shlain uses Google AdWords remarketing for advertising purposes across the internet. The AdWords remarketing program allows the display of relevant ads based on the pages of the Website that are visited by Users. This information is collected by cookies. Cookies will not identify any personal information or allow access to a User’s computer. The Google AdWords remarketing program enables Avroy Shlain to customise their marketing to serve the needs of a User and to only show that User ads that they may prefer to see.
4. RETENTION OF INFORMATION
   • Avroy Shlain will process the personal information collected from the User at their operating offices and in any other place where the parties involved in processing are located.
   • The User’s personal information will be processed and stored for as long as required for the purpose it has been collected for pursuant to the provisions of this Privacy Notice and as long as required by applicable law.
   • Personal information collected for purposes related to the performance of a contract between Avroy Shlain and the User will be retained until such contract has been performed. Personal information collected for the purpose of Avroy Shlain’s legitimate interests will be retained as long as needed to fulfil such purposes.
   • Avroy Shlain may retain personal information for a longer period in instances where the User has given consent to such processing, and where such consent has not been withdrawn. Avroy Shlain may also be required to retain personal information for a longer period when required to do so in the performance of a legal obligation, in accordance with tax or accounting requirements or upon the order of a court order.
   • Once the retention period expires, personal information will be deleted.
5. DISCLOSURE OF PERSONAL INFORMATION
   Avroy Shlain may release the User’s personal information or disclose it to third parties in certain circumstances, including, but not limited to the following:
   • if required or authorized to do so by law or a court order;
   • in order for it to enforce its rights; and
   • in order for it to provide goods or services.
6. SECURITY
   • For purposes relating to the Website, Avroy Shlain uses systems that are sufficiently secure with reference to accepted technological standards at the time of transactions.
   • Avroy Shlain will secure the integrity and confidentiality of Users’ personal information in its possession and under its control by taking appropriate, reasonable technical and organisational measures to prevent:
     • loss of, damage to or unauthorised destruction of personal information; and
     • unlawful access to or processing of personal information.
   • Avroy Shlain routinely reviews its operations to ensure that personal information remains adequately protected.
7. TRANSFER OF PERSONAL INFORMATION
   • Personal information collected by Avroy Shlain may be transferred to third party partners and businesses, including online payment providers. In such cases, Avroy Shlain will take reasonable steps to ensure that such persons have appropriate privacy measures in place.
   • Personal information collected by Avroy Shlain may be transferred to persons in other countries. The User consents to such transfer. Avroy Shlain will take reasonable steps to ensure that such persons have appropriate privacy measures in place.
8. COOKIES
   • The Website makes use of cookies to collect data. A cookie is a small piece of data that is stored on the user’s electronic device (computer, mobile phone, tablet etc) by a website’s server. It allows a website to keep track of the user’s browsing activities, remember information such as their product preferences and items in the User’s shopping basket.
   • A User may disable or decline cookies. However, if this is done, the User may not be able to use the Website properly and certain aspects of the Website may not function.
   • Avroy Shlain uses cookies to personalise content and ads, to provide social media features and to track traffic on the site. We also share information about your use of our website with our social media, advertising and analytics partners who may combine it with other information that you have provided to them or that they have collected from your use of their services. By continuing to use this website, you consent to our cookies.
9. DATA PROTECTION RIGHTS
   • The User may exercise certain rights regarding personal information processed by Avroy Shlain. In particular, subject to applicable law, the User has the right to do the following:
     • the right to access personal information by requesting a copy of their personal information (which service may be subject to a small fee);
     • the right to rectify personal information by requesting that any inaccurate information is corrected or that any incomplete information is supplemented;
     • the right to erase personal information;
     • the right to restrict the processing of personal information;
     • the right to object to the processing of personal information;
     • the right to object how we use your personal information for direct marketing purposes; and
     • the right to lodge a complaint with a competent supervisory authority.
   • In some instances, the User may withdraw consent for processing. This withdrawal will have no effect on any lawful processing of personal information preceding such withdrawal.
   • If the User wishes to exercise any of these rights, they can contact Avroy Shlain’s information officer using the details below. Avroy Shlain may charge a fee for accessing, amending or deleting your personal information. The User will be advised of this fee in advance, if applicable.
     Contact details
     Avroy Shlain Cosmetics Proprietary Limited
     Telephone number: +27 11 655 3500 or Customer Services 0860 114 182 (Share Call)