Legal

MOROCCANOIL PRIVACY POLICY

 

Moroccanoil respects your privacy and is committed to protecting the personal information that you share with us. Generally, you can browse through our website without giving us any information about yourself (except for cookies and pixel tags, as provided in our Cookie Policy. If you are a resident of the European Union, when we do need your personal information to provide services that you request or when you choose to provide us with your personal information, for example when you decide to contact us for additional information or subscribe to our newsletter, this policy describes how we collect and use your personal information.

 

  1. Who is Responsible for the Processing of Your Personal Data?

The entity responsible for the processing of your personal data is Moroccanoil Israel Ltd., referred to as Moroccanoil, “our”, “we” or “us” in this privacy policy. Our representative in the European Union is 

Moroccanoil DE GmbH HRB 110685
Friedrich-Ebert-anlage 36
60325 Frankfurt am Main

              

  1. The Information We Collect, How We Collect it and Use it

Personal information means any information that may be used to identify an individual, including, but not limited to, a first and last name, email address, a home, postal or other physical address, other contact information, title, birth date, gender, occupation, industry, personal interests, and other information when needed to provide a product or service you requested.

These are the categories of personal data we collect directly or indirectly from you:

 

Identity information – includes full name, date of birth, e-mail address, unique consumer identifier number, nickname, password, and gift card codes that are assigned to you.

               

Contact information – includes your phone number, shipping and billing address, e-mail address, Messenger ID, social media handle, any other communication channel you have used to contact us for more information.

 

Purchase information – includes your payment information (credit card number), payment risk profile (provided to us by our payment risk solution), shopping cart (your ordered items), delivery details, shipping and billing address, customer order number, purchase history with Morrocanoil, transaction ID, and any other information related to your purchase. We use it to complete your order on Morrocanoil sites.

 

Behavioral and Profile information – includes your shopping history, your browsing behavior, your browsing preferences, your shopping preferences, product reviews and any other characteristics we obtain about you.

 

Device information – includes information about your device or browser that gives us an idea about your browsing behavior or device usage. Your device information is collected by our app, and your browser information is collected by our cookies, tags, and pixels. This is often required for network security purposes. This includes, but not limited to: IP address, date and time of the visit, how long you remained on our website, the referral URL (if you came to our site via a different site or an advertisement), the pages visited on our site, your browser type, device type, versions, operating system.

 

Correspondence – includes conversation we have when you contact customer service, the emails you write us about our products or services, chat correspondence in our social media pages, the complaints you address to us via post, e-mail, fax, or call, notes we prepared on your feedback, call back from our customer service to you, and any other communication between you and our personnel. We record all customer service calls for quality assurance purposes.

 

Preference information – includes preferred language, log-in location, preferred shipping address, browsing preferences, our correspondence with you, your Morrocanoil product reviews.

 

  1. Legal Basis for Processing and How We Use Your Information

Our collection and processing of personal information are based on the following:

 

  1. Site Operation

 

To run the sites and applications that are connected to the Morrocanoil domain, fix bugs to make sure you always see the site the way we intended and monitor compliance with our Terms and Conditions, we screen all traffic to our site and analyze data that is received by our servers.

Use of Cookies/Tags/Pixels: We may collect your personal data for this purpose by using technologies such as cookies, pixels, and tags to collect your device information.

 

LEGAL BASIS:  Legitimate Interest

 

CATEGORIES OF PERSONAL DATA:           

  • Device information
  • Identity information
  • Behavioral and Profile information
  • Preference information

 

  1. Domain and Network Security and User Authentication

 

To protect our domains, detect unusual activities, and prevent payment fraud and security threats, we screen all traffic to our sites and authenticate user log-in information using tokens to verify the details you provide to us and compare it with other available information, such us the credentials you have provided directly to Moroccanoil or other platforms or information that is available in the public domain to ensure only “authorized” users have access to our sites. 

Use of Cookies/Tags/Pixels: We may collect your personal details for this purpose by using technologies such as cookies, pixels, and tags to collect your device information.

 

LEGAL BASIS: Legitimate Interest

 

CATEGORIES OF PERSONAL DATA:           

  • Device information
  • Identity information
  • Behavioral and Profile information
  • Preference information

 

  1. Sales of Moroccanoil Products - Online and Off-Line Order

 

To process your online, provide you with different payment options, create a smooth check-out process for you, make sure your payment is received, and comply with the requirements under our Terms and Conditions, including invoice processing, delivery, personalization services, exchanges, and refunds, etc. Your order cannot be completed if our payment fraud detection solutions flag your transaction as suspicious and potentially fraudulent. Please note the payment fraud detection system is an automated decision-making process. It is required to allow us to conclude the contract with you. You have the right to request a human review of this decision and challenge the decision.

 

LEGAL BASIS:   

  • Performance of Contract
  • Legitimate Interest
  • Legal Obligation

 

CATEGORIES OF PERSONAL DATA:           

  • Identity information
  • Contact information
  • Purchase information
  • Correspondence
  • Device information

 

  1. Payment Processing and Fraud Detection

 

We combine the purchase information you provide to us with other information we obtain through our third-party payment risk and fraud prevention service providers to ensure any purchases are legitimate, or you do not purchase our products in violation with our Terms and Conditions. This means depending on the outcome of the analysis of your information, we may reject your order, and decline your payment. This is an automated decision-making process that is required to conclude our sales contract with you.

 

We may use the service of Braintree (a PayPal Service) for the purpose of processing your payments. In such circumstances, Braintree and/or PayPal will also be independent controllers of your personal data subject to their privacy statement available here: https://www.braintreepayments.com/de/legal/braintree-privacy-policy

 

LEGAL BASIS:  Performance of Contract; Legitimate Interest

 

CATEGORIES OF PERSONAL DATA:           

  • Identity information
  • Contact information
  • Behavioral and Profile information
  • Purchase information
  • Device information

 

  1. Product Delivery

Once you have successfully placed an order, we use your contact details (home and/or shipping address) and other purchase information to deliver the products you purchased to you.

 

LEGAL BASIS: Performance of Contract

 

CATEGORIES OF PERSONAL DATA           

  • Identity information
  • Contact information
  • Purchase information

 

  1. Business Operational Analytics

 

For the purpose of evaluating our business operations, we need to analyze different categories of information to understand how our products are selling in different markets, what are the popular features of our products, what worked and what didn’t in terms of our marketing and advertising campaigns, our product designs and distribution strategy, our website design and overall user experience, so we can establish, implement, and evaluate our business strategy.

This includes analyzing data to understand how users browse our site and use the app to improve our user experience design to make sure you will continue to purchase our products and interact with us on our sites.

Use of Cookies/Tags/Pixels: We may collect your personal details for this purpose by using technologies such as cookies, pixels and tags to collect your device information.

 

LEGAL BASIS: Legitimate Interest

 

CATEGORIES OF PERSONAL DATA           

  • Identity information
  • Purchase information
  • Behavioral and Profile information
  • Device information
  • Correspondence

 

  1. Customer Service

 

We collect your personal data to tell you when the product you like is available upon your request and respond to your questions and concerns through various communications channels we make available to you. Your requests to our customer service will be analyzed so that we can provide you with valuable service in the future.

 

LEGAL BASIS:  Legitimate Interest; Performance of Contract

 

CATEGORIES OF PERSONAL DATA:           

  • Identity information
  • Contact information
  • Purchase information
  • Correspondence

 

  1. Personalized Marketing Messages

 

We send you marketing messages that we think you would be interested (“personalized”) to the email address you provide to us. To send you “personalized” messages, we observe your online (and sometimes, where applicable, offline) behavior, and analyze your behavior using analytics to best estimate what product lines you might be interested in, and you can benefit from. This requires us to collect various categories of Personal Data from you. We use different analytics tools to understand what your behavior means in terms of your like and dislike of our various product lines, and to understand the impact (success rates) of the messages delivered to you.

Use of Cookies/Tags/Pixels: We may collect your personal details for this purpose by using technologies such as cookies, pixels and tags to collect your device information.

 

LEGAL BASIS: Consent

 

CATEGORIES OF PERSONAL DATA           

  • Identity information
  • Contact information (if available to us)
  • Purchase information (if available to us)
  • Behavioral and Profile information (if available to us)
  • Device information
  • Preference information (if available to us)

 

  1. Targeted Messages On 3rd-Party Advertising Platforms

 

We use third-party advertising platforms, such as Facebook, Google, YouTube, Instagram, etc. to send you messages that are targeted at you, based on your behavior and browsing pattern, at specific times and locations of these platforms to increase the efficiency of our advertising campaigns. We use third-party solutions such as Google Analytics and Facebook Business Manager tools to help us do a better job at targeting our campaigns and messages for our consumers. Your personal data is shared with the third-party advertising platforms, and they will attempt to match your profile in their database to determine the optimal time and place (the page you are browsing) to show you an advertisement from Moroccanoil. We also need to analyze necessary information to understand the impact of our campaigns. If you do not accept that we track you for this purpose, you will still see Moroccanoil advertisements on other platforms at random.

You can learn more about how our Advertising Partners help us achieve this purpose by visiting their sites:

Instagram – https://help.instagram.com/519522125107875

Facebook – https://www.facebook.com/policy.php

Pinterest – https://policy.pinterest.com/en/privacy-policy

Twitter – https://twitter.com/en/privacy

Youtube – https://www.youtube.com/howyoutubeworks/policies/community-guidelines/

Google Tag Manager – https://www.google.com/analytics/terms/tag-manager/

Google Ads – https://policies.google.com/technologies/ads?hl=en-US

Taboola – https://www.taboola.com/policies/platform-terms-of-service

Outbrain – https://www.outbrain.com/advertisers/guidelines/

Tiktok – https://www.tiktok.com/legal/privacy-policy?lang=en

Bronto – https://bronto.com/policies/bronto-data-processing-addendum/

 

Use of Cookies/Tags/Pixels: We may collect your personal details for this purpose by using technologies such as cookies, pixels and tags to collect your device information.

 

LEGAL BASIS: Consent

 

CATEGORIES OF PERSONAL DATA:           

  • Identity information
  • Contact information (if available to us)
  • Purchase information (if available to us)
  • Behavioral and Profile information (if available to us)
  • Device information
  • Preference information (if available to us)

 

  1. Product Research and Development

 

We conduct analysis to research improve our products and services. This includes asking you questions in surveys, asking you for feedback, asking you to test our products and provide us with a review, asking other service providers to conduct market and product research for us to stay ahead of the competition.

 

LEGAL BASIS: Legitimate Interest

 

CATEGORIES OF PERSONAL DATA           

  • Identity information (only if required by the project)
  • Contact information (only if required by the project)
  • Purchase information (only if required by the project)
  • Behavioral and Profile information (only if required by the project)
  • Device information (only if required by the project)
  • Correspondence (only if required by the project)
  • Preference information

 

  1. Legal Obligation

 

When we are legally required to provide your personal data for national and public security reasons, crime prevention, investigation and prosecution, anti-money laundering, judicial proceedings, protection of other individuals’ rights and freedoms, and enforcement of civil claims, we will provide information as requested by the authorities or parties once we are satisfied that the request is mandated by law. We may not be able to notify you if it is against the law to do so.

 

LEGAL BASIS: Legal Obligation

 

CATEGORIES OF PERSONAL DATA:           

All Categories of Personal Data as requested by the enforcement authority.

 

  1. Collecting Your Device Information on Our Website Using Cookies, Pixels, Tags, And Similar Technologies (“Cookies Notice”)

 

When you visit the Moroccanoil site, we store data collectors such as cookies, tags, pixels, tag containers, beacons, among others, in your browser to obtain certain information about your current browsing session. These technologies are often referred to as “Cookies” collectively by other websites. Cookies also enable our website to remember your actions and preferences (such as login, language, font size, and other display preferences) over a period, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another. We use Cookies for different purposes, which also means they have different legal bases. Please review our Cookie Policy to understand how we use different types of Cookies to fulfill different purposes.

 

  1. Information Sharing and Disclosure

Because Moroccanoil is a global company, your personal information may be shared with other Moroccanoil offices or subsidiaries around the world. All such entities are governed by this Privacy Policy or are bound by the appropriate confidentiality and data transfer agreements.

Moroccanoil may share your personal information with other companies or people under any of the following circumstances and to the following categories of recipient:

  • when we have your consent to share the information;
  • we need to send the information to third parties who work on behalf of Moroccanoil to provide you with customer service or promotional materials (we will only provide those companies the information they need to deliver the service, and they are prohibited from using that information for any other purpose);
  • in the event of sale or transfer of all or substantially all of Moroccanoil or any Moroccanoil affiliate’s shares or assets, in cases of mergers or in case of negotiations with respect to the foregoing;
  • to our service providers and subcontractors in order to keep you up to date on any information we think you would like to hear about either from us or from our business partners (unless you have opted out of these types of communications), subject to your opt-in consent to such processing activities;
  • to our subsidiaries and affiliates for the purpose of managing our international group of companies;
  • to our service providers and business partners for any of the purposes set forth in Section 3 above, including to online advertising tools and platforms such as Google, Facebook, and other, as well as to third party information technology and cloud computing service providers, all subject to the terms of this Privacy Policy;
  • Where needed for corporate audits or to investigate or respond to a complaint or security threat, to prevent illegal uses of our services, to defend ourselves against third-party claims and assist in fraud prevention or investigation; or
  • We will also disclose your personal information if required to do so by law, or in urgent circumstances, to protect personal safety, the public, or our website.

 

We will not sell or otherwise transfer the personally identifiable information you provide to us at our Websites to any third parties for their own direct marketing use unless we provide clear notice to you and obtain your explicit consent for your data to be shared in this manner.

For the above purposes, personal information may be transferred to recipients in countries around the world (which may be located outside the EU/EEA) which in some cases may have a lower level of protection than that within the EU/EEA. When transferring personal data to countries outside the EU/EEA, to jurisdictions that did not receive an adequacy decision by the European Commission, we use standard contractual clauses approved by the European Commission to ensure a sufficient level of protection for your personal information. The standard contractual clauses can be found via the following link: http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm.

 

  1. Data Subject Rights

If you are a resident of the EU/EEA, you may at any time request the rectification or erasure of your personal information. Please note however that deletion could mean that Moroccanoil cannot process your requests or provide you any requested services. You have the right to request a copy of your personal information from our record. You have the right to request a limitation of the use of your personal information (for example if you deem the information to be incorrect) or the termination of use of your personal information (for example as regards the use of the information to improve our services). You have the right to object to any of our processing of your personal data. Any of the above-mentioned requests are subject to limitations set forth under applicable law, and we reserve the right to decline any such request subject to adequate reasoning.

If you have a Moroccanoil account, you can opt out of receiving marketing communications by modifying your preferences in the "account" section of our website. You can also opt-out by modifying your email or SMS subscriptions by clicking on the unsubscribe link or following the opt-out instructions included in the message. Alternatively, you can contact us using the contact details below.

 

  1. Data Security

Moroccanoil safeguards the security of the data you send us with physical, electronic, and managerial procedures, taking into consideration the state of the art, the costs of implementation, and the nature, scope, context, and purposes of processing as well as the risk of processing your personal information. While we strive to protect your personal information, we cannot ensure the security of the information you transmit to us, and so we urge you to take every precaution to protect your personal data when you are on the Internet.

 

  1. Third-Party Sites

Our website may contain links to websites operated by other companies. Moroccanoil does not share your personal information with those websites and is not responsible for their privacy practices. We encourage you to learn about the privacy policies of those companies. Some of these third-party sites may have permission to include the Moroccanoil logo, even though they are not operated or maintained by Moroccanoil. Although we choose our business partners carefully, Moroccanoil is not responsible for the privacy practices of websites operated by third parties that are linked to our site. Once you have left our website, you should check the applicable privacy policy of the third-party website to determine how they will handle any information they collect from you. We may provide services based on third-party applications and content tools on the Moroccanoil website. These third parties may automatically receive certain types of information whenever you interact with us on our website using such third-party applications and tools, based on such third parties’ privacy statements.

 

  1. Changes to This Privacy Policy

Moroccanoil will amend this policy from time to time. If we make any substantial changes in the way we use your personal information we will make that information available by posting a notice on this site.

 

  1. Privacy Inquiries

Moroccanoil is responsible for the processing of your personal data, and requests to exercise your rights as stated above shall be addressed to Lenor Sebag, DPO, Privacyeu@moroccanoil.com.

If you are a resident of the EU/EEA and have a complaint regarding the processing of your personal data by Moroccanoil you are entitled to report such dissatisfaction to the applicable supervisory authority in your country of residence.