When you provide us with information through this Hong Kong web site, www.esteelauder.com.hk (“Estée Lauder HK Site” or “this Site”), we respect your privacy. It is important for you to understand what information we collect about you during your visit and what we do with that information. Your visit to this Site is subject to this Privacy Policy and our Terms and Conditions. Please note that this Privacy Policy governs only information provided to Estée Lauder Hong Kong. It does not govern any other information or communications that may reference Estée Lauder, e.g. communications from Estée Lauder counters located within bricks and mortar retail stores. If you visit one of our other regional websites, e.g. esteelauder.com, you are subject to the privacy policy applicable for that website and you should review such privacy policy. This Privacy Policy was last updated January 2007.

1. Information Collection

We do not collect personally identifiable information about you, except when you provide it to us directly or through a third party. For example, if you decide to complete a user registration form or complete an online survey, you may be asked to provide certain information such as your name, contact information (email address, mailing address and telephone number), birthday, gender, product and/or cosmetic concerns, and the brands and products you use. Please note you may be transferred to a third party service provider's website in order to submit this information.

If you would prefer that we do not collect any personally identifiable information from you, please do not provide us with any such information. To protect your personal information, users registering at this Site must also enter a user name and password.

Prior to your submission of your personally identifiable information to this Estée Lauder HK Site, you will be asked whether you consent to the processing and transfer of your personal information in accordance with this Privacy Policy. If you consent, you will be able to submit your information to this Estée Lauder HK Site.

2. Use of Personally Identifiable Information

We strive to provide you with a full range of information and content services relating to skincare and cosmetic products. In order to provide you with this level of service, we will use your personal information in the manner described below, and you hereby expressly consent to its use in such manner:

a. Communications to Serve You

If you have elected to provide us with your contact information, e.g. by registering at the Estée Lauder HK Site or emailing our Customer Service department, we may provide you with service related announcements concerning the Estée Lauder HK Site or contact you regarding your customer service requests. For example, all registered users will receive a welcoming email to confirm their registration. We may also contact you to respond to your product questions or concerns that you have expressed. These types of communications are necessary to serve you, respond to your concerns and to provide the high level of customer service that we offer our customers.

b. Opt-Out Communications

In addition to the essential service related announcements that we will send you as described in Section 2(a) above, when you submit personally identifiable information, the information you provide may be used to create and deliver to you our newsletters, surveys or other communications containing product and event information, cosmetics tips or promotions (“Opt-Out Communications”). Sometimes Opt-Out Communications will include information relating to third party products or services selected by us which we think may interest you. If you prefer not to receive Opt-Out Communications, please see Section 13 (Choice) below.

3. Use of Personally Identifiable Information by Group Companies

We may share your personally identifiable information with our affiliates (including parents and subsidiaries) and other divisions of our company that distribute and market Estée Lauder products (the "Group Companies"). The Group Companies may use this information in accordance with this Privacy Policy. See also Section 6.

4. No Disclosure of Personally Identifiable Information for Third Party Marketing Without Your Consent

Except as detailed in this Privacy Policy we will not provide your personally identifiable information to third parties for their use in marketing their products or services to you without your consent.

5. Disclosure of Personally Identifiable Information

a. Fraud Protection and Compliance with Law

We may disclose any information, including personally identifiable information, we deem necessary, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request.

b. Service Providers

We may retain other companies and individuals to perform functions consistent with our Privacy Policy on our behalf. Examples include customer support specialists, webhosting companies, fulfillment companies (e.g. companies that coordinate mailings), data analysis firms and email service providers. Hachette Filipacchi Hong Kong Ltd. is one, but not the only one, of such third parties. Such third parties may be provided with access to personally identifiable information needed to perform their functions, but may not use such information for any other purpose. See also Section 6.

c. Special Events

If you elect to participate in any promotions, sweepstakes, surveys, questionnaires or other events during your visit to our Estée Lauder HK Site, the rules or terms and conditions for those events may indicate that your personally identifiable information will be shared with third parties. By choosing to participate and submitting your personally identifiable information with respect to such events, you consent to disclosure of your personally identifiable information to such third parties. We are not responsible for, and to the maximum extent permitted by law disclaim all liability for, any use of the information you choose to provide to such third parties.

d. Business Transfers

As we continue to develop our business, we might sell certain of our assets. In such transactions, user information, including personally identifiable information, generally is one of the transferred business assets, and by submitting your personal information through the Estée Lauder HK Site, you agree that your data may be transferred to such parties in these circumstances.

6. Transfer of Data to Other Countries

The Group Companies and third parties referenced in Sections 3 and 5 who will receive your information only for the purposes set forth in this Privacy Policy, the third parties with whom you direct us to share your information referenced in Sections 4 and 5 and the databases in which your personally identifiable information may be stored both inside and outside Hong Kong. By providing personally identifiable information to this Estée Lauder HK Site, you acknowledge and accept that the Group Company or third party which receives your personally identifiable information may be located within a state or country which does not guarantee the same level of protection for personally identifiable information as the one in which you reside.

7. Cookies, IP Addresses, Pixel Tags and Tracking Technology

A cookie is a piece of data that enables us to track and target your preferences. We may place a "cookie" on your computer's hard drive so we can recognise you as a return user and personalise your experience and your use of our Estée Lauder HK Site. The cookie will be stored on your computer's hard drive until you remove it. You can have your browser notify you of, or automatically reject, cookies. If you reject our cookies, you may still use the Estée Lauder HK Site, but you may be limited in the use of some of the features.

We may also use IP addresses to analyse trends, administer the Estée Lauder HK Site, track traffic patterns, and gather demographic information for aggregate use, as well as in combination with your personally identifiable information for credit fraud protection and risk reduction.

When you visit this Estée Lauder HK Site or view one of our emails, we may use pixel tags (also called "clear" gifs), tracking links and/or similar technology to note some of the pages you visit on our Estée Lauder HK Site and personalise your experience. We may also use pixel tags to determine what types of emails your browser supports. We may use the information collected through pixel tags, tracking links and similar technology in combination with your personally identifiable information.

Some of our other business partners and service providers may also use cookies on their sites. For example, you may have clicked through to this Site from one of their sites. We have no access to, or control over, these cookies and do not accept any responsibility for such third party cookies. Please refer to the privacy policies posted on the applicable third party website to understand the third party's use of cookies and your options relating to them.

8. Use of Aggregate Information

We may use the information you provide in aggregate (non-personally identifiable) form for internal business purposes, such as generating statistics and developing products and marketing plans. We may collect, store or accumulate certain non-personally identifiable information concerning your use of this Site, such as information regarding which of our pages are most popular. We may share or transfer non-personally identifiable information with or to our affiliates, licensees and partners. See also Section 6.

9. Children under 18

If you are under 18 years of age, you may browse this Site. However, you may not provide personal information to us. For example, you cannot register. This Site is not designed for children and we do not knowingly collect personally identifiable information from any children under 18. If you are under 18 and you have any questions or concerns about this Site, please seek guidance from a parent or a responsible adult.

10. Links

This Estée Lauder HK Site may contain links to or from other websites. Please be aware that we are not responsible for the privacy practices of other websites. This Privacy Policy applies only to the information we collect on this Estée Lauder HK Site. We encourage you to read the privacy policies of other websites you link to or from our Estée Lauder HK Site.

11. Security

We implement various security measures in accordance with industry standards to protect the security of your personal information. Your personal information will be stored at facilities located across the world and not necessarily within Hong Kong. See also Section 6. If you have any questions about security at the Estée Lauder HK Site, you can email us by clicking here.

12. Accuracy and Updating of Your Information

We will take reasonable steps to create an accurate record of any personally identifiable information you have submitted through this Site. However, we do not assume responsibility for confirming the ongoing accuracy of your personally identifiable information.

You are responsible for keeping your information on file with us up to date. You may review and change the personally identifiable information you provide to us at any time by emailing us at: enquiry@hk.esteelauder.com.

13. Choice

You may opt out of receiving future Opt-Out Communications when you register at this Site or at any other time by clicking the "unsubscribe" link at the bottom of each Opt-Out Communication e-mail you receive. Please note that this opt-out only applies to Estée Lauder HK Site Opt-Out Communications and does not apply to communications to serve you (described in Section 2(a) of this Privacy Policy) or to other communications, which may reference Estée Lauder, e.g. from a retail store.

14. Data User

The information you provide will be used and managed by Estée Lauder Hong Kong Limited 33/F, Tower 2, The Gateway, Harbour City, Tsimshatsui, Hong Kong.

15. Notification of Changes

We may revise this Privacy Policy from time to time. If we decide to change our Privacy Policy, we will post the revised policy on this Site. As we may make changes at any time without notifying you, we suggest that you review this Privacy Policy regularly.

16. Comments

We have taken steps to ensure that your visit to our Estée Lauder HK Site is an excellent one and that your privacy is respected. If you have any questions, comments or concerns about our privacy practices, please e-mail us at: enquiry@hk.esteelauder.com.

Copyright © 2007 ESTĒE LAUDER HONG KONG LIMITED. All worldwide rights reserved.