Privacy Policy

​UNIVERSELLE BULY​ pays particular attention to the processing, confidentiality and safety of your personal data.

This aim of this privacy policy is to inform you in a clear, simple and complete information about how we process the personal data you give us, or that we may collect through the various contacts you may have with us (e.g. shop, customer relations, website, social networks, digital applications, events), their possible transfer to third parties, as well as your rights and the options you have to control your personal information and protect your privacy, in compliance with the regulations in applicable.

OFFICINNE UNIVERSELLE BULY​, a Parfumerie Amicale company with headquarters located at 6 rue Bonaparte – 75006 Paris, registered in the Paris trade and companies register under no. 00042 and register under no. 79474115700042 (OFFICINNE UNIVERSELLE BULY​) is the data controllers of personal data collected on the website Officine Universelle Buly (buly1803.com)http://www.makeupforever.fr/, in shops and counters in the sense of regulations applying to personal data, in particular European Union (hereinafter "EU") Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and the free movement of such data (hereinafter the "GDPR").

I. What is personal data?

Personal data is any information about an identified physical person or a physical person that may be directly or indirectly identified via an identification number or one or more elements particular to them, such as their last name, first name, date of birth, customer number, order number, photo, etc.

II. When can we collect your personal data?

We can collect your personal data when you:

Create a customer account on our website, apps, or in our stores.

Order goods from our website.

Make purchases in stores.

Agree to receive personalized marketing communications from us by email, telephone, SMS or post, depending on your selection.

Answer surveys or satisfaction questionnaires based on your customer experience.

Interact with our Maison via its official page on social networks or when we suggest re-use of content that you have published on a social network.

Contact our customer service.

Send requests for information to our Maison.

Take part in an event we organize.

Browse on the Internet using cookies or similar technology or when you click on advertisements for our products.

Visitors to the Officine Universelle Buly (buly1803.com) website who browse our products, information and offers may choose to do so without identifying themselves, as well as for point-of-sale searches and social networking.

III. What personal data might we collect?

As part of the services we provide, we may need to collect certain data directly from you using electronic forms on our website, mobile apps or in selected stores, or in paper form, for a range of purposes (see IV for a list of processing purposes) which are limited to those that are relevant and appropriate for that interaction.

Information we might collect includes:

Your identity.

Your contact details (e.g. email address);

Your personal preferences in relation to the products we market or to our website (language);

Information relating to your orders, their tracking and your purchase invoices.

Information you may provide for our customer service.

Specific health data if you notify us of any undesirable side-effects concerning any of our products.

Your bank details if you place an order via our website.

Personal data essential to ​ UNIVERSELLE BULY​ is marked with an asterisk on all personal data collection forms on our website, in electronic form at some of our counters and stores, as well as off-line in paper form. If you do not fill in these compulsory fields, ​ UNIVERSELLE BULY​ will probably be unable to respond to your request and/or provide you with the requested services. Other information is optional and enables us to get to know you better and improve our communications and services with respect to you.

During your purchase journey, you will be able to choose between i) logging into your existing ​ UNIVERSELLE BULY​ account, ii) creating a new account, or iii) paying as a Guest. This last purchasing experience is thus summarized as follows. Payment for purchases as a Guest refers to the possibility for any ​ UNIVERSELLE BULY​ customer or prospect to make a purchase in our online store without logging into an account. Your information is collected for the process of payment and delivery of items or for ​ UNIVERSELLE BULY​ in order to comply with applicable laws. Your information may also be used for analytical purposes by ​ UNIVERSELLE BULY​ and for communication purposes via its preferred channel (for example: sending a general newsletter relating to the news of our Maison by email for which you have the right to object). For more information on these purposes, please go to the section "For what purpose is your personal data collected and used?".

We may also collect certain data generated by your purchases of products or services, online or in stores, particularly information regarding the amount and type of your purchases.

Lastly, we may collect information regarding the use of our website, especially with respect to your browsing (pages visited, links clicked, etc.). Some of this information may be collected using cookies placed in your web browser when you browse our website. For more information about cookies, read our cookie policy, here.

If you apply for a job with our Company via our website, we may collect the following information:

Your identity.

Your contact details.

Your Curriculum Vitae.

Your application letters.

As this data concerns your application, please inform us in writing of any changes to your contact details or, more generally, to your career and employment situation, to help us to manage your application efficiently.

We invite you to ensure that your data is regularly updated, either by modifying it directly on our sites or by informing us in writing of any modification by referring to the dedicated section " X. What are your rights and how can you exercise them? ".

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

​UNIVERSELLE BULY​ processes your data to:

Enable you to create a customer account on our website, applications and at our counters and in our stores.

Manage your access to your customer account on the Internet or our applications.

Process and manage your online orders and their delivery.

Record purchases made at our counters or in our stores.

Secure online transactions, prevent fraud, payment incidents and manage debt collection (see our terms and conditions for more details);

Trace and manage any alerts you may send us as part of our cosmetic vigilance obligations.

Manage and optimize your customer experience by improving our knowledge of our customers.

Propose appropriate, tailored services, particularly when we enhance our products and services.

Conduct statistical analyses to develop management, measuring and reporting tools in order to adjust and improve our sales, marketing and product manufacturing.

manage any online job applications ;

Carry out audience analysis or statistics.

Manage your participation in the events for which you register.

Send a generic newsletter: you have the right to object if you no longer wish to receive it.

Subject to your free, specific, informed and unambiguous consent: to send you personalised information according to the communication preferences you have indicated to us and your profile (link to the channel preference manager if you have a customer account, otherwise you have the possibility to contact us, see section "XI. What are your rights and how to exercise them") and use third party services to personalise your profile.

In the latter two interactions ('providing you with a personalised customer experience' & 'analysing your preferences and habits'), when we send personalised communications or content, we may use so-called profiling techniques. For the sake of transparency within this Policy, profiling is defined as any form of automated processing of personal data that consists of using that personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict elements concerning the preferences, interests, behaviour, location of that natural person. In these circumstances, you have the right to withdraw your consent.

V. What legal grounds legitimise the processing of your data?

​​ UNIVERSELLE BULY​ processes your personal information:

To perform the contract agreed between yourself and ​ UNIVERSELLE BULY​, to manage your access to your customer account, your subscription to the loyalty program, and to process and track your orders.

Our legitimate interest: for example, to improve our products and services, to defend ourselves, to secure our tools or to refine our customer knowledge through our third-party partners' tools and in particular to:

to define the personalized profile of our customers based on their interests and to provide them with relevant offers of our brand on other websites.

identify audiences similar to our target audience (in order to deliver our offers to audiences of people with similar profiles to our customers).

When you have given your consent for the processing of your data, especially for the purposes of managing our personalized sales prospection, and of your browsing data via cookies, etc.

Within the framework of compliance with our legal obligations, particularly fiscal obligations (conserving purchase invoices) and cosmetic vigilance with regard to Regulation (EU) 1223/2009 of 30 November 2009 on cosmetic products.

VI. Who are the recipients of your personal data?

Your personal data is processed by the personnel of ​ UNIVERSELLE BULY​. We ensure that only authorized persons within ​ UNIVERSELLE BULY​ have access to your personal data when this is necessary for the purpose of managing our commercial relations or meeting our legal obligations.

We may also disclose your personal data, if possible, in a format that does not allow direct identification, to:

Others ​ UNIVERSELLE BULY​ entities and department shops where you buy our products in order to provide you with the same personal service all over the world.

Other ​ UNIVERSELLE BULY​ subsidiaries in Europe or abroad, as well as with our parent company ​ UNIVERSELLE BULY​;

Other entities of the LVMH Group, with some of these entities acting as data processors.

Subcontractors, such as:

site hosting and maintenance service providers and the providers of our electronic personal data collection solutions at counters and in stores.

payment service providers.

anti-fraud service providers.

logistic service providers.

marketing solution service providers.

customer service providers.

service providers for managing cosmetic vigilance alerts.

event organization service providers.

Third parties, including the LVMH Group, who wish to learn about your preferences and patterns of use of our programs and services in order to improve their visibility, accessibility and performance.

Third parties who carry out statistics relating to our performance on social networks on our behalf.

Third parties wishing to know your interests so that they can build up similar audiences and target prospects corresponding to your profile. In the context of this specific processing, these partners may re-use the personal data made available to them to carry out autonomous and distinct targeting for commercial prospecting purposes, for which they are responsible, and are responsible for their legal and regulatory obligations.

Please note that in the context of re-use, these partners act as data controllers. You should therefore refer to their own privacy policies. We illustrate some examples in the table below:

Facebook (Privacy Policy available here)

Google (Privacy policy available here)

Instagram (Privacy policy available here)

Third parties in the event of a change of control or a change of status or company name for legal reasons.

You may also choose to disclose your personal data to our partners, advertisers and affiliates by following a link to and from their websites. Please note that these websites have their own privacy policies.

Lastly,​ UNIVERSELLE BULY​ may need to share your personal data with third parties to meet its legal, regulatory or treaty obligations, or to respond to requests from authorised legal authorities.

With your consent, data regarding your job application may be shared with other companies of the [​ UNIVERSELLE BULY​] Group and of the LVMH Group worldwide, for recruitment purposes.

VII. How do we ensure the protection and confidentiality of your data?

The security measures we have in place are evaluated and updated to meet new threats and challenges, as well as new legal requirements in the countries where we operate.

We require our partners and group companies to maintain a similar level of protection for your personal data as we do. We take reasonable precautions to ensure the confidentiality and security of your data. We prevent your data from being distorted, damaged, destroyed or accessed by unauthorized third parties.

Your bank details are not transmitted unencrypted on the servers of ​ UNIVERSELLE BULY​. Payments are made via a secure payment platform, supplemented by control measures, in order to guarantee the security of purchases made on UNIVERSELLE BULY and to fight against fraud.

The details of your payment card communicated at the time of your order are never accessible in clear text on the network: they are encrypted using the SSL (Secure Socket Layer) protocol.

In addition, the security measures we have adopted are proportionate to the sensitivity of the particular data collected. For example, any photos or images linked to the Virtual Try-On tool, when visible to us during a session, are more sensitive than ordinary browsing data and are subject to stricter security measures.

Data transfers abroad

Because ​ UNIVERSELLE BULY​ operates in many countries around the world and in order to provide you with a personalised service worldwide, some of your data may be collected, accessed or stored outside your country of residence.

You should be aware that data protection and security requirements differ from place to place and may not provide the same level of protection as in your home country.

You are informed that your data may be transferred for the purposes mentioned above to companies located in countries outside the European Union which have a lower level of data protection than the European Union. Prior to the transfer outside the European Union, ​ UNIVERSELLE BULY​ will take all necessary measures and guarantees to secure such transfers.

Before transferring data between different countries, we take into account the risks that this operation could create for the data; where appropriate, we rely on the mechanisms in place, such as the Data Privacy Framework in the United States or standard contractual clauses, to ensure that your rights relating to your data are protected. Where data is shared with third parties, we require them to guarantee the same protection for your data as we do.

Data may also be processed by staff operating outside the EEA who work for us or for one of our service providers.

VIII. How long do we keep your data?

The legal retention periods defined by ​ UNIVERSELLE BULY​ comply with the recommendations of the Personal Data Authority of your country and/or the legal obligations to which ​ UNIVERSELLE BULY​ is subject.

We keep your personal data only for as long as is necessary to fulfil the purpose for which it was collected, to meet your needs, or to comply with our legal obligations.

In general, your personal data is kept in our database:

Data subject: Regular customer (i.e.: having a customer profile)

Duration: 5 years from the date of the first purchase or account creation

Specificity: This period will be renewed each time you interact with ​ UNIVERSELLE BULY​ (for example a purchase or an update of your profile) or your consent to continue to interact at the end of this period

Data subject: Prospect (i.e. never purchased products from ​ UNIVERSELLE BULY​ but registered for our communications)

Duration: 3 years from the date of data collection

Specificity: This period will be renewed each time you interact with ​ UNIVERSELLE BULY​ (e.g. participation in an event) or your consent to continue to interact at the end of this period

Data subject: Client ‘Guest’ (i.e. not having a client account)

Duration: 5 years from the date of first purchase

Specificity: This period will be renewed each time you interact with ​ UNIVERSELLE BULY​ (e.g. a purchase)

Data subject: customer care (i.e.: complaints or information)

Duration: duration of the processing of the request plus 5 years. For exercises of rights, under GDPR, the request is kept during its treatment plus 6 years.

Data subject: cosmetovigilance

Duration: duration of the processing of the request plus 5 more years

Specificity: These data are sensitive; they are stored with adequate security measures.

Data subject: Privileged interlocutors (e.g. agents, stylists, journalist, celebrity managers, artists) in relation to Maison ​ UNIVERSELLE BULY​ Public Relations services

Duration: 10 years from the date of your first contact

Specificity: This period will be renewed each time you interact with ​ UNIVERSELLE BULY​ (for example a request for information on the ​ UNIVERSELLE BULY​)

If cookies are placed on your computer, we keep them for a maximum of 6 months.

As stated above, when you choose to use our Virtual Try-On tool, no photos or images are retained or stored beyond the conclusion of the session.

When we no longer need to use your personal data, it is deleted from our systems and our registers or made anonymous so that it can no longer be identified, subject to retention for archival purposes. claims and litigation management as well as to meet our legal and / or regulatory obligations and / or to respond to requests from authorities authorized to make the request.

IX. What are your rights and how can you exercise them?

​​UNIVERSELLE BULY​ has adopted the data protection and security practices described in this privacy policy for all individuals concerned. In addition, we have also identified and taken in to account the data protection and security measures required at local or regional level. This includes, for example, those required for residents of the European Union / European Economic Area under the General EU Data Protection Regulation (GDPR) 2016/679.

In particular, the GDPR provides the following rights:

• Right to information: you have the right to obtain clear, transparent, and understandable information about how we use your personal data and about your rights. You will find all of this information in this Privacy policy.

• Right of access: you have the right to access the personal data that ​ UNIVERSELLE BULY​ holds about you

• Right of rectification: you have the right to have your personal data rectified if it is inaccurate or obsolete and / or to supplement it if it is incomplete

• Right to erasure / right to be forgotten you have the right to have your data erased or deleted. However, this right may be limited by a legal reason or our legitimate interest in keeping your personal data.

• Right of opposition: you can at any time request to no longer receive our communications relating to our offers, news and events. You can in particular use the hypertext link provided for this purpose in each email or communication that we send to you. You can also request to receive non-personalized communications about our products and services.

• Right to withdraw consent at any time for data processing based on consent: you can withdraw your consent relating to our processing of your data when this processing is based on consent

• Right to data portability: you have the right to move, copy or transfer data from our database to another. This right only applies to the data you have provided, and provided that the processing is based on a contract or your consent and carried out using automated processes.

Please contact us at the contact details below to exercise these rights or if you have any questions or complaints regarding the processing of your personal data.

These rights can be exercised directly with ​ UNIVERSELLE BULY​ by e-mail to dataprivacy@buly1803.com or by post to 6 rue Bonaparte – 75006 Paris.

You also have the right to contact the data protection authority of your country in order to lodge a complaint against the data protection and privacy practices of UNIVERSELLE BULY. We also wish to inform you about the contacts of other authorities in Europe that you can find and contact on the website of the European Data Protection Board: https://edpb.europa.eu/about-edpb/board/members_fr.  

We may require proof of your identity and full details of your request before we process it.

XI. Contact details of the Data Protection Officer (DPO)

For all questions relating to the collection and processing of your data by ​ UNIVERSELLE BULY​ you can contact the ​ UNIVERSELLE BULY​ Data Protection Officer at privacy@buly1803.com.

Last update : 29/04/2024