LAST UPDATED AND EFFECTIVE AS OF 25 MARCH 2021.
· About Us
· Our Retail Partners
· Collection of Personal Information
· Use of your Personal Information
· Sharing of Personal Information
· Your Choices
· Advertising and Analytics Services Provided by Others
· Your California Privacy Rights
· California Notice of Financial Incentive
· Contact Us
this Privacy Policy explains how The Roja Beauty Inc. (“The Roja,” “we,” or “us”)collects, uses, and discloses information about you when you access or use[www.TheRojaBeauty.com/us], visit our US stores, call our customer care team or otherwise interact with us in or from the United States. Please note that we provide different or additional privacy notices in connection with certain activities, programs, and offerings. For more information about our privacy practices in another jurisdiction, please refer to the privacy policy posted on our website for that jurisdiction.
If you are a California resident, please see the section below titled “Your California Privacy Rights."
If you have any questions about this Privacy Policy or our information practices, please contact us at legal@TheRojaBeauty.com.
We will update this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.
ABOUT US
This Privacy Policy is provided by The RojaBeauty Inc. We are responsible for The Roja US website (www.TheRojaBeauty.com/us)and any orders placed by customers on this website or in our US The Roja stores.
When you place an order on our website, you are contracting with The Roja Beauty Inc., but we are part of a wider group of The Roja companies across the globe. This includes companies in the UK, Canada, the Netherlands, Germany, France, Spain, Italy, and Hong Kong. When we refer to the “The Roja Group,” we are referring to the wider family of The Roja companies. If you want to know more about The Roja Group, please get in touch with us using the contact details at the end of this Privacy Policy.
OUR RETAIL PARTNERS
You can purchase The Roja products and services via our retail partners across the US, including at select Sephora, Bloomingdales, and Nordstrom stores (our “Retail Partners”). When you purchase TheRoja products or services through a Retail Partner online or in one of their stores, you are contracting directly with that Retail Partner and not with us. Any personal information you provide to the Retail Partner will be managed by the Retail Partner and governed by its privacy policy. If you have questions about how our Retail Partners collect, use, and disclose information, you must contact them directly.
COLLECTION OF PERSONAL INFORMATION
When you use our website, visit our stores, or otherwise interact with us, we collect information from and about you. Some of this information may be considered “personal information,” meaning it identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to you or your household. We also collect, use, and disclose aggregated or de-identified data that cannot reasonably be used to identify you and is not subject to thisPrivacy Policy.
PERSONAL INFORMATION YOU PROVIDE TO US
We collect personal information directly from you in a variety of ways. For example, we collect information when you:
· Register for an online account;
· Request additional information about our products or services or sign up to receive news, information, or special offers from us;
· Interact with us on social media;
· Purchase any product or service from us;
· Book an appointment with a make-up artist;
· Apply to join our Pro Programme;
· Request information or assistance from us, including correspondence with our customer service team;
· Participate in or respond to surveys or requests for opinions, feedback, and preferences or fill out other forms on our website or in our stores;
· Engage with us via our Website, telephone or cell phone, via Livechat or via video chat;
· Engage with us via our marketing communications;
· Engage with us via games you play on our website or via emails we send you;
· Provide reviews of products or post other content in interactive areas of our website; and
· Sign up for and participate in events, contests, sweepstakes, or promotions. The types of personal information we collect directly from you include your name, email address, phone number, mailing address, date of birth, credit card number or other payment information, password, personal preferences, age, gender, skin tone, hair color, eye color, facial image, video and audio recordings and any other information you choose to provide.
AUTOMATICALLY COLLECTED PERSONAL INFORMATION
We automatically collect personal information when you access and use our website or transact business with us in our stores, including:
· Log and Usage Information: We collect information about the device you use to access our website and your use of our website, including the type of browser you use, operating system, IP address, unique device identifiers, access times, pages viewed, links clicked, items placed in your cart, browsing behavior and the referring URL (the webpage you visited before navigating to our website);
· Transactional Information: When you make a purchase or return, we collect information about the transaction, such as product details, purchase price, and date and location of the transaction.
· Information Collected by Cookies and SimilarTracking Technologies: We (and our service providers) use different technologies to collect personal information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our website, services, and your experience, see which areas and features of our website are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that may be used in our website or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see Cookies below.
PERSONAL INFORMATION WE COLLECT FROM THIRD PARTIES
We may collect personal information about you from other sources. For example, we may collect personal information about you from:
· Other customers, such as when a friend purchases a gift card for you and provides your email address so we can deliver the gift card electronically;
· Our Retail Partners, trade show organizers, and other organizations we partner with to organize contests and events or otherwise promote our products and services;
· Social media or messaging services, such as Facebook, Twitter, and WhatsApp, depending on your account settings with those third-party platforms and services; and
· Publicly available sources.
PERSONAL INFORMATION WE DERIVE
We may derive personal information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address, or that you are interested in a particular product based on your browsing behavior on our website.
USE OF YOUR PERSONAL INFORMATION
We collect and use personal information to provide, maintain and improve our products and services and to:
· Facilitate and improve your in-store and online shopping experience
· Complete the transactions you request, perform our contractual obligations, and send you related information, including confirmations and receipts;
· Create and manage your online account and provide technical support (including to debug and troubleshoot) and send you technical notices, updates, security alerts, and support and administrative messages;
· Send promotional messages and newsletters(for information about how to manage promotional communications, please see marketing Communications below);
· Respond to your questions and comments and provide customer support;
· Allow you to complete surveys or comment on or review our products or services;
· Organize and provide events, sweepstakes, contests, and promotions;
· Conduct internal research and development;
· Engage with you via LiveChat or VideoChat or via our Website;
· Provide advertising and marketing targeted toward your interests;
· Provide you information about and remind you about the products and services you have looked on our Website;
· Analyze traffic and user activities on our website, identify popular areas or features of our website, and optimize and personalize website content;
· Protect the rights and property of the TheRoja Group and others and comply with our legal obligations, including to detect, investigating, and preventing fraud and other illegal activities and to enforce our agreements; and
· Carry out any other purpose described to you at the time the personal information was collected.
SHARING OF PERSONAL INFORMATION
We may share personal information about you as follows or otherwise described in this Privacy Policy:
· With other companies within The RojaGroup to enable us to run data analysis, develop new products and services, and for other business development purposes. We may also share personal information to allow another The Roja Group company to perform services on our behalf.
· With our vendors and service providers, who are trusted third parties we hire or work with, to allow us to provide our products and services to you. These service providers need access to your personal information in order to perform services on our behalfs, such as Webhosting, payment processing, email distribution, marketing and advertising, customer support, information technology, and analytics services.
· With our partners, such as organizations with whom we organize contests or events, our Retail Partners, or trade show, organizers.
· With other website visitors when you choose to participate in certain interactive areas of our website, such as by posting a product review.
· In connection with a corporate transaction, such as any purchase, sale, lease, merger, or another type of acquisition, disposal, or financing involving The Roja Group.
· With our professional advisors, such as our legal, financial, insurance, and other advisors in connection with the corporate transactions described above or the management of our business and operations.
· With law enforcement and individuals involved in legal proceedings, when it’s necessary for us to comply with applicable law or legal process, to respond to legal claims, or to protect the rights, property, or personal safety of The Roja Group, our users, employees, or the public.
· With your consent or at your direction.
YOUR CHOICES
You have options in relation to the personal information we collect about you, as described below.
MARKETING COMMUNICATIONS
We love keeping you up-to-date about our latest products, services, offers, and events, but if you decide that you don’t want to receive these communications at any point, you can unsubscribe by following the unsubscribe instructions in those communications or by emailing us at customercare@TheRojaBeauty.com. You may also opt out of receiving our text messages by texting STOP to our SMS number. To unsubscribe to our marketing emails, you can also visit the account information page on The Roja website, click on “Newsletters,” and unsubscribe from that page. If you opt out of marketing emails, please note that we may still send you non-promotional emails, such as those about your account or our ongoing business relationship.
COOKIES
For detailed information about the cookies we use and the purposes for which we use them, see our Cookie Policy. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.
ADVERTISING AND ANALYTICS SERVICES PROVIDED BY OTHERS
We may allow others to provide analytics services and serve advertisements on our behalf across the web. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our website and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by The Roja and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our website and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing activity used for behavioral advertising purposes, please visit our Cookie Policy and the Cookie management tool. We may also work with third parties to serve ads to you as part of a customized campaign on third-party platforms (such as Facebook, Snapchat, or Instagram). As part of these ad campaigns, we or third-party platforms may convert information about you, such as your email address and phone number, into a unique value that can be matched with a user account on this platform to allow us to learn about your interests and to serve you advertising that is customized to your interests. Note that the third-party platforms may offer you choices about whether you see these types of customized ads.
YOUR CALIFORNIA PRIVACY RIGHTS
Consumers residing in California are afforded certain additional rights with respect to their personal information under the California Consumer Privacy Act (“CCPA”). If you are a California resident, this section applies to you.
In the preceding 12 months, we have collected the following categories of personal information: identifiers, characteristics of protected classifications under California or U.S. law, commercial information, internet and electronic network activity, audio and visual information, biometric information, inferences drawn about you, and other categories of personal information that relates to or are reasonably capable of being associated with you. For details about the precise data points we collect and the sources of collection, please see sections titled “Collection of Personal Information” and “Personal Information We Collect from Third Parties” above. We collect personal information for the business and commercials purposes described in the “Use of Your Personal Information” section above.
In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:
Category of Personal Information
Categories of Recipients
Identifiers Internet service providers, data analytics providers, operating systems and platforms, social networks, customer service partners, fraud prevention partners, marketing partners, advertising partners, retail partners, payment processors, cloud service providers, other users (if you choose to share certain information, such as product reviews, publicly on our website), other companies within the The Roja Group, and our professional and legal advisors Characteristics of protected classifications under California or U.S. law Other companies within the The Roja Group, operating systems and platforms Commercial information Internet service providers, data analytics providers, government entities, operating systems and platforms, customer service partners, fraud prevention partners, marketing partners, payment processors, cloud service providers, other users (if you choose to share certain information, such as product reviews, publicly on our website), other companies within the The Roja Group, and our professional and legal advisors Internet and electronic network activity Internet service providers, data analytics providers, operating systems and platforms, fraud prevention partners, marketing partners, advertising partners, cloud service providers, other companies within the The Roja Group, and our professional and legal advisors Audio and visual information operating systems and platforms, social networks, customer service partners, fraud prevention partners, marketing partners, other users (if you choose to share certain information, such as product reviews, publicly on our website), other companies within the The Roja Group, and our professional and legal advisors Biometric information other companies within the The Roja Group. Inferences are drawn about your Data analytics providers, operating systems and platforms, social networks, customer service partners, marketing partners, advertising partners, other companies within The Roja Group, and our professional and legal advisors
California law requires that we provide transparency about the personal information we “sell,” which for purposes of the CCPA broadly means scenarios in which we have shared personal information with third parties in exchange for valuable consideration. We “sell” personal information for the commercial purposes of advertising and marketing our products to you across other websites and via social networks and platforms. In the preceding 12 months, we have “sold” the following categories of personal information to the following categories of third parties:
Category of Personal Information
Category of Third Parties
Identifiers Advertising networks, social networks, and marketing partners. Internet or other electronic network activity information Advertising networks, social networks, and marketing partners.
You have the right to opt out of these sales at any time by visiting our “Do NotSell My Personal Information ” webpage or calling us at +1-855-528-8495. We do not knowingly sell personal information about consumers under the age of 16.
In addition to the right to opt out of “sales” explained above subject to certain limitations, the CCPA provides California consumers the right to (1) request to know more details about the categories and specific pieces of personal information we collect, use, disclose and sell (2) request deletion of their personal information, and (3) not be discriminated against for exercising their rights. If you are a California resident, you may make these requests by calling+1-855-528-8495 or visiting this page. Once we receive your request, we will verify it by asking you to verify your contact information and may ask you for information related to your recent interactions with us, such as information about a recent purchase. Authorized agents may submit requests on behalf of consumers by contacting us at legal@TheRojaBeauty.com. If you use an authorized agent registered with the California Secretary of State to exercise your rights, we may ask you to verify your identity with us directly or confirm with us that the agent otherwise has your permission to submit the request on your behalf. We will not discriminate against you if you choose to exercise your rights under the CCPA.
CALIFORNIA NOTICE OF FINANCIAL INCENTIVE:
We make available various offers and financial incentives to our customers. For example, we provide discounts, special offers, and other benefits to individuals who participate in our loyalty programs and we may offer you a discount if you sign up to receive our email newsletters. When you participate in the financial incentives we offer, we collect personal information from you, such as identifiers like your name and email address, and commercial information like your purchasing habits. In some cases, additional terms may govern a financial incentive, which we will specify when you sign up. You can opt into the financial incentive or price or service difference by following the instructions provided at sign-up, including submitting the relevant personal information. If you do not wish to opt-in to the financial incentive or price or service difference, do not sign up or submit the requested personal information.
If you subsequently wish to withdraw from the financial incentive or price or service difference, the method for doing so will be explained at the time the personal information is to be submitted, or you may request such withdrawal by contacting us at customercare@TheRojaBeauty.com.
Each financial incentive or price or service difference offered is valued based upon our reasonable determination of the estimated value of such personal information submitted, which takes into consideration, without limitation, estimates in respect of the anticipated revenue generated from such information, the anticipated expenses that may be incurred in the collection, storage, and use of such information in the operation of our business, and other relevant factors related to the estimated value of such information to our business, as permitted under the CCPA. The value of your personal information is reasonably related to the value of the discount or benefit presented to you.
CONTACT US
If you have questions regarding this privacy policy, you can contact us at legal@TheRojaBeauty.com.