Updated: January 1, 2020
The Company currently does not request or require you to provide any personal information to use the Website. It will, however, collect the personal information you voluntarily provide via the Website; such as: when you voluntarily provide personal information via its Website link “Sign up to our Newsletter” located on the home page in order to obtain marketing and sales information, or when you voluntarily provide personal information via its Website link “Contact Us” page when requesting any information about its products or providing feedback about its Website. More specifically, the personal data we collect with respect to information you voluntarily provided includes the below items, and is considered “Personal Data”.
We collect your:
The Company may also automatically collect general anonymous information related to your use of its Website, such as the date and time you visit the Website and the pages you visit on the Website. In addition, the Company may collect “cookie” information from your browser to identify your computer and provide you with a more personal experience (Collectively, the foregoing is referred to as “Usage Data”).
Cookies provide features, as well as functionality. They can be used to recognize you when you visit our Website, remember your preferences, and give you a personalized experience that’s in line with the Usage Data collected. The technology used to gather “cookie” information is also provided by the Internet browser you use and is stored on your browser. The following cookies are collected:
The Company uses Usage Data and feedback information (feedback information is defined as any information and data voluntarily provided to the Company by users via its Website “contact us” page) for the purposes of monitoring and improving the use and features of the Website. It will use your contact information (i.e. first name, last name, country, e-mail, phone) to provide you with the information you have requested via its Website link “Sign up to our Newsletter” located on the home page, as well as any information about its product which you have submitted via its Website “Contact Us” page.)
The Company will not transfer, sell or otherwise disclose any of your Personal Data to any third party without your prior written consent, unless such disclosure is required to satisfy any Legal requirements, law enforcement requirements, court demands, requests from regulators, government obligations/requests, or to protect the rights or property of the Company and its users, sponsors, providers, licensors, or merchants, as applicable.
We will also retain your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
By browsing this Website, you will be able to access links and references to other websites. Those links and references are provided to you are for convenience purposes only. The Company does not warrant that the information and/or material contained in those links, or the accessibility thereof, is accurate and exhaustive. The Company assumes no responsibility whatsoever for any such outside websites, or for the information or material posted thereon, nor does it assume any responsibility for products or services offered thereon. Unless the Company has expressly authorized you to do so in writing, you may not create links from other websites to this Website.
You have the right to access, to rectify, to restrict and, where applicable and subject to personal data we are required to retain to meet our compliance obligations, to delete your personal data. You also have the right to data portability. You may be entitled, on legitimate grounds and subject to us meeting our compliance obligations, to object to the processing of any personal data relating to you. Furthermore, you hold the right to lodge a complaint with the local data protection authority.
You can exercise these rights, with a proof of your identity, by simple written request sent by email to firstname.lastname@example.org.
You can exercise these rights, with proof of your identity, by a written request sent by email to email@example.com.
Or by mail at the following address:
Joseph Ribkoff Inc. Attn: Marketing Department
2375 De L’Aviation
Dorval, Quebec, Canada
If your request is not sufficiently precise or does not include all elements enabling us to answer your request, the Company may ask you to provide additional information.
If you are located in the European Economic Area (EEA), please see your rights in relation to personal information below.
Joseph Ribkoff will maintain your personal information in secure data storage to safeguard it from unauthorized access.
The Company uses, processes, and stores Personal Data, including the data listed in the “COLLECTION OF PERSONAL INFORMATION” section above based on our legitimate interests for the purposes of monitoring and improving the use and features of the Website, and provide you with the information you have requested or have signed up for. We rely on your consent to process Personal Data to send promotional emails and to place cookies on your devices as defined in the “COLLECTION OF PERSONAL INFORMATION” section noted above. In some cases, the Company may process Personal Data pursuant to legal obligation.
If you’re accessing the Company’s Website from the EU, your Personal Data is governed by the General Data Protection Regulation, or “GDPR”. On May 25, 2018, the GDPR replaced the Data Protection Law (which was in effect since 1999). The GDPR was developed by the European Parliament and Council to protect data rights of EU citizens. Any company that does business transactions with EU citizens or collects or processes data of EU citizens must comply with this legislation.
Why is it important? GDPR has been put in place to make people more informed and put them in control of how businesses collect, use, share, secure and process their Personal Data. The legislation’s main aim is to make privacy policies clear and comprehensive to customers.
The GDPR requires disclosure of the below elements, and beside each element, we have provided you with the relevant answer.
JOSEPH RIBKOFF INC., 2375 de l'Aviation, Dorval, Quebec, Canada, H9P 2X6, (514) 685-9191, 1(800) 361-1839, firstname.lastname@example.org
The Company processes Personal Data based on your consent, which you are free to give or refuse. A consent option will be available when visiting our Website for the first time.
In order to communicate clearly and directly with you, we need this data, as well, to customise your experience while visiting our Website. For example, one of the pieces of information we save is your language preference, to ensure we provide the Website pages in the language of your choice.
We collect the information identified above as “Personal Data”, as well as “Usage Data”.
We usually keep their information in 2 ways: Firstly, cookie information has a set lifespan, ranging from 2 weeks to 1 year. Secondly, information you provide to us such as when you complete our newsletter signup is kept indefinitely; that is we will continue to send you the newsletter until you opt-out or unsubscribe (every email newsletter we send contains an unsubscribe link).
We do not directly transfer your data internationally, but the third-party data processors we use, such as Facebook and Google, have servers all around the world.
Currently we share data with:
Google: advertisements, analytics and retargeting.
Facebook: advertisements, analytics and retargeting.
MailChimp: e-mail marketing and retargeting.
GDPR also requires us to tell our users about their rights, which are:
A- The right to be informed: You have the right to request information about the Personal Data we hold about you at any time.
B- The right of access: Request a Personal Data report by submitting a request through email@example.com. This report will include the Personal Data we have about you.
C- The right to rectification & to erasure: Upon obtaining the Personal Data we have about you, you can have the data corrected, or where applicable and subject to the Personal Data we are required to retain to meet our compliance obligations, deleted, by submitting a request through firstname.lastname@example.org.
D- The right to restrict processing: You can, subject to our requirements to meet our compliance obligations, ask us to stop using your Personal Data, including when we use your Personal Data to send you marketing and sales emails. We only send marketing and sales communications to users located in the EEA with your prior consent, and you may withdraw your consent at any time by clicking the “unsubscribe” link found within a marketing Joseph Ribkoff email you may receive.
E- The right to data portability: Whenever the Company processes your Personal Data by automated means based on your consent, you have the right to get a copy of your data transferred to you. This only includes the personal data you have submitted to us.
G- The right to update your personal data: You have the right to update incomplete or incorrect personal data about you.
Is information collected from children?
Children under 13 should not use this site, as we do not market to children. We do not collect Personal Data online from children under the age of 13.
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
|A. Identifiers.||A real name, Internet Protocol address, email address, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES **We collect your name and phone number but only with your explicit permission and with a check box opt-in to record your choice.|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||NO|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.||YES ** We collect information on your interaction with a website, application, or advertisement, but we don’t have access to your browsing and search history.|
|G. Geolocation data.||Physical location or movements.||NO|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||NO|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO ** We collect language preference.|
Personal information does not include:
We obtain the categories of personal information listed above from the following categories of sources:
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, Company has not disclosed personal information for a business purpose.
In the preceding twelve (12) months, the Company had not sold personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following our webpage and sending us a message.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in at any time by visiting our Website and sending us a message. We will only use personal information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you a notice on our Website.
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Phone: (514) 685-9191, 1(800) 361-1839
JOSEPH RIBKOFF INC., 2375 de l'Aviation, Dorval, Quebec, Canada, H9P 2X6,
Attn: VP Marketing or Legal Affairs