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1. Introduction

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Rituals Cosmetics Enterprise B.V. (Keizersgracht 683, 1017 DW Amsterdam, The Netherlands) and our affiliated companies (hereinafter: “Rituals”, “we”, “our”, or “us”) is committed to the proper handling of personal data, in accordance with applicable privacy laws (including where relevant the General Data Protection Regulation).

To ensure your privacy as far as possible, we adhere to the following core values:

Information: We inform you about why and how we collect and use your personal data. This is described in this Privacy Policy.

Limited collection: We aim to limit the information we collect and use to only that which is necessary for selling our Products and/or providing our Services (as defined below).

Security: We take the appropriate technical and organizational measures designed to secure your personal data and require the same from the parties that process your data on our behalf.

Individuals’ rights: We respect your rights under applicable privacy laws.

In this Privacy Policy (“Privacy Policy”) we describe how we (i) implement these core values to protect your privacy, (ii) how we collect, use, disclose and otherwise process your personal data, and (iii) about the rights and choices you have regarding such personal data. We strongly urge you to read this statement carefully, as it applies to our processing of personal data about customer and prospective customers, including purchasers of  our products (“Products”), whether online or in one of our stores or via other Rituals’ points of sale, loyalty program members, visitors to our stores, and users who visit and access our websites, apps, or otherwise interact with us or use our services and applications (collectively referred to as: the “Services”).

Our use of the term “personal data” includes “personal information” and other similar terms as defined under applicable privacy laws. 

California residents.  If you are a California resident, please be sure to review Section 13 “Information for California Residents” below for important information, as required by California privacy laws, about the categories of personal information we collect, use and disclose and your rights under California privacy laws.  

2. Personal Data We Collect And Use

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We collect personal data about you directly (such as when you buy our Products or provide information to us on and offline), automatically (such as when you access our website or use our services), and, in some cases, from third parties (such as social networks when you interact with us or discuss us on social media). 

In general, the personal data we collect about you include the following personal data:

• Your contact details. Your name, postal address and other contact details, such as your telephone number and e-mail address, and any other contact details you provide to us (including delivery address when you purchase our Products online).

Your electronic identification data, including personal data, and other information we collect automatically when you visit, use, and interact with our online website, apps and services (“Services”). For example, we collect data automatically including through cookies, IP address, app identifier, advertising ID, location information, browser type, device type, domain name, the website that led you to our website, the website to which you go after leaving our website, the dates and times you access our websites and online services, and the links you click and your other activities. We also may use pixels in HTML emails to understand if you read the emails we send to you, your interaction with the site and content (e.g. opening, clicking, reading, cursor-movement etc.), your interaction with our newsletter or with being confronted with online marketing advertisements of Rituals. We collect data automatically through your browser or device, by making use of cookies and other technologies to track visitors on the website (including web analytics), such as your IP address, MAC address, your browsing behavior, the Products and Services you like and the content of your abandoned shopping basket. You can review our Cookie Policy to find out more or click the Privacy Settings link to adjust your cookie preferences for our website (Please note that our websites do not recognize or respond to any signal which your browser might transmit through the so-called “Do Not Track” feature)… 

• Your account data. To complete your account at Rituals (“MyRituals”) online or instore via the onboarding application, we use your name, gender, email address, date of birth and other information you voluntarily provide to us, such as your phone number, favorite Rituals collection, additional interests and favorite categories or personal product advice (such as but not limited to soul wear, skincare, make up and haircare).

• Your purchases in our stores. Only when you are a MyRituals member, we can link data from your purchases in our stores to your MyRituals profile based on the verification of your personal data at the counter that you provide (e.g., your MyRituals member card (number), email address and/or mobile telephone number), such as the amount and date of your purchases, the Product(s) or Service(s) you purchase, the location of the store, payment statuses, employee discount (if any), voucher code used (if any), gift with purchases (if applicable) and optional additional personal card or engraving data.

• Your purchases online. To complete your online purchases via the official Rituals web shop or via other official social media-channels of Rituals, we use your name, gender, telephone number if you voluntarily provide this to us), delivery method and delivery address and all relevant information regarding your purchases, such as the amount and date of your purchases, the Product(s) or Service you purchase, the device through which you make your purchases, payment method, payment status, bank account details, (employee) discount, voucher code used (if any), gift with purchases (if applicable) and optional additional personal card or engraving data, delivery method and delivery address. In order to offer you third party partner payment methods, we might pass your personal data in the form of contact and order details to said third parties in the checkout process, in order for them to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data transferred is processed in line with the third party’s privacy notice. Please see this page for our payment partners.

• Your personal data when using our Rituals Perfume Diffuser device and app. If you make use of our Rituals Perfume Diffuser App we record your name and email address. In order to be able to use the device in combination with the App, information in relation to the device is automatically collected, such as Wi-Fi strength, battery percentage, cartridge fill, scent, installed version, fan-information, online/offline status. We also collect and use other personal data you voluntarily provide to us, such as room size, and room name.

• The personal data you share with us during the personalization-process when you buy a personalized Rituals product. If you personalize Rituals Products via us, we use your personalized data (e.g. the name you would like to be placed on the Rituals Products) in order to be able to handle your request and provide you our Services. Where available, Rituals may also offer the option to personalize your Rituals Online Gift Card via the Rituals website, (such as, but not limited to, personalization by means of uploading and usage of a picture, video, GIF or other file (hereinafter: ‘Image Material’). Rituals works together with third parties to provide you with such service, which third parties work on our behalf, as further explained in this Rituals Privacy Policy. The Image Material provided by you will be made available by Rituals on the Rituals Online Gift Card until the Rituals Online Gift Card has been completely redeemed, however in any event no longer than 12 months after receiving the Rituals Online Gift Card by recipient, after which the personalized Image Material shall be replaced by a standard Rituals image and the Image Material will be deleted by Rituals.

• Your personal data when subscribing to our newsletter. To be able to provide you with the newsletter of Rituals containing inspirational and commercial content, we use your email address and additional information if you add such to your profile, such as name, date of birth and favorite store. Rituals also sends out personalized newsletters, based on your personal preferences.

• Recordings (CCTV, events and telephone recordings). Some of our stores use video surveillance systems (CCTV). When you enter such stores, you are recorded by our video surveillance systems. If you attend events or fairs that Rituals hosts or attends, you can also be recorded if we make video footage of such event or fair. If you call us with a question or complaint, your telephone calls to us will be recorded.

• Your communication data. Any data shared by you when communicating with us via email, online, telephone, social media or any other form, such as questions, requests or complaints.

• Your personal data regarding raffles, subscribe and win, marketing campaigns, contests or sampling-activation. Any data shared by you when participating in a raffle, subscribe and win, lead generation campaign, contest or sampling-activation.

• Your personal data regarding our (store) events. Any data shared by you when sign up to and/or participate in events hosted by us, such as workshops, store events etc.

• Your ratings and reviews and feedback. The opinions, experiences, preferences and interests and product or event reviews that you publish on our websites or share with us online or through social media.

• Health data. We can also collect certain limited information in relation to your health, such as regarding your allergies. We will only use health data you voluntarily provide us and such only with your prior consent or under your direction to do so and only for the purposes set out in this Privacy Policy. You may refuse or revoke your consent at any time, as set out below.

3. Purposes Of Use Personal Data

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The personal data we collect is exclusively used for the following purposes:

For the performance of our agreement with you: In order to carry out our obligations arising from any contracts entered into between you and us, and to provide you with the Products, Services and information that you request, including managing and handling your requests, inquiries or complaints. This also includes enabling you to make a purchase of our Products, to participate in our MyRituals program,  responding to your requests to provide customer service, responding to your inquiries, providing you with essential information regarding our Products and Services you request, etc. 

For our legitimate commercial interests: We use your personal data as described above (both on aggregated and on individual basis) for the purpose of advertising our Products and Services, to contact you via e-mail, regular mail, social media or otherwise for direct marketing or other commercial purposes. We also use your personal data to validate that the age requirements in order to create a MyRituals account are met and to send you a birthday gift. Furthermore, we use your personal data for analyzing and improving the quality of our Products and Services, such as providing you with customer services and aftersales, and to understand you as a customer (customer optimalization). This enables us to assess what may interest you, to measure or understand the effectiveness of advertising we serve to you and others and to deliver relevant advertising. In addition, based on your use of our Services and Products you purchased, we may target you with advertisement or other marketing materials that are customized to your personal preferences and experiences. 

Improving and analyzing our products and services: We may also use your personal data, for our other legitimate commercial interests such as to operate and expand our business activities; to develop and improve or modify our Products and Services; to better understand how our services and website are accessed and used, in order to administer, monitor, and improve our services, for our internal purposes, and to generate aggregated statistics about the users of our Products and Services for research and analytical purposes. 

In support of our general business operations: where necessary for the administration of our general business, accounting, record keeping and legal functions, including analyze operational and business results and risks, and maintain business records; to operate company policies and procedures; to enable us to negotiate or enter into corporate transactions, such as any merger, sale, reorganization, transfer of Rituals’ assets or businesses, acquisition, bankruptcy, or similar event; or for other legitimate business purposes permitted by applicable law. 

To secure and Protect our assets and rights: to protect and defend our (and others’) rights, property or safety; to prevent abuse and fraud related to online sale of our products and to monitor the compliance with our House Rules for the use of our website(s) and apps; to protect our business operations, secure our network and information technology, assets and services; unauthorized activities, access and other misconduct; where we believe necessary to investigate, prevent or take action regarding suspected violations of our General Terms and Conditions and other agreements with you, as well as fraud, illegal activities and other situations involving potential threats to the rights or safety of any person or third party.   

Complying with Legal Obligations: to comply with the law or legal proceedings. For example, we may use information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements. 

Use of information based on your consent: Under circumstances we will also ask your consent for the processing of your personal data. For example, when you have not purchased our Products but would like to receive (MyRituals) direct marketing communications (such as newsletters, promotions, news on products) via email, other electronic means or telephone. Or when you would like to participate in our raffles, contests or our marketing campaigns.