Last updated and effective date: NOVEMBER 29, 2021
This privacy notice describes how bareMinerals US Buyer LLC (“Orveon”, “we”, “us” or “our”) collects, uses, shares, and protects personal information. It also tells you about the rights and choices you have with respect to your personal information, and how you can reach us to get answers to your questions.
This privacy notice covers the “personal information” that Orveon obtains about you in various contexts, both online and offline, including when you visit our websites (“Sites”), download and use our mobile applications (“Apps”), communicate with us, or participate in any of our programs or events. This Privacy Notice does not cover Orveon’s processing of personal information relating to job applicants, employees or other staff members. Our Sites may include links to third party websites and/or applications.
Please note that we have no control over the privacy practices of websites or applications that we do not own, and we encourage you to review the privacy notices of these third party websites.
We obtain information about you from a variety of sources depending on our relationship with you. The following are examples of the types of personal information that we collect:
Examples of Personal Information Collected
When you choose to receive our newsletter, we collect your e-mail address.
When you communicate with us, including contacting us for support, to provide feedback or comments, to participate in a survey, or to make a request or other inquiry, we will collect your name and contact information (such as e-mail address or phone number), as well as any other information that you choose to provide to us. In some cases, we record customer service calls for quality assurance.
If you choose to submit or post information, reviews or photos in a public space on our Sites, or on our social media pages, such as creating a public profile, rating our products, submitting content as part of Orveon’s online community, or leaving a testimonial about an Orveon influencer, we collect the information you share.
When you sign up to receive promotional communications from us, such as e-mail communications, mobile messages (including text and/or push notifications), and postal mailings, we collect your contact information. We may also collect certain information about how you interact with the e-mails and promotional messages we send you.
When you participate in a sweepstakes, contest, or other similar campaign or promotion, we collect your name, contact information, and in some cases limited demographic information and content generated by participants. Some campaigns and promotions have a social networking component where you can choose to submit additional information such as social media profiles and handles, photographs, and other content.
If you register for a professional account on the Sites, in addition to your name and contact details, we will collect your license number or student identification number, your license expiration date, whether or not you are a salon owner and your salon details, and the details required to verify that you are a professional (such as a copy of a business card, professional website link, photo of professional certification, or professional distributor store and location). If you choose to become a certified Orveon stylist, we will collect information regarding your enrollment in our Certification course, your responses in each of our Certification quizzes and whether or not you receive an Orveon Certificate.
In addition to the personal information we collect from you directly, we may also obtain information about you from other sources, including third parties, business partners (e.g., beauty stores or distributors), our corporate affiliates (i.e., other entities in the Orveon group), social networks, vendors that provide services on our behalf, or publicly available sources. For example, if you have given Orveon permission to store your credit card information and your credit card issuer provides an account updater service, we may receive updated credit card information (including credit card number and expiration date) from the credit card issuer.
When you visit our Site, we may obtain certain information by automated means, such as through cookies, web beacons, web server logs and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an internet tag, pixel tag or clear GIF, links web pages to web servers and cookies and may be used to transmit information collected through cookies back to a web server. The information we collect in this manner may include your device IP address, unique device identifier, web browser characteristics, device characteristics, operating system, language preferences, referring URLs, media access control, clickstream data, and dates and times of website visits.
We may use these automated technologies on our Sites and Apps to collect information about your equipment, browsing actions, and usage patterns. These technologies help us (1) remember your information so you do not have to re-enter it; (2) track and understand how you use and interact with our Sites and Apps; (3) tailor the Sites and Apps around your preferences; (4) measure the usability of our Sites and Apps and the effectiveness of our communications; and (5) otherwise manage and enhance our products and services, and help ensure they are working properly.
Your browser may tell you how to be notified about certain types of automated collection technologies and how to restrict or disable them. Please note, however, that without these technologies, you may not be able to use all of the features of our Sites and Apps. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.
We use personal information when required in order for us to perform our contract with you, or take steps to form a contract with you, such as to:
We also use your information in order to pursue our legitimate interests in offering you the best service and customer experience possible, securing our website and customers, and running our business efficiently. For example we process your information to:
We also use your information so that we can send marketing and advertising communications and other promotional materials such as trend alerts, promotions, sweepstakes, contests, new product launches, and event invitations, and understand how you interact with our communications with you.
If you are an individual located in the European Union or United Kingdom, we will not send you marketing and advertising material without your prior consent, unless otherwise permitted to do so by applicable law. In addition, we will only use general health and wellness information that we collect for the purposes of recommending products and treatments, when we have your consent to do so, or are otherwise permitted to do so by applicable law.
Finally, we use your information when necessary in order to comply with and enforce applicable legal requirements, relevant industry standards and Orveon policies, including our Terms & Conditions.
We also may use the information we collect in other ways for which we provide specific notice at the time of collection.
Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this privacy notice, unless a longer retention period is required or permitted by law.
We use third-party analytics services on our Sites and Apps, such as Google Analytics and Shopify Reports. The information we obtain through the Sites and Apps may be disclosed to or collected directly by these services.
On our Sites and Apps, we may obtain information about your online activities to provide you with advertising about products and services that may be tailored to your interests. This section of our privacy notice provides details and explains how you can exercise certain choices.
The Sites and Apps are not designed to respond to “do not track” signals from browsers.
To learn how to opt out of interest-based advertising, please visit www.youronlinechoices.com for more information.
In addition to the specific situations discussed elsewhere in this privacy notice, we disclose personal information in the following circumstances:
We may share personal information with our corporate affiliates within the Orveon group. We also share personal information with our professional advisors, such as our lawyers and accountants.
We share certain personal information with third parties that perform services to support our core business functions, Sites and Apps, and internal operations (e.g., hosting and securing our Sites, providing web support to our Sites, processing and fulfilling orders, delivering packages, complying with your request for the shipment of products to or the provision of services by a third party intermediary, sending postal mail and e-mails, analyzing customer data, providing marketing assistance, processing credit card and debit card payments, investigating fraudulent activity, conducting customer surveys, and providing customer service).
Some of our Sites have features such as plugins, widgets, or other tools made available by third parties that may result in information being collected or shared between us and the third party. For example, if you use Facebook’s “Like” feature, Facebook may register the fact that you “liked” a product and may post that information on Facebook. Their use of your information is not governed by this privacy notice.
We may disclose personal information in response to subpoenas, warrants, court orders, government inquiries or investigations, or to comply with relevant laws and regulations. We may also disclose information to establish, exercise, or protect the rights of our company, employees, agents, and affiliates; to defend against a legal claim; to protect the safety and security of our visitors; to detect and protect against fraud; and to take action regarding possible illegal activities or violations of our policies.
We may share personal information with another company that buys some, or all, of the assets or shares of Orveon, and that company may use and disclose personal information for purposes similar to what is described in this notice. Orveon may also share personal information with prospective purchasers to evaluate the proposed transaction.
We may ask if you would like us to share your information with other third parties who are not described elsewhere in this privacy notice.
We maintain administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized access, destruction, loss, alteration, disclosure or use.
Our Sites and Apps are designed for a general audience and are not directed to children. In connection with the Sites and Apps, we do not knowingly solicit or collect personal information from children under the age of 16 without parental consent. If we learn that we have collected personal information from a child under age 16 without parental consent, we will either seek parental consent or promptly delete that information. If you believe that a child under age 16 may have provided us with personal information without parental consent, please contact us as specified in the Communicating With Us section of this privacy notice.
You have the following choices regarding your personal information:
What you need to do
You may request access to your personal information by emailing firstname.lastname@example.org. To the extent required by law, upon request, we will grant you access to the personal information we have about you.
You may also contact us to update your information by emailing email@example.com
You may, however, request that we delete your personal information by emailing firstname.lastname@example.org If required by law, we will grant a request to delete information. Please note that in some cases we may be required to retain your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, protect against fraudulent, deceptive, or illegal activity, or for another one of our business purposes.
Subject to applicable law, you may request that we restrict the use of your personal information in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your personal information.
Subject to applicable law, you may request that we cease to process certain personal information where you object to its use, we do not have an overriding legitimate interest in carrying out the processing and it is not necessary for the establishment, exercise or defence of legal claims.
You may choose to provide us with your e-mail address for the purpose of allowing us to send you free newsletters, surveys, offers, and other promotional materials. You can stop receiving promotional e-mails at any time by clicking on the “unsubscribe” link at the bottom of any promotional e-mail that you receive.
Subject to applicable law, you may request that we provide a copy of your personal information to you in a structured, commonly used and machine readable format.
Subject to applicable law, where we rely on your consent for the purposes of our use of your personal information you have the right to withdraw your consent at any time. This will not affect the lawfulness of our use of your personal information prior to your withdrawal of consent.
You can request that we remove content or information that you have posted on a public page on some of our Sites by e-mailing details to Customer Service at email@example.com Please note that while we will endeavor to honor your request, our removal of your content or information does not ensure complete or comprehensive removal of that information from our Sites. For example, historical copies, or “caches,” may remain.
If you are located in the United Kingdom and are unsatisfied with our processing practices or our response to your request, you may lodge a complaint with the Information Commissioner’s Office.
If you are a California consumer, for more information about our privacy practices and your privacy rights, please see our California Consumer Privacy Statement.
Orveon is located in the United States and our service providers may be located in the United States or other countries. As a result, your personal information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. By submitting your personal information to us you agree to the transfer, storage and processing of your personal information in a country other than your country of residence including, but not necessarily limited to, the United States.
If you have any questions about our privacy or security practices, you can contact Orveon:
Attn. Legal Department
500 Fifth Avenue
New York NY 10110
If we need, or are required, to contact you concerning any event that involves your personal information we may do so by e-mail, telephone, or mail.
We may revise this privacy notice from time to time. We will notify you of material changes by posting a notice of the update on the Orveon website.