For material changes (i.e., substantially new practices you wouldn’t expect from us or that we didn’t
previously tell you about), we may decide to notify you more prominently and/or give you prior choice. We
reserve the right to make changes to our practices and this Policy at any time, provided that we follow the
- How do we collect information from you?
- What information do we collect?
- How do we use your information?
- With whom do we share your information?
- How do we protect your information?
- Other important policy information
- How can you contact us with questions?
- California “Do Not Track” Notice?
- California Privacy Rights
- How to contact us
How do we collect information from you?
The Peter Thomas Roth website: We may collect information from you through (a) our U.S. website (www.peterthomasroth.com) or (b) any site or web application that we may develop and run on a third party social network such as Facebook. This Policy will only apply if it is posted or linked to on the website or application which you are using.
Information we collect directly from youWe collect the information you provide directly to us, such as when you open an account, place an order, ask to receive emails, or interact with us on social media.
The types of personal data we may collect directly from you include:
- • Contact information, such as your name, email address, mailing address, and phone number;
- • Account information, such as your username and password;
- • Billing information, such as credit card details and billing address;
- • Optional information you may choose to provide, such as your date of birth, gender, social handles, skincare concerns or preferences; and
- • Any other information you choose to provide.
Information about your use of our ServicesWe collect information about your use of the Services, such as the products you buy or express interest in.
Data collected from other sources:Occasionally, we may obtain information about you from other sources. For example, we may hire a third party data aggregator or vendor to provide us additional information about our existing customers (this is known as “data appending”), including information from your profile or postings on a third party social network. We may also receive information from third party co-sponsors who we may partner with occasionally to run special promotions or giveaways. We may also receive information about customers in the event we acquire other companies.
What information do we collect from you?
Depending on how you interact with Peter Thomas Roth (online, on the phone, etc.), we may collect from you various types of information, which are described in more detail below. In some instances (and unless we say otherwise below), we may combine one type of information with another type of information, and store them together in our records. In all cases, however, we strive to limit the amount of information we collect and store to that which is necessary to provide you the relevant services.
Personal contact information:
This includes any information that would allow us to personally contact you, such as your name, home or mailing address, phone number (home, cell, etc.), or email address. In some cases, this could include information that you give us about someone else (for example, if you ask us to ship a Peter Thomas Roth product to a friend). We typically collect personal contact information in connection with a variety of activities, including account registration (e.g., online shopping and website community features, newsletter sign-up, or other registration), product orders, customer service, contests and promotions, and customer feedback. If you create an account with us, some of your personal contact information may be stored under your account profile. To review or edit this information, go to the relevant “My Account” section of our site or contact Customer Service at firstname.lastname@example.org
Account login information:
This refers to any information that is required for you to establish a unique account with us or for us to give you access to your specific account information. Examples include customer number, login ID, screen name, password, and/or security question and answer. Certain login information, such as your customer number, may be generated by us and then sent to you. We only collect (or create for you) unique login information for those activities that require an account. Your unique login information, especially your password, should always be kept confidential and should never be shared with anyone else. To change your account password, go to the relevant “My Account” section of our site or contact Customer Service at email@example.com
This includes any information that describes demographic or psychographic characteristics. Examples may include your date of birth, age or age range, gender, facial attributes (e.g., hair color, eye color, skin type, skin tone, etc.), general geographic location (e.g., zip code or city and state), favorite products, hobbies and interests, or lifestyle information. We typically collect demographic information in connection with a variety of activities, including account registration (e.g., online shopping, website community features, newsletter sign-up, etc.), contests and promotions, and customer surveys. If you create an account with us, you may be allowed to modify certain demographic information stored under your account profile. To do so, go to the relevant “My Account” section of our site or contact Customer Service at firstname.lastname@example.org For demographic information associated with your profile on a third party social network (e.g., Facebook), see separate paragraph on “Social network information” below.
Technical computer info:
This includes any information about the computer system or other technological device that you may be using to access one of our websites. We typically collect this information through the use of automated technologies such as cookies and web beacons. For more on cookies, see Section 4 below. Examples of technical computer information that may be collected include your computer’s IP address, operating system type, and web browser type. If you access our website via a mobile device such as a smartphone, the collected information may also include your phone’s unique device ID, location, and other similar mobile device data. Technical computer information is not typically associated with your personal contact information.
Website usage information:
This includes information about how you use and navigate our website, including which links you click on, which pages or content you view, and other similar information or statistics about your interactions with our websites (e.g., date and time of visit, which site you came from, etc.). This information is captured using automated technologies such as cookies and web beacons, and may be collected regardless of the device you may be using (computer, smartphone, tablet, etc.). This information may also be collected using third party analytics services (such as Google Analytics) that collect data in aggregate (such as number of visits to a particular page or the amount of time spent on a site). We may also use these technologies, such as web beacons, to capture information about how users respond to certain email campaigns (e.g., time the email is opened, where users link to from that email, etc.). Website usage information may be associated with your personal contact information. For more on cookies and analytics, see Section 4 below
This includes information that you voluntarily share with us about your experience in using our products or services, including our beauty products, or website. Examples may include comments and suggestions, testimonials, or other feedback you send us about what you may have liked (or disliked) about your experience in using our products or services. We typically collect this information in the form of customer surveys, feedback forms, and email correspondence.
This refers to any content that you create and then share with us (and perhaps others) by uploading it to one of our websites, such as our Facebook fan pages. Examples may include photos, videos, personal stories, or other similar media or content. We mostly collect customer-generated content in connection with contests and promotions, website community features, customer engagement, and third party social networking.
Social network information:
This refers to any information that is part of your profile on a third party social network (such as Facebook) and that you allow the third party social network to share with us or that you post publicly. Examples may include your basic account information (e.g., name, email address, profile picture, gender, birthday, current city, user ID, list of friends, etc.) and any other additional information or activities that you permit the third party social network to share with application developers or that you post publicly on a Peter Thomas Roth social networking page. For example, we may receive your social network information (or parts of it) when you download or interact with a Peter Thomas Roth application on a social networking site (such as Facebook) or use a third party social networking feature that is integrated within the Peter Thomas Roth website (such as Facebook Connect). To learn more about how your social network information may be obtained by Peter Thomas Roth (or other application developers), please visit the website of the relevant third party social network.
Other information (depending on context):
This refers to any other information that we might need to collect for a specific Peter Thomas Roth form, feature, or other service that you use or request. What this information might include will vary depending on the method of collection and the specific purpose(s) for which the information is being collected. Please see Section 3 below for more specific examples.
How do we use your information?
The following paragraphs describe the various purposes and features for which we might collect and use your information, and the different types of information that might be collected for each. Please note that not all of the uses listed below will be relevant to every customer.
We may use your information to maintain your accounts with us, including administering any customer loyalty or rewards programs associated with such accounts. This typically involves the use of the information that was originally collected to set up your account (e.g., personal contact information, payment information, account login information, demographic information, etc.).
We may collect and use your information to provide you customer service, including responses to your inquiries. This typically requires the collection and use of certain personal contact information (such as your name, email address) and information regarding the reason for your inquiry (e.g., order status, technical issue, product question, general question, etc.). Customer service may be provided through various forms of communication, such as email correspondence and call center support. We may also use your personal information to protect against, identify, investigate, and respond to fraud or other illegal activity.
Product improvement and customization:
We may collect and use your information so we can constantly improve our products, tailor them to your needs, and come up with new product ideas. This mostly involves the collection and use of demographic information and customer feedback. Personalized product recommendations: We may use your information to provide you with Peter Thomas Roth product recommendations, offers, and rewards that are tailored to your interests and profile.
Contests and Promotions:
We may collect and use your information to administer a contest, sweepstakes, giveaway, competition, or other similar marketing campaign or promotion. These events typically require the collection and use of personal contact information (for prize fulfillment), limited demographic information (for eligibility), and, in some cases, customer-generated content. Some promotions with customer-generated content or a social networking component will be run on third party social networks such as Facebook (e.g., on our Facebook fan page). To comply with sweepstakes laws, we may publish or share limited information about promotion winners (such as name and city of residence). For more information about our contests and other promotions, please see the official rules or details posted with each promotion.
Website personalization and convenience:
We may collect and use your information to personalize your experience and save you time when you visit our websites. This is typically done through the use of automated technologies (such as cookies) that collect and remember certain account login information, technical information, and/or previous website usage information. For example, we might remember your login ID or username so you can quickly login the next time you visit our site. Based on this type of information, we might also show you specific Peter Thomas Roth content or offers that are more relevant to your interests.
Website community features:
We may collect and use your information to give you access to our website community features, such as features that may allow you to upload and share ratings, reviews, questions/answers, stories, pictures, videos, or other content. This typically involves the collection, use, and (in some instances) public display of certain personal contact information, account login information, demographic information, and/or customer-generated content. Because these types of features are “communal” in nature, information you post in these areas may be visible to others. Please use caution when using these features or uploading content to the Peter Thomas Roth site. For some community features, you may have the ability to control whether some parts of your profile can be seen by others and whether we send you notifications about certain community activities (like the fact that one of your questions has been answered). To access these settings, go to the “My Account” section of our site and login to the relevant community account. For community features that are integrated with third party social networks such as Facebook, see separate paragraph on “Third party social networking” below. Website viral features (e.g., tell-a-friend): Where permissible under applicable law, we may request and use your information so you can use our website viral features, such as tell-a-friend. These features allow you to easily share certain Peter Thomas Roth news, product information, promotions, wish list items, or other content with family members and friends. These features typically require the collection and use of certain personal contact information (such as email addresses and names) so that the selected message or content can be delivered to the proper recipients. In some instances, this information may be stored in our records so we can track and reward our customers for their referrals. For tell-a-friend or other viral features offered by third party social networks (such as Facebook “Share” and “Like” features), see separate section on “Third Party Online Advertising” below.
Third party social networking:
We may collect and use your information when you interact with third party social networking features, such as Facebook Connect, Facebook Like, Pinterest, and Instagram. These tools may be embedded into our sites for the purpose of running contests, allowing you to share content (such as beauty tips, articles, stories, etc.), allowing you to sign up for certain Peter Thomas Roth accounts, or for other stated purposes. If you use these tools, we may have the ability to obtain certain information about you from your social networking profile (see “Social network information” under Section 2). You can learn more about how these features work, and the profile data we may obtain about you, by visiting the website of the relevant third party social network.
Third party online advertising:
We may allow third party ad networks to collect and use your information to show you targeted ads (including Peter Thomas Roth digital ads) on our sites or on other sites. Some of these ads may entice you to come back and revisit our site for new offers and promotions. This type of advertising typically involves an ad network collecting and tracking certain technical information (such as your IP address) and website usage information (such as your browsing history) on our sites and across many other sites on the Internet. This does not involve the collection, use, or sharing of your personal contact information, such as your name or email address. You can opt-out from this type of third party tracking at any time by going to: http://www.networkadvertising.org/managing/opt_out.asp.
Other general purposes (e.g., website security, internal research)
We may collect and use your information for other general business purposes, such as to maintain the day-to-day operation and security of our websites and to conduct internal marketing and demographic studies. These activities mostly require the collection and use of certain personal information, demographic information, technical computer information, website usage information, and customer feedback.
With whom do we share your information?
We may share your information with the types of companies or in the situations described below. We do not rent or sell your information to third party companies for their own marketing use.
We may share or receive information about you, including personal information, with or from our corporate affiliates, including our sister company, June Jacobs Laboratories LLC, and Naturally Serious, LLC.
Third party vendors:
These are outside vendors, agencies, or contractors we hire to help us run our business (e.g., fulfill orders, operate our websites, run promotions and marketing campaigns, operate our call center, etc.). The information shared with our vendors could include personal contact information, payment information, demographic information, or other types of information depending on the service being provided by the vendor. Our vendors are only allowed to use your information for the specific tasks we’ve hired them to do, and for no other purpose. They’re also required by contract to keep your information confidential and secure.
Legal disclosures (when necessary):
This is when we may need to share your information for law enforcement or other legal purposes. This type of sharing may be necessary in connection with a lawsuit, claim or investigation, governmental inquiry, court order, enforcement of legal rights (e.g., contract terms, intellectual property rights, etc.), safety issue, or other similar legal or security matter.
Business transfers (e.g., sale or acquisition of company):
How do we protect your information?
We use a variety of standard methods (described below) to keep customer information confidential and secure. Please note, however, that these protections do not apply to any information you choose to share in public areas such as our website community features or other social areas.
Secure operating environments:
We store your information in secure operating environments that are protected from the public and that we only allow authorized employees and agents/contractors to access on a need-to-know basis.
Encryption for payment info:
We use industry-standard encryption to provide greater protection for sensitive financial information, such as your credit card information or other payment information, when such information is sent to us over the web. For example, encryption is used when you make payments through our online store, as well as if you choose to have your payment information stored with our third party processor for future online purchases.
Other security measures:
In addition to the methods above, we may take other measures to protect your information, depending on the sensitivity of the data and other considerations (such as how the information is collected and where it is stored). These measures may include (among other things) additional access restrictions, password requirements, and physical protections (e.g., secure data centers, etc.).
Measures you can take:
Despite all of our efforts, no security safeguards or standards are guaranteed to provide 100% security. It is also important for you to play a role in keeping your information safe and secure. When signing up for an online account, please be sure to choose an account password that is hard for others to guess and never to reveal it to anyone else. If you use a shared or public computer, never choose to have your login ID or password remembered and make sure to log out of your account every time you leave the computer.
Other important policy information
This section provides additional information that is important for you to know about this Policy or our practices.
We do not collect information from children:
We do not solicit or collect any type of information from a person known to be under the age of 13. If we discover that we have accidentally collected information from a child, or you have reason to believe that a child has provided personal data to use, please contact us and we will remove that information from our records as soon as feasibly possible (or obtain the necessary parental permission to retain it).
We are not responsible for third party sites/features:
Our websites may provide links to, or features from, other third party sites (such as third party social networks) that we do not own or control. If you click on such links or use such features, you do so at your own risk. We are not responsible for the content or practices of any third party site, application, or feature.
California “Do Not Track” Notice.
Peter Thomas Roth does not currently recognize and process “do not track” signals from different web browsers. You may manage your preferences for tracking across sites in the Third Party Web Analytics section above. For more information on “do not track” please visit http://www.allaboutdnt.org.
If you are minor under 18 and have a profile on peterthomasroth.com, you may ask us to remove reviews or other content that you posted on the site by writing to email@example.com. We will begin to process your request within 30 days. Please note that processing your request does not ensure complete or comprehensive removal of content that you posted.
Notice to Nevada Residents
Pursuant to Nevada law, you may direct a business that operates an internet website not to sell certain personal information a business has collected or will collect about you. Peter Thomas Roth does not sell your personal information pursuant to Nevada law. However, Nevada residents have the legal right to opt out of the sale of their personal information, even if their information is not currently being sold. For more information about how we handle and share your personal information or to opt-out under Nevada law, contact us at firstname.lastname@example.org.
This notice applies to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household such as your real name, alias, postal address, unique personal identifier, online identifier Internet Protocol (IP) address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers (defined in the CCPA as “Personal Information”). This notice applies to Personal Information of California residents collected through this Website.
Personal Information does not include:
- • Publicly available information we obtain from government records,
- • De-identified or aggregated consumer information.
Information We Collect
We have collected the following categories of Personal Information from consumers within the last twelve (12) months:
|Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.||Yes|
|Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, address, telephone number, passport number, credit card number, debit card number, or any other financial information. Some Personal Information included in this category may overlap with other categories.||Yes|
|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).||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|
|Commercial information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Yes|
|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|
|Internet or other similar network activity||Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.||Yes|
|Geolocation data||State and country location.||Yes|
|Sensory data||Audio, electronic, visual, or similar information.||Yes|
|Professional or employment-related information||Current or past job history or performance evaluations.||No|
|Education information||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|
|Inferences drawn from the above||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||Yes|
Categories of Sources
We obtain Personal Information provided voluntarily by you or a family member when you purchase our products or submit other similar forms directly to us or our affiliates by mail, email, by telephone, or via our websites and mobile applications. We also gather it from written or verbal inquiries submitted by you, surveys, transactions, and from online interactions with you.
We also collect information from third parties and publicly available sources, which include data service providers, social media services, advertising and market research firms, joint marketing partners, and consumer reporting agencies.
Business Purposes for Collection of Personal Information
Collecting and using Personal Information is necessary to our business as a consumer products company in order to develop, enhance, and administer our products and services, respond to your requests, inquiries and concerns, inform and educate you about our company and events, and for advertising and marketing purposes. It also helps us to confirm your identity for certain transactions you request or that are initiated on your behalf, improve our website and mobile application user experience, authenticate users, prevent and detect fraud and potential security issues, and fulfill our legal and regulatory obligations such as tax reporting.
Disclosures of Personal Information
Your Personal Information may have been disclosed to:
- • You, your authorized representatives, legal agents, and other persons
acting on your behalf or to whom you ask, instruct or authorize us to disclose
your Personal Information,
- • Our contracted service providers who provide a service to or on behalf of
Peter Thomas Roth, including analytics service providers, payment providers and
- • Our auditors, consultants, accountants, attorneys and others providing professional advice to Peter Thomas Roth,
- • Other Peter Thomas Roth affiliates and brands,
- • Business partners of Peter Thomas Roth,
- • Applicable governmental, regulatory, supervisory, law enforcement, tax or similar authorities or industry bodies,
- • Any other person or entity Peter Thomas Roth reasonably thinks customary,
whom Peter Thomas Roth is obliged by applicable law or regulation to make the disclosure,
- • Any other party where Peter Thomas Roth has obtained your consent or authorization.
Business Purposes for Disclosure of Personal Information
- • To advertise and market to you, and to consumers who are similar to you,
- • To perform services on our behalf, including providing customer service, processing or fulfilling orders, account maintenance, processing payments, and quality control,
- • For risk management purposes, identity verification, information security, fraud detection and prevention,
- • Undertaking internal research, operational efficiencies and improvements, product enhancements, and business development purposes,
- • In connection with legal proceedings, such as responding to a subpoena or court order,
- • To demonstrate compliance with our regulatory obligations,
- • To report tax information to relevant tax authorities,
- • In the event of any planned or actual company reorganization, merger, sale, or transfer, of our business.
Your CCPA Rights
Right to Know
You have the right to request that we disclose certain information to you about our collection of your Personal Information. Such information shall cover the 12-month period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the following:
- • The categories of Personal Information we have collected about you,
- • The categories of sources from which we have collected your Personal Information,
- • Our business or commercial purpose(s) for collecting or sharing your Personal Information,
- • The categories of third parties with whom we have shared your Personal Information, and
- • The specific pieces of Personal Information we have collected about you.
Please note that even if your request is validated, we will not at any time disclose sensitive information such as a consumer’s financial account number, account password, or answers to security questions. We are not required to respond to more than two requests per 12-month period.
You have the right to request that we disclose certain information to you about our disclosures of your Personal Information to third parties. Such information shall cover the 12-month period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the following:
- • The categories of Personal Information we have collected from you,
- • The categories of Personal Information that we disclosed about you for a business purpose.
To access your Right To Know, please click here.
Right to Opt-Out of Sale
We don’t monetize your personal information, however, we sometimes share information with unaffiliated third parties we collaborate with or that provide offers that we think may be of value to you, or with data cooperatives. This sharing of information may be considered a “sale” under California law. If you would like to opt out of our sharing with those unaffiliated third parties for purposes that could be considered “sales” or otherwise for those parties’ own commercial purposes, please click here.
Right to Delete
You have the right to request that we delete certain Personal Information we collected from you. However, in many cases we cannot delete all or some of it due to our regulatory obligations to retain certain information, or as required or permitted by other applicable laws, such as for fraud prevention and similar purposes.
To access your Right To Delete, please click here.
Right to Non-Discrimination
We will not discriminate against you for exercising your rights under the CCPA, such as denying you products and services, charging you different rates or prices including use of discounts or penalties, or suggesting or providing a different level of service or quality of products to you.
How to Exercise Your CCPA Rights
To submit a request to exercise any of your rights provided in this notice, please either contact us at email@example.com using “CCPA REQUEST” in the subject line. You may also write to us at Peter Thomas Roth, LLC. 460 Park Ave. Floor 16, New York, NY 10022. You may also use this webform to learn more and exercise your CCPA rights. We must be able to verify your identity and place of residence before we take action on your request. Please provide sufficient information to assist us, including a name and shipping address and transaction date. Let us know if there is anything specific that you are requesting.
You may also use an authorized agent to exercise your rights on your behalf. If you wish to use an authorized agent, we require that your authorized agent provides written proof to us that he or she is authorized to act on your behalf, and we may also require your authorized agent to verify his or her own identity. To appoint an authorized agent, please contact us at firstname.lastname@example.org.
How can you contact us with questions?
Peter Thomas Roth, LLC
460 Park Ave. Floor 16,
New York, NY 10022.