Privacy Policy
Privacy Policy
Last Updated and Effective as of: October 6, 2022
Maurice Max Inc. (“we”, “us” or “RA”) respects your privacy and is committed to protecting your personal data. The privacy notice below discloses our practices regarding information collection and usage solely for the website located at https://roxanneassoulin.com (the "Website"). This privacy notice does not apply to any other websites, apps or services provided by us, our affiliates or clients, unless it appears on such website, app or service.
Information We Collect:
Your provision of your Personally Identifiable Information to us is completely voluntary. “Personally Identifiable Information” is information that can specifically identify you. We do not collect Personally Identifiable Information unless you submit that information to us, such as when you choose to participate in our offers and programs or otherwise provide information directly to us, including when you register with us, purchase products, participate in our interactive features or otherwise interact with us on the Website. Categories of Personally Identifiable Information we collect include:
Identity Data, which includes name or other similar identifiers.
Contact Data, which includes address, email address and telephone numbers.
Financial Data, which includes payment card details.
Additionally, we may also collect certain other types of information that, along with Identity Data, Contact Data, and Financial Data may be considered and specifically named “personal data” in certain jurisdictions, including the European Union (“EU”), such as:
Transaction Data, which includes details about payments.
Technical Data, which includes internet protocol (IP) address, your login data.
Profile Data, which includes your username and password, information about your past purchases, loyalty rewards account information.
Usage Data, which includes information about how you use our Website and services.
Marketing and Communications Data, which includes your preferences in receiving marketing from us.
IF YOU ARE SITUATED IN THE EU, PLEASE SEE THE SECTION “ADDITIONAL EU DISCLOSURES” THAT PERTAIN TO OUR COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.
Lastly, we collect information (some of which may also constitute Personally Identifiable Information) that identifies, relates to, describes, references, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. The California Consumer Privacy Act of 2018 (“CCPA”) refers to such information as “personal information”. For more information on the categories of personal information we collected within the last twelve (12) months see the “California Consumer Rights” section below. Personal information does not include (i) information that is lawfully made available from federal, state or local government records; (ii) deidentified or aggregated information or (iii) information excluded from the scope of CCPA.
IF YOU ARE A RESIDENT OF CALIFORNIA, PLEASE SEE THE SECTION “CALIFORNIA CONSUMER RIGHTS” FOR SPECIFIC DISCLOSURES WITH RESPECT TO OUR COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.
Non-Personally Identifiable Information:
As noted above, we may collect information that is not Personally Identifiable Information (“Non-Personally Identifiable Information”). We may aggregate Personally Identifiable Information so that the aggregated information does not personally identify you or anyone else, such as by using Personally Identifiable Information to calculate the percentage of our customers who live in a particular area ("Aggregate Information"). Because Non-Personally Identifiable Information does not personally identify you, we may collect, use and disclose Non-Personally Identifiable Information for any purpose permitted by law and subject to the section titled “Additional EU Disclosures” and “California Consumer Rights”. In some instances, we may combine Non-Personally Identifiable Information with Personally Identifiable Information. If we combine any Non-Personally Identifiable Information with Personally Identifiable Information, the combined information will be treated by us as Personally Identifiable Information.
Information Usage and Disclosure:
Besides using your information ourselves, we may send your information to other companies, affiliates and third parties to help us process your information for the purposes set out in this policy.
We use your information as described herein:
-To process and fulfill any orders that you have placed,
-To contact you about our products and services and provide you with our products and services,
-To personalize your experience with us including by presenting products or offers tailored to you,
-To respond to your direct inquiries,
-To add you to our mailing lists and send you emails from time to time.
We may also share your information with third parties such as website hosting, data analysis, payment processing, order fulfillment, infrastructure provision, information technology services, customer service, e-mail delivery services, credit card processing, auditing, training, and other similar services. These third parties may have access to Personally Identifiable Information necessary to perform their functions. One such third party is Shopify, provider of our online storefront platform. To see how Shopify will use your Personally Identifiable Information, please review their privacy policy here. To view their terms of use, click here.
We will not sell your Personally Identifiable Information to any third party not affiliated with RA without your consent except in connection with the sale or merger of RA or the division responsible for such services.
Additionally, we may disclose Personally Identifiable Information and other information as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) for legitimate business interests.
We may use Aggregate Information and Non-Personally Identifiable Information to improve and enhance your experience on the Website and for our market research activities. For example, and subject to section titled “Additional EU Disclosures” and “California Consumer Rights”, we may share Aggregate Information and Non-Personally Identifiable Information with unaffiliated third parties, such as business partners, manufacturers, distributors and retailers, in a form in which means the shared information will not contain nor be linked to any Personally Identifiable Information.
Please note that if you specifically consent to additional uses of your information, we may use your information in a manner consistent with that consent.
Security:
The security of your information is very important to us. We attempt to provide for the secure transmission of your information from your computer to our servers by utilizing encryption software. However, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and RA, or information stored on the Website or our servers, will be free from unauthorized access by third parties such as hackers and your use of the Website demonstrates your assumption of this risk. We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect. Only those employees who need access to your information in order to perform their duties are authorized to have access to your information. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the Contact section below.
Data Retention:
We will retain your information for as long as your account or inquiry is active or as needed to provide you with the Website and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your information, we may continue to retain and use anonymous or aggregated data previously collected. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties.
Protection for Children
Our Website is intended for ages 18 and over. We do not knowingly collect Personally Identifiable Information from children. When we become aware that Personally Identifiable Information (or other information that is protected under applicable law) from a child under 13 (or such other age as may be restricted under local law) has been collected, we will use all reasonable efforts to delete such information from our database.
Other Websites and Social Networking Services:
Our Website may contain links to other websites not maintained by us. Other websites may also reference or link to our Website. The inclusion of a link on the Website does not imply endorsement of the linked site by us. We are not responsible for the privacy practices of websites operated by third parties that are linked to or integrated with our Website, or for the privacy practices of third party Internet advertising companies. We encourage you to be aware when you leave our Website, or surf the Internet, and to read the privacy statements of each and every website that you visit.
The Website may integrate with social networking services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Website, we are doing so merely as an accommodation and, like you, are relying upon those third party services to operate properly and fairly.
Opt-Out:
To opt-out of any future promotional messages from us, you should send an unsubscribe request to us at TeamRA@RoxanneAssoulin.com. We will process your request within a reasonable time after receipt. Please note that if you opt out in this manner, certain aspects of the Website may no longer be available to you.
If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website or some of its functionality may be affected. Cookies and similar items are not used by us to automatically retrieve Personally Identifiable Information from your device without your knowledge.
We may, and may work with third parties, to use Personally Identifiable Information to deliver targeted advertisements to you based upon your online activities and other information. The online advertising industry provides a service through which you may opt-out of receiving targeted ads from certain data partners and other advertising partners that participate in self-regulatory programs. We comply with the Self-Regulatory Principles for Online Behavioral Advertising set forth by the Digital Advertising Alliance (DAA). You can opt-out of targeted advertising from certain providers at www.aboutads.info/consumers. Other providers are members of the Network Advertising Initiative, and you can opt-out of interest-based advertising by those members by visiting http://optout.networkadvertising.org/. Please note that by opting out, you will continue to see generic advertising that is not tailored to your specific interests and activities. To be clear, cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted out on your device browser, that opt-out will not be effective on your mobile device. You must separately opt out on each device.
For targeted advertisements delivered through mobile apps, you can install the DAA’s AppChoices app on your device to opt-out of targeted advertising by certain providers and can also select a system level advertising preference feature on your device (such as “Limit Ad Tracking” on Apple devices or “Opt-out of Interest-based ads” on Android devices).
Please note that, unless required by law, we do not respond to or honor “do not track” (a/k/a/ DNT) signals or similar mechanisms transmitted by web browsers.
Changes to policy:
We reserve the right, at our discretion, to change, modify, add, or remove portions from this policy at any time. Your continued use of the Website following the posting of any changes to this policy means you accept such changes.
California Consumer Rights:
If you reside in California or in a jurisdiction that provides similar rights, under the CCPA or applicable law, you have specific rights regarding your personal information. This section describes the rights that California consumers (and residents of other applicable jurisdictions) have and explains how to exercise those rights.
We collect (and have collected within the last twelve months) the following categories of personal information and share such personal information with the following categories of third parties:
|
Category |
Sources of Personal Information |
Purpose for Collecting Personal Information |
Categories of Third Parties with Whom Personal Information was Shared |
|
Personal identifiers including contact information such as name, shipping address, billing address, email address, telephone number, payment card details, account login information; and online identifiers such as internet protocol (IP) address, unique device identifiers, type of browser. |
Contact information is collected from you directly through the Website when you place an order with us, create an account with us, contact us with any inquiries or send us a job application. Online identifiers are collected from you when you visit or use our Website. |
We use such information to process your orders, provide you with our products and services, respond to your direct inquiries, process your job application, and send you communications and advertising about goods and services that may be of interest to you. We also use such information to better understand how the Website is being used, customize the Website to you, improve our Website’s functionality and assist in anti-fraud services. |
Service Providers. We have contracted with operational service providers to manage certain aspects of the Website, including online shopping, payment processing, hosting and IT services, customer support services, data analysis and to develop and audit our Website. Advertisers. We share such information with our advertising partners. |
|
Personal information covered by the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) including name, address, telephone number, education, employment, employment history, credit card number, and debit card number. |
Collected from you directly through the Website when you place an order with us, create an account with us, contact us with any inquiries or send us a job application. |
We use such information to process your orders, provide you with our products and services, respond to your direct inquiries and process your job application. |
Service Providers. We have contracted with operational service providers to manage certain aspects of the Website, including online shopping, payment processing, and customer support services. |
|
Commercial information including products or services purchased, obtained, or considered, loyalty rewards information and other purchasing or consuming histories or tendencies and marketing preferences. |
Collected from you directly through the Website when you place an order with us, create an account with us or contact us with any inquiries. Collected from our partners who collect the information from you directly when you visit our partners’ sites or use our partners’ search engines. |
We use such information to process your orders, provide you with our products and services, respond to your direct inquiries and to deliver targeted advertising about goods and services that may be of interest to you. |
Service Providers. We have contracted with operational service providers to manage certain aspects of the Website, including online shopping, payment processing and customer support services. Advertisers. We share such information with our advertising partners. |
|
Internet or other similar network activity including browsing history (websites you visited before and after you visited the Website, webpages of the Website you visited), search history, and information on a consumer's interaction with the Website or advertisements (links or ads that you clicked on, how much time is spent on webpages). |
Collected from you when you visit or use our Website and from our partners who collect the information from you when you visit our partners’ sites or use our partners’ search engines. |
We use such information to deliver targeted advertising about goods and services that may be of interest to you, to better understand how the Website is being used, customize the Website to you and improve our Website’s functionality. |
Service Providers. We have contracted with operational service providers to manage certain aspects of the Website, including hosting and IT services, data analysis and to develop and audit our Website.Advertisers. We share such information with our advertising partners. |
|
Location data including the region where your device is located (e.g., country derived from IP address) |
Collected from you when you visit or use our Website. |
We use such information to better understand how the Website is being used, customize the Website to you and improve our Website’s functionality. |
|
|
Professional or employment-related information including current or past job history |
Collected from you directly when you apply for a job through our Website. |
We use such information to process your job application. |
|
|
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) including education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades or transcripts. |
Collected from you directly when you apply for a job through our Website. |
We use such information to process your job application. |
|
|
Inferences drawn from other personal information for profiling purposes including data used to create a profile reflecting a person's preferences such as language preference and other characteristics. |
We use such information to deliver targeted advertising about goods and services that may be of interest to you and customize the Website to you. |
Service Providers. We have contracted with operational service providers to provide data analysis and to develop and audit our Website. Advertisers. We share such information with our advertising partners. |
Sharing of Personal Information:
We may disclose your personal information to a third party for a business purpose. The chart above lists the categories of third parties with whom we may share your personal information for such purposes as well as further details regarding each category of personal information.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
-Personal Identifiers
-Personal information covered by the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
-Protected classification characteristics under California or federal law
-Commercial information
-Internet or other similar network activity
-Location data
-Inferences drawn from other personal information
Your Rights, Choices, and Opt Out:
The CCPA provides consumers with specific rights regarding their personal information. This section describes the rights that you have under CCPA if you are a California resident and explains how to exercise those rights. You may also have similar rights if you reside in jurisdictions with similar laws to CCPA.
Right to Opt-Out of Sales of Personal Information:
The CCPA provides California consumers the right to direct businesses to not sell their personal information at any time (the “right to opt-out”). In the preceding twelve (12) months, we have not sold personal information (including the personal information of minors under 16 years old), and we will not sell any personal information, including the personal information of minors.
Right to Know About Personal Information Collected, Disclosed, or Sold:
You have the right to request that we disclose certain information to you about our collection, use, disclosure or sale of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, and Deletion Rights), and subject to certain limitations that we describe below, we will disclose such information to you. You have the right to request any or all of the following:
-The categories of personal information we collected about you
-The categories of sources from which the personal information is collected
-Our business or commercial purpose for collecting or selling that personal information
-The categories of third parties with whom we share that personal ifnormation
-The specific pieces of personal information we collected about you
Right to Request Deletion:
You have the right to request that we delete any of your personal information that we collected from you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records. However, we may retain personal information that has been de-identified or aggregated.
Furthermore, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) in order to perform certain actions set forth under CCPA, such as detecting security incidents and protecting against fraudulent or illegal activity.
Exercising Access and Deletion Rights:
To exercise the access and deletion rights described above, please submit a request to us by either:
-Emailing us at TeamRA@RoxanneAssoulin.com
-Notification via mail at 49 West 27th Street, 5F, New York, NY 10001
Only you, or a person or business entity registered with the California Secretary of State that you authorize to act on your behalf (an “authorized agent”), may make the requests set forth above. Authorized agents may submit requests using one of the methods set forth above. If you use an authorized agent to make request, you must provide the authorized agent written permission to do so, and we may require that you verify your identity directly with us and directly confirm that you provided the authorized agent permission to submit the request. You may also make a request on behalf of your minor child.
The request should include your contact information and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. In addition, you should provide sufficient information (including name and email address) that allows us to reasonably verify that you are the person about whom we collected the personal information or an authorized representative.
Making a request does not require you to create an account with us. However, we may consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. If you maintain an account with us, you are required to submit your request through that account.
For more information about verification, see Response Timing and Format.
Response Timing and Format:
We will respond to consumer requests in a reasonably timely manner. If we require extra time to respond, we will inform you of the reason and extension period in writing.
In order to protect the security of your personal information, we will not honor a request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. The method used to verify your identity will vary depending on the nature of the request. Generally speaking, verification will be performed by matching the identifying information provided by you to the personal information that we already have.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. We are not obligated to provide the information set forth above under Right to Know About Personal Information Collected, Disclosed or Sold more than twice in a 12-month period.
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.
Non-Discrimination:
We will not discriminate against you for exercising any of your CCPA rights, including, but not limited to, by:
-Denying you goods or services
-Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties that are not reasonably related to the value of your personal information
-Providing you a different level or quality of goods or services that is not reasonably related to the value of your personal information
-Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services
Nevada Privacy Rights:
If you are a Nevada resident, you have the right to request that we do not sell your covered information (as those terms are defined in N.R.S. 603A) that we have collected, or may collect, from you. We do not sell your covered information, however, if you would like to make such a request you may do so by contacting us at TeamRA@RoxanneAssoulin.com.
Additional EU Disclosures:
Data controller:
Maurice Max Inc. is the data controller of all personal data collected through our Website. To contact us, please see the section titled “Contact Us”.
If you are situated in the EU and have any complaints regarding our privacy practices, you have the right to make a complaint at any time to your local Supervisory Authority. We would, however, appreciate the chance to deal with your concerns before you approach your Supervisory Authority so please contact us in the first instance. If you have a complaint, please contact our privacy manager at: TeamRA@RoxanneAssoulin.com.
Legal Basis:
We will only use your personal data as defined by the EU General Data Protection Regulation (“GDPR”) when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
-Where we need to perform the contract we are about to enter into or have entered into with you.
-Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
-Where you have consented to a certain use of your personal data.
-Where we need to comply with a legal or regulatory obligation.
To the extent permitted under applicable laws, we will also process, transfer, disclose and preserve personal data when we have a good faith belief that doing so is necessary.
Provision of personal data and failure to provide personal data:
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we will not be able to provide services to you.
Information from third parties sources or publicly available sources. We work with Shopify to assist us with your sale and refund procedures.
Withdrawing your consent:
If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time. You have the right to withdraw your consent at any time by contacting us at TeamRA@RoxanneAssoulin.com.
Data Transfer:
We may transfer personal data from the EU to the USA and other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. If we transfer personal data outside the EU to a processor, such transfer will be in compliance with the requirements of the GDPR.
Use of your personal data for marketing purposes:
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
-Promotional offers from us: We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or used our services and, in each case, you have not opted out of receiving that marketing.
-Third-party marketing: We will get your express opt-in consent before we share your personal data with any company outside our company for their marketing purposes.
To see how you can opt out of marketing communications, please see the section titled “Opt-Out”.
Data Subject Rights:
If you are a situated in the EU, under the GDPR as a data subject you have the following rights:
-Request access to your personal data (commonly known as a "data subject access request").
-Request correction of the personal data that we hold about you.
-Request erasure of your personal data.
-Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
-Request restriction of processing of your personal data in certain situations.
-Request the transfer of your personal data to you or to a third party in certain situations.
-Withdraw consent at any time where we are relying on consent to process your personal data.
To exercise your rights under the GDPR, please contact us at TeamRA@RoxanneAssoulin.com
Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have.
Website Terms and Conditions:
Use of this Website is governed by, and subject to, the legal notices contained at “Term and Conditions”. Your use, or access, of the Website constitutes your agreement to be bound by these provisions.
Contact:
For questions or concerns relating to privacy, we can be contacted at: TeamRA@RoxanneAssoulin.com.
Site Maintenance:
Our Website is maintained in the United States of America. Subject to the subsection “Data Transfer” in the section titled “Additional EU Disclosures”, by using the Website, you authorize the export of your information to the USA and its storage and use as specified in this policy.