Last Modified: [April 20th, 2018]
This Privacy Statement explains how ZoeTop Business Co., Limited (collectively, “ROMWE,” “we,” “us,” or “our”) collect, use, share and process your information.
Click on the links below to go to a specific section of this Privacy Statement.
- Collection and Use of Personal Data
- Cookies and Similar Technologies
- Disclosure of Personal Data
- Your Rights
- Closing Accounts
- Third-Party Websites and Services
- Data Security, Integrity, and Retention
- Data Transfers, Storage, and Processing Globally
- Changes to This Privacy Statement
- Contact Us
Collection and Use of Personal Data
Personal data is information that can be used to directly or indirectly identify you. Personal data also includes anonymous data that is linked to information that can be used to directly or indirectly identify you. Personal data does not include data that has been irreversibly anonymized or aggregated so that it can no longer enable us, whether in combination with other information or otherwise, to identify you.
Here is a description of the types of personal data we may collect and how we may use it:
What Personal Data We Collect
Depending on the products and services you use, we collect different kinds of personal data from or about you.
- Data you provide: We collect the personal data you provide when you use our products and services or otherwise interact with us, such as when you create an account, Contact Us, participate in an online survey, use our online help or online chat tool.
- Data about payments: If you make a purchase, we collect personal data in connection with the purchase. This data includes your payment data, such as your credit or debit card number and other card information, and other account and authentication information, as well as billing, shipping, and contact details.
- Data about use of our services and products: When you visit our websites, we may collect data about the type of device you use, your device’s unique identifier, the IP address of your device, your operating system, the type of Internet browser that you use, usage information, diagnostic information, and location information from or about the computers, phones, or other devices on which you install or access our products or services. Where available, our services may use GPS, your IP address, and other technologies to determine a device’s approximate location to allow us to improve our products and services.
How We Use Your Personal Data
Generally speaking, we use personal data to provide, improve, and develop our products and services, to communicate with you, to offer you targeted advertisements and services, and to protect us and our customers.
ZoeTop Business Co., Limited, processes and determines how to process your personal data as data controller for the following purposes:
- Providing, improving, and developing our products and services: We use personal data to help us provide, improve, and develop our products, services, and advertising. This includes using personal data for purposes such as data analysis, research, and audits. Such processing is based on our legitimate interest in offering you products and services and for business continuity. If you enter a contest, or other promotion, we may use the personal data you provide to administer those programs. Some of these activities have additional rules, which may contain further data about how we use personal data, so we encourage you to read those rules carefully before participating.
- Communicating with you: Subject to your prior express consent, we may use personal data to send you marketing communications in relation to ROMWE own products and services, communicate with you about your account or transactions, and inform you about our policies and terms. If you no longer wish to receive email communications for marketing purposes, please Contact Us to opt-out. We also may use your data to process and respond to your requests when you contact us. Subject to your prior express consent, we may share your personal data with third party partners who may send you marketing communications in relation to their products and services.
- Offering and measuring targeted advertisements and services: Subject to your prior express consent, we may use personal data to personalize your experience with our products and services and on third-party websites and applications and to determine the effectiveness of our promotional campaigns.
For any of the uses of your data described above that require your prior express consent, note that you may withdraw your consent by contacting ZoeTop Business Co., Limited.
- Promoting safety and security: We use personal data to help verify accounts and user activity, as well as to promote safety and security, such as by monitoring fraud and investigating suspicious or potentially illegal activity or violations of our terms or policies. Such processing is based on our legitimate interest in helping ensure the safety of our products and services.
Cookies and Similar Technologies
You can remove or reject cookies using your browser or device settings, but in some cases doing so may affect your ability to use our products and services.
Disclosure of Personal Data
We make certain personal data available to strategic partners that work with us to provide our products and services or help us market to customers. Personal data will only be shared by us with these companies in order to provide or improve our products, services, and advertising; it will not be shared with third parties for their own marketing purposes without your prior express consent.
We share personal data with companies that provide services on our behalf, such as website hosting, email services, marketing, sponsoring of sweepstakes, contests, and other promotions, auditing, fulfilling customer orders, data analytics, providing customer service, and conducting customer research and satisfaction surveys. These companies are obligated to protect your data and may be located wherever we operate.
Corporate Affiliates and Corporate Business Transactions
We may share personal data with all ZoeTop Business Co., Limited-affiliated companies. In the event of a merger, reorganization, acquisition, joint venture, assignment, spin-off, transfer, or sale or disposition of all or any portion of our business, including in connection with any bankruptcy or similar proceedings, we may transfer any and all personal data to the relevant third party.
Legal Compliance and Security
It may be necessary—by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence—for us to disclose personal data. We may also disclose personal data if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.
We may also disclose personal data if we determine in good faith that disclosure is reasonably necessary to protect our rights and pursue available remedies, enforce our terms and conditions, investigate fraud, or protect our operations or users.
Legal Basis For The Processing of Personal Data from EEA Residents
If you reside within the European Economic Area (EEA), our processing of your personal data will be legitimized as follows: Whenever we require your consent for the processing of your personal data such processing will be justified pursuant to Article 6(1) lit. (a) of the General Data Protection Regulation (EU) 2016/679 (“GDPR”). If the processing of your personal data is necessary for the performance of a contract between you and us or for taking any pre-contractual steps upon your request, such processing will be based on GDPR Article 6(1) lit. (b). Where the processing is necessary for us to comply with a legal obligation, we will process your data on basis of GDPR Article 6(1) lit. (c), and where the processing is necessary for the purposes of our legitimate intere