Privacy Policy

Updated: January 10, 2022

AT JOSEPH RIBKOFF INC.’S (“JOSEPH RIBKOFF”, or “THE COMPANY”) ENTIRE DISCRETION, WE RESERVE THE RIGHT TO CHANGE THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY FROM TIME TO TIME. BEFORE EACH USE OF THE WEBSITE, YOU HAVE THE RESPONSIBILITY OF CHECKING THAT YOU STILL WISH TO BE BOUND BY ITS TERMS AND CONDITIONS.

Joseph Ribkoff is committed to preserving and safeguarding your right to privacy. As part of this commitment, the Company wants you to be fully aware of what happens to the personal information it collects through your use of this website (the “Website”). Accordingly, this Website Privacy Policy sets out the manner in which Joseph Ribkoff will collect, use, disclose and otherwise manage your personal information.

COLLECTION OF PERSONAL INFORMATION

The Company currently does not request or require you to provide any personal information to use the Website. It will, however, collect the personal information you voluntarily provide via the Website; such as: when you voluntarily provide personal information via its website link “Sign up to our Newsletter” located on the home page in order to obtain marketing and sales information, or when you voluntarily provide personal information via its Website link “Contact Us” page - as well when you contact the Company by phone, when requesting any information about its products or providing feedback about its Website. More specifically, the personal data we collect with respect to information you voluntarily provided includes the below items, and is considered “Personal Data”.

The Company collects your:

• Country of residence

• Permission to opt-in to e-mail and phone communication

• First name

• Last name

• E-mail address

• Phone number

• Any message you provide via a text input field

• preferred language of communication

The Company may also automatically collect general anonymous information related to your use of its Website, such as the date and time you visit the Website and the pages you visit on the Website, where you are located, or your country.

For details of the cookies employed by the Company, please see our Cookie Policy, which forms part of this Privacy Policy

USE AND DISCLOSURE OF PERSONAL INFORMATION

The Company uses Usage Data and Personal Data to provide you with the information you have requested via its Website link “Sign up to our Newsletter” located on the home page, as well as any information about its product which you have submitted via its Website “Contact Us” page or by phone.

Moreover, the Company may use Usage Data and Personal Data

• to understand and analyze the usage trends and preferences of our users, to improve the Services, and to develop new products, services, feature, and functionality.

• to send you communications, notably commercial information.

• to comply with legal and regulatory requirements, where applicable

Internally, only employees who need access to your Personal Data and Usage Data for the execution of their duties will have access to it. The Company may also share your Usage Data and Personal Data, including:

• within the Joseph Ribkoff’s family of companies, which includes parents, corporate, affiliates, subsidiaries, business units and other companies that share common ownership.

• with third-party service providers working on behalf of the Company, such as:

  • Google: advertisements, analytics and retargeting. Click here to see their privacy policy

  • Facebook: advertisements, analytics and retargeting. Click here to see their privacy policy

  • MailChimp: e-mail marketing and retargeting. Click here to see their privacy policy

  • Third-party companies mandated to develop and maintain the Website

• to law enforcement authorities, or on court demand, request from regulators, government obligations/requests.

In the event of a change of ownership, sale, merger, liquidation, reorganization or acquisition of Joseph Ribkoff, in whole or in part, your information may be transferred as part of the transaction, as long as, the party acquiring such information agrees to be bound by the terms of this Privacy Policy.

When Joseph Ribkoff discloses your personal information to third parties, the Company takes reasonable measures to ensure that the rules set forth in this Privacy Policy are complied with and these third parties provide sufficient guarantees to implement appropriate technical and organizational measures.

Joseph Ribkoff will also retain your Personal Data as necessary to comply with its legal obligations, resolve disputes, and enforce its agreements.

THIRD PARTY LINKS

By browsing this Website, you will be able to access links and references to other websites. Those links and references are provided to you for convenience purposes only. The Company does not warrant that the information and/or material contained in those links, or the accessibility thereof, is accurate and exhaustive. The Company assumes no responsibility whatsoever for any such outside websites, or for the information or material posted thereon, nor does it assume any responsibility for products or services offered thereon. Unless the Company has expressly authorized you to do so in writing, you may not create links from other websites to this Website.

For details of the cookies employed by the Company, please see our Cookie Policy, which forms part of this Privacy Policy.

YOUR RIGHTS IN RELATION TO PERSONAL DATA

You have the right to access and to rectify your Personal Data, where necessary, as authorized or required by law. However, to make sure that the Personal Data the Company maintains about you is accurate and up to date, please inform Joseph Ribkoff immediately of any change in your personal information.

You can exercise these rights, with a proof of your identity, by simple written request sent by email to privacy@ribkoff.com.

Or by mail at the following address:

Joseph Ribkoff Inc.

2375 De L’Aviation

Dorval, Quebec, Canada

H9P 2X6

If your request is not sufficiently precise or does not include all elements enabling us to answer your request, the Company may ask you to provide additional elements.

If you are located in the European Economic Area (EEA), please see your rights in relation to personal information below.

SECURITY OF PERSONAL INFORMATION

Joseph Ribkoff will maintain your Personal Data and Usage Data in secure data storage to safeguard it from unauthorized access, and will be used, disclosed or retained only for as long as necessary to fulfill the purposes for which that personal information was collected, as permitted or required by law and to comply with its legal obligations, resolve disputes, and enforce our agreements. If you would like more information on the periods during which your personal information will be kept, please contact us using the contact details in the “Contact Us” section below.

STORAGE AND LOCATION OF PERSONAL INFORMATION

Your Personal Data and Usage Data may be stored and processed in any country where Joseph Ribkoff has facilities or in which Joseph Ribkoff engages third party service providers. By using the Services, you consent to the transfer of information to countries outside your country of residence, which may have different data protection rules than in your country. While such information is outside of Canada, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. However, Joseph Ribkoff’s practices regarding your personal information will at all times continue to be governed by this Privacy Policy and, if applicable, and where appropriate, we will comply with the General Data Protection Regulation (“GDPR”) requirements regarding the transfer of personal information.

OPTING OUT OF COMMUNICATIONS 

If you no longer want to receive marketing-related emails from Joseph Ribkoff, you may opt-out of receiving marketing-related emails by clicking the “unsubscribe” link at the bottom of any email you receive from us, or, if you created an online account when you registered to receive Joseph Ribkoff emails, you may log-in to your account and make changes to your communication.  You may also opt-out by contacting us directly using the contact information in the “Contact Us” section below.

We will endeavour to respond to your opt-out request promptly but ask that you please allow a reasonable time to process your request.  Please note that if you opt-out from receiving marketing-related emails, we may still need to send you communications about your use of our products or services, or other matters.

FOR EU/ European Economic Area (EEA) USERS

The Company uses, processes, and stores Personal Data, including the data listed in the “COLLECTION OF PERSONAL INFORMATION” section above based on our legitimate interests for the purposes of monitoring and improving the use and features of the Website, and provide you with the information you have requested or have signed up for. We rely on your consent to process Personal Data to send promotional emails and to place cookies on your devices as defined in the “COLLECTION OF PERSONAL INFORMATION” section noted above. In some cases, the Company may process Personal Data pursuant to legal obligation.

If you’re accessing the Company’s website from the EU, your Personal Data is governed by the General Data Protection Regulation, or “GDPR”. On May 25, 2018, the GDPR replaced the Data Protection Law (which was in effect since 1999). The GDPR was developed by the European Parliament and Council to protect data rights of EU citizens. Any company that does business transactions with EU citizens or collects or processes data of EU citizens must comply with this legislation.

Why is it important? GDPR has been put in place to make people more informed and put them in control of how businesses collect, use, share, secure and process their Personal Data. The legislation’s main aim is to make privacy policies clear and comprehensive to customers.

The GDPR requires disclosure of the below elements, and beside each element, we have provided you with the relevant answer.

1-Who is processing your data?

JOSEPH RIBKOFF INC., 2375 de l'Aviation, Dorval, Quebec, Canada, H9P 2X6, (514) 685-9191, 1(800) 361-1839, privacy@ribkoff.com   

2-What legal basis allows us to collect your data?

• The Company processes Personal Data based on your consent, which you are free to give or refuse, notably in order to send you communications, notably commercial information. A consent option will be available when visiting our website for the first time;

• Joseph Ribkoff’s legitimate interests in order to understand and analyze the usage trends and preferences of users, to improve the Services, and to develop new products, services, feature, and functionality;

• Compliance with a legal obligation, notably to comply with legal and regulatory requirements, where applicable.

3-What types of personal data do we collect?

We collect the information identified above as “Personal Data, as well as Usage Data”.

4-How long do we store your data for?

Joseph Ribkoff will maintain your Personal Data and Usage Data for as long as a business need exists, or as required by applicable laws, regulations, or government orders.

5-Do we transfer your data internationally?

We do not directly transfer your data internationally, but the third-party data processors we use, such as Facebook and Google, have servers all around the world. For more information, please refer to section “STORAGE AND LOCATION OF PERSONAL INFORMATION”.

6-With what third parties do we share your data with?

Currently we share data with:

• Google: analytics for website tracking.

• MailChimp: e-mail.

For more information, please refer to section “USE AND DISCLOSURE OF PERSONAL INFORMATION”.       

7- What are your data subject rights?

GDPR also requires us to tell our users about their rights, which are:

• The right to be informed: You have the right to request information about the personal data we hold about you at any time.

The right of access: Request a Personal Data report by submitting a request through privacy@ribkoff.com. This report will include the Personal Data we have about you.

• The right to rectification & the right to erasure: Upon obtaining the Personal Data we have on you, you can have the data corrected or where applicable and subject to the Personal Data we are required to retain to meet our compliance obligations, deleted.

• The right to restrict processing: You can, subject to our requirements to meet our compliance obligations, ask us to restrict the processing if you believe Joseph Ribkoff has exceeded the legitimate basis for processing or if the processing is no longer necessary.

• The right to data portability: Whenever the Company processes your Personal Data by automated means based on your consent, you have the right to get a copy of your data transferred to you. This only includes the personal data you have submitted to us.

• The right to object: If you’re based in the EEA and think that we haven’t complied with data protection laws, you have a right to lodge a complaint with your local supervisory authority.

• The right to withdraw consent to processing where consent is the basis of processing.

• The right object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you, under certain conditions.

• The right to lodge a complaint with data protection authorities.

If you want to know more about your rights, contact Joseph Ribkoff as mentioned in the Contact section.

PERSONAL INFORMATION OF MINOR PERSON

Minor persons should not use this site, as we do not market to children. If you are a minor under the laws applicable to your place of residence, please do not submit to us any Personal Data without the express consent of a parent or guardian. We do not collect personal information online from minor persons.

UPDATE

The Company reserves the right to change this Policy at any time. You will be notified of such changes through disclosure on the Website. If at any point the Company decides to use personal information in a manner different from that stated at the time it was collected, users will have a choice as to whether it uses their information in this different manner.

Last update: see the top of the page.

CONTACT US

If you have any inquiries or comments about this Website Privacy Policy, please contact us at privacy@ribkoff.com.

PRIVACY STATEMENT-CALIFORNIA

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of Joseph Ribkoff Inc. and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or device (“personal information”). We have collected the following categories of personal information from consumers within the last twelve (12) months:

 

Personal information does not include:

• Publicly available information from government records.

• De-identified or aggregated consumer information.

• Information excluded from the CCPA's scope, like:

  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, when you sign up to receive our newsletter.

• Indirectly from you. For example, from observing your actions on our website or interactions with our advertisers.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provide the information. For example, if you shared your name and contact information to request to receive our newsletter, we will use that personal information to send you our newsletter.

• To provide you with information that you request from us.

• To provide you with email alerts, event registrations and other notices concerning our products, or events or news, that may be of interest to you.

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.

• To improve our website and present its contents to you.

• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

• As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has not disclosed personal information for a business purpose.     

Sales of Personal Information

In the preceding twelve (12) months, the Company had not sold personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.

• The categories of sources for the personal information we collected about you.

• Our business or commercial purpose for collecting or selling that personal information.

• The categories of third parties with whom we share that personal information.

• The specific pieces of personal information we collected about you (also called a data portability request).

• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

  • sales, identifying the personal information categories that each category of recipient purchased; and

  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3. Debug products to identify and repair errors that impair existing intended functionality.

4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 ).

6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

8. Comply with a legal obligation.

9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at 1-800-361-1839, or emailing us at: privacy@ribkoff.com

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

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.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following our webpage and sending us a message.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by visiting our website and sending us a message. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

• Provide you a different level or quality of goods or services.

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: (514) 685-9191, 1-800-361-1839

Website: www.josephribkoff.com
Email: privacy@ribkoff.com

Postal Address:

JOSEPH RIBKOFF INC., 2375 de l'Aviation, Dorval, Quebec, Canada, H9P 2X6,
Attn: VP Marketing or Legal Affairs