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Orveda Privacy Policy and Notice at Collection
Last modified April 12, 2023
Your privacy is important to Orveda and we are committed to protecting your personal information. Orveda is a wellbeing beauty brand specializing in cosmetic products which are cruelty free, vegan, gluten free, paraben and sulfate free and suitable for all skin types. This website, is operated by Coty DTC Holdings, LLC operates the Website and sells goods and services, (“Orveda”, “we” or “us”) located at address is 350 5th Avenue, 19th Floor, New York, NY 10118-0110. Our contact email address is concierge@orveda.com.
This Privacy Policy and Notice at Collection (“Notice”) relates to our use of your personal information when you:
This Notice explains who we are; what personal information we collect about you; how we use it (including who we share that personal information with) and your rights and choices regarding your personal
This website is not directed to or meant for use by residents of the United Kingdom (“UK”), France, Germany, or other European Union country. If you are a resident of these jurisdictions, please visit our jurisdiction specific websites at the following links respectively:
For the United Kingdom: https://uk.orveda.com
For France, Germany or other European Union Country: https://eu.orveda.com
We collect information that identifies, describes, or is reasonably capable of being associated with you (“personal information”). The following discusses the categories of personal information we collect and have collected in the preceding 12 months, the sources we collect information from, and the business or commercial purposes use of your personal information.
To provide you with products and services we may collect:
In connection with a skin consultation we may collected and process:
To process payments we may collect and process:
To perform analytics we may collect and process:
To provide marketing communications we may collect and process:
To provide tailored advertising we may collect and process:
If you would like more information about Advertisers’ practices, please see http://optout.aboutads.info/#!/. You can generally opt-out of receiving personalized ads from third-party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising (DAA) by visiting the opt-out pages on the NAI website (http://optout.networkadvertising.org) and DAA website (http://www.aboutads.info/choices/).
To provide SMS communications we may collect and process:
To provide non-marketing communications we may collect and process:
To support site optimization and management we may collect and process:
Use of Non-Personally Identifiable Information
We may use non-personally identifiable information, such as anonymized and/or aggregated Services usage data, in any manner that does not identify individual users for the purpose of improving the operation and management of the Services, including to develop new features, functionality, and services, to conduct internal research, to better understand usage patterns, to resolve disputes, to troubleshoot problems, to fulfill user requests, or for security and compliance purposes. Any non-personally identifiable information that is combined with personal information will be treated by us as personal information.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the business purpose which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may disclose personal information about you 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. In the preceding twelve (12) months, we have disclosed we categories of third parties indicated in the chart below.
We may sell or share personal information about you to third parties, subject to your right to opt-out of those sales. Our personal information sales do not include information about individuals we know are under age 16. In the preceding twelve (12) months, Orveda has sold the following categories of personal information to the categories of third parties indicated in the chart below. To opt-out of personal information sales or sharing, contact the Orveda Concierge.
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|
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Categories of Service Providers or Third Parties |
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Personal Information Category |
Business Purpose Disclosures |
Sales
|
Sharing and Disclosure |
|
Identifiers |
Payment processing, marketing, delivery services, customer relationship management, web hosting, or data storage
|
None |
Application Service Providers, Financial Service Providers, Website Hosting and/or IT Consultancy Service Providers, Marketing and promotion service providers, Data analysis service providers, Security Service Providers
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Account information
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Marketing, customer relationship management, or data storage
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None |
Application Service Providers, Financial Service Providers, Website Hosting and/or IT Consultancy Service Providers, Marketing and promotion service providers, Data analysis service providers, Security Service Providers
|
|
Protected Classification Characteristics and Sensitive personal information
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Include but are not limited to race, age, marital status, religion, sexual orientation, gender identity and military or veteran status |
None |
Financial service providers, such as independent agents, brokerage firms, and insurance companies Website hosting or information technology consulting service providers Marketing and promotion service providers Data analysis service providers Legal service providers Accounting service providers Administrative service providers Security service providers Application service providers
|
|
Communications |
Customer relationship management, or data storage
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None
|
Financial service providers, such as independent agents, brokerage firms, and insurance companies Website hosting or information technology consulting service providers Marketing and promotion service providers Data analysis service providers Legal service providers Accounting service providers Administrative service providers Security service providers Application service providers
|
|
Internet network activity |
Marketing, delivery services, customer relationship management, web hosting, or data storage
|
Remarketing, retargeting, and advertising providers |
Application service providers, Website hosting or information technology consulting service providers, Marketing and promotion service providers, Data analysis service providers, Legal service providers, Accounting service providers, Administrative service providers, Security service providers
|
|
Geolocation information |
Marketing, customer relationship management, web hosting, or data storage |
Remarketing, retargeting, and advertising providers |
Application Service Providers, Accounting Service Providers, Financial Service Providers, Website or Hosting Service Providers, Marketing and promotion service providers, Data analysis service providers. |
We retain personal information in identifiable form only for as long as necessary to fulfill the purposes for which the personal information was provided to us or, if longer, to comply with legal obligations, to resolve disputes, to enforce agreements and similar essential purposes. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
We are required to satisfy one or more of the reasons set out by applicable data privacy law before we can collect and use your personal information.
Generally, our business purpose for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally rely on the following reasons to collect and use your personal information:
Using your information may be necessary for us to perform our obligations under a contract with you or with a view to entering into such a contract. For example, where you have: (i) purchased services and/or products from us, we will need to use your information to provide those services and/or products; or (ii) approached us in relation to employment opportunities, the collection and use of your personal information is necessary to enable us to offer you the job role, process your acceptance of the offer, on-board you as an employee and fulfil our obligations as an employer.
The collection and use of your personal information may be necessary to enable us to meet our legal obligations. For example, to verify your identity and undertake necessary due diligence checks.
Where such processing is not overridden by your interests or fundamental rights, we are permitted to use your personal information where it is necessary in order to pursue our legitimate interests, for example to operate the website and our other digital offerings, to improve our products and services, content and our other digital offerings or to undertake marketing. We may have other legitimate interests and if appropriate we will make this clear to you at the relevant time.
In some limited circumstances, we may rely on your consent to collect and use your personal information. For example, we may rely on consent: (i) where you have approached us in relation to employment opportunities and have provided us with sensitive personal information, such as information in relation to your racial and ethnic origin, sexual orientation, religion, physical and mental health, disabilities or trade union membership; or (ii) in relation to the sending of e-marketing or communications.
In some instances, we may need to use your personal information to protect your vital interests or those of another person.
You may not always be required to provide the personal information that we have requested. However, if you choose not to provide certain information, you may not be able to take advantage of some of our services. Any information that is so required is clearly marked as mandatory. If you would prefer that we not collect certain personal information from you, please do not provide us with any such information, or opt out of providing this information where applicable.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), these interests will normally be as set out in this Notice; however, if this changes we will make clear to you at the relevant time what those legitimate interests are.
If you have any questions or need further information concerning the business purpose on which we collect and use your personal information, please contact us using the contact details provided in the section below marked “How do I contact Orveda?"
In addition to the third parties identified under the “Do we Sell or Share Personal Information” section, during the past 12 months, we may have disclosed the categories of personal information listed in the section marked “what categories of personal information does Orveda collect about me?” to the following categories of recipients:
State consumer privacy laws may provide their residents with additional rights regarding our use of personal information. The following Section applies to individuals who reside in specific jurisdictions that provide additional privacy rights, including California, Virginia, Colorado, Connecticut, and Utah.
6.1 Your Rights and Choices
Right to Access Specific Information and Data Portability Right. You have the right to request that we disclose certain information to you about our collection and use of personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
Right to Correct Information. You have the right to request we update personal information about you that is incorrect in our systems.
Right to Delete. You have the right to request that we delete any personal information about you 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) the personal information from our records, unless an exception applies.
Right to Opt-out of the sale or sharing of Personal Information for Cross-Contextual Behavioral Advertising.
Residents of California, Colorado, Connecticut, Virginia and Utah have or will soon have the right to opt-out of certain data sharing and usage arrangements, and may do so by either:
Right to Limit Sensitive Personal Information Use. You have the right to limit the use of sensitive personal information regarding you.
Non-Discrimination. We will not discriminate against you for exercising any of your rights.
6.2 How to Exercise these Rights
To submit a request to exercise these rights you may use one of these three methods:
For all requests, please clearly state that the request is related to “Your Privacy Rights,” indicate which type of request you are making, and provide your name, street address, city, state, zip code and an e-mail address or phone number where we may contact you. We are not responsible for notices that are not labeled or sent properly or that do not include complete information.
To appeal a decision regarding a consumer rights request, please submit your appeal using one of the three methods above. Your appeal should include an explanation of the reason you disagree with our decision. Within 60 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
Only you, or a person registered with the applicable Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to personal information about you. You may also make a verifiable consumer request on behalf of your minor child.
You may only make such a 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 and 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.
We endeavor to respond to a verifiable consumer request within forty-five (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. We will deliver our written response electronically. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request. 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 the personal information that is readily usable 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.
6.3 Opt-out Preference Signals
Through your browser configuration, our website honors your opt-out preference signal.
You can get further help in configuring your browser by visiting: https://globalprivacycontrol.org/
6.4 Personal Information Sales Opt-Out
If you are age 16 or older, you have the right to direct us to not sell personal information about you 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 old, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 15 years old, or the parent or guardian of a consumer less than 13 years old. 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 Internet Web page link:
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.
The website may contain links to or from third party sites. Please be aware that we are not responsible for the privacy practices of such third parties. This Notice applies only to the personal information we collect as described above. We encourage you to read the privacy policies of third-party sites you access from links on the website or otherwise visit.
We will only send you marketing communications if you have agreed to this, or if we are otherwise permitted by law. If at any time you decide that you no longer wish to receive marketing communications from us, you may opt out by clicking on the relevant ‘unsubscribe’ link in the emails you receive, by texting STOP in response to any text message or by contacting us using the details found in the section “How do I contact Orveda”.
Please note, while we will honor your request to stop receiving marketing communications, we will continue to send you service-related communications such as emails confirming purchases through the website.
In order to provide our services, we may need to transfer and process your personal information internationally (including to destinations outside the country in which you are located).
As a result, your information may be transferred to and/or processed in countries which may not guarantee the same level of protection for personal information as the country in which you reside. However, we have taken appropriate safeguards to ensure that your personal information will remain protected in accordance with this Notice.
Further information can be provided on request: please contact us using the details found in the section “How do I contact Orveda?" We have also implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.
We understand that you care how your personal information is used and/or shared with others, and we value your trust and seek to safeguard your personal information.
We implement appropriate technical and organizational security measures, including physical, administrative and technical safeguards to protect your personal information from unauthorized access, use and disclosure.
The measures we use to protect your personal information are designed to provide a level of security appropriate to the risk of processing your personal information. However, please be aware that no electronic transmission of information can be entirely secure. We cannot guarantee that the security measures that we have in place to safeguard personal information will never be defeated or fail, or that those measures will always be sufficient or effective.
Orveda and its preferred third-party service providers or business partners may offer sweepstakes, contests, promotions and surveys (each, a “Promotion”).
Where we do this, we will use your personal information as set out in this Notice, or as otherwise notified to you. However, in certain cases, a third party’s privacy policy may apply to any personal information that you provide in connection with such Promotion. Before entering any Promotion, we encourage you to check who is operating the Promotion in question, and the terms, conditions, policies and rules that apply to it.
You must be aged 13 or over to use the Orveda sites and our other digital offerings.
We take your privacy very seriously and we understand the importance of taking extra precautions to protect the privacy and safety of children who use our products and services. We do not solicit or knowingly collect personal information from children aged 13 and under. If we are made aware that we have received such information, or any information in violation of our policy, we will use reasonable efforts to locate and remove that information from our records.
California Minors: If you are a California resident who is under age 18 and you are unable to remove publicly-available content that you have submitted to us, you may request removal by contacting us at: concierge@orveda.com. When requesting removal, you must be specific about the information you want removed and provide us with specific information, such as the URL for each page where the information was entered, so that we can find it. We are not required to remove any content or information that: (1) federal or state law requires us or a third party to maintain; (2) was not posted by you; (3) is anonymized so that you cannot be identified; (4) you don’t follow our instructions for removing or requesting removal; or (5) you received compensation or other consideration for providing the content or information. Removal of your personal information from the Services does not ensure complete or comprehensive removal of that content or information from our systems or the systems of our service providers. We are not required to delete the content or information posted by you; our obligations under California law are satisfied so long as we anonymize the content or information or render it invisible to other users and the public.
We may update or modify this Notice from time to time in response to changing legal, technical or business developments. We will obtain your consent to any material Notice changes if and where this is required by applicable data protection laws. The date of the most recent version of this Notice will appear at the top of the page.
When we update our Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. for example, we will notify you of any changes to this Notice by posting a new Notice and updating the “last modified" date at the top of this page or by sending the new Notice to you via email, where appropriate.
We have taken great measures to ensure that your visit to the website is an excellent one and that your privacy is respected. If you have any questions, comments, or concerns about our privacy practices and/or would like to submit a privacy request, please contact us either:
California Shine the Light Law
California Civil Code Section 1798.83 permits users who are California residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed personal information (if any) for direct marketing purposes in the preceding calendar year. If you are a California resident and you wish to make such a request, please send an e-mail with “California Privacy Rights” in the subject line to concierge@orveda.com or write us at: Coty DTC Holdings, LLC, Attn: Privacy Inquiries, at 350 5th Avenue, 19th Floor, New York, NY 10118-0110
Contact Information
If you have any questions or comments about this notice, the ways in which we collect and use your information described in this Notice, or your choices and rights regarding such use please do not hesitate to contact us at
Phone - 1-833-7ORVEDA (1- 833-767-8332) +44 808 196 0312 (UK) +33 1 86 47 22 86 (FR)
E-mail - concierge@orveda.com
Postal Address - Coty DTC Holdings, LLC, Attn: Privacy Inquiries, 350 5th Avenue, 19th Floor, New York, NY 10118-0110
Orveda Privacy Policy and Notice at Collection
Last modified April 12, 2023
Your privacy is important to Orveda and we are committed to protecting your personal information. Orveda is a wellbeing beauty brand specializing in cosmetic products which are cruelty free, vegan, gluten free, paraben and sulfate free and suitable for all skin types. This website, is operated by Coty DTC Holdings, LLC operates the Website and sells goods and services, (“Orveda”, “we” or “us”) located at address is 350 5th Avenue, 19th Floor, New York, NY 10118-0110. Our contact email address is concierge@orveda.com.
This Privacy Policy and Notice at Collection (“Notice”) relates to our use of your personal information when you:
This Notice explains who we are; what personal information we collect about you; how we use it (including who we share that personal information with) and your rights and choices regarding your personal
This website is not directed to or meant for use by residents of the United Kingdom (“UK”), France, Germany, or other European Union country. If you are a resident of these jurisdictions, please visit our jurisdiction specific websites at the following links respectively:
For the United Kingdom: https://uk.orveda.com
For France, Germany or other European Union Country: https://eu.orveda.com
We collect information that identifies, describes, or is reasonably capable of being associated with you (“personal information”). The following discusses the categories of personal information we collect and have collected in the preceding 12 months, the sources we collect information from, and the business or commercial purposes use of your personal information.
To provide you with products and services we may collect:
In connection with a skin consultation we may collected and process:
To process payments we may collect and process:
To perform analytics we may collect and process:
To provide marketing communications we may collect and process:
To provide tailored advertising we may collect and process:
If you would like more information about Advertisers’ practices, please see http://optout.aboutads.info/#!/. You can generally opt-out of receiving personalized ads from third-party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising (DAA) by visiting the opt-out pages on the NAI website (http://optout.networkadvertising.org) and DAA website (http://www.aboutads.info/choices/).
To provide SMS communications we may collect and process:
To provide non-marketing communications we may collect and process:
To support site optimization and management we may collect and process:
Use of Non-Personally Identifiable Information
We may use non-personally identifiable information, such as anonymized and/or aggregated Services usage data, in any manner that does not identify individual users for the purpose of improving the operation and management of the Services, including to develop new features, functionality, and services, to conduct internal research, to better understand usage patterns, to resolve disputes, to troubleshoot problems, to fulfill user requests, or for security and compliance purposes. Any non-personally identifiable information that is combined with personal information will be treated by us as personal information.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the business purpose which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may disclose personal information about you 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. In the preceding twelve (12) months, we have disclosed we categories of third parties indicated in the chart below.
We may sell or share personal information about you to third parties, subject to your right to opt-out of those sales. Our personal information sales do not include information about individuals we know are under age 16. In the preceding twelve (12) months, Orveda has sold the following categories of personal information to the categories of third parties indicated in the chart below. To opt-out of personal information sales or sharing, contact the Orveda Concierge.
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Categories of Service Providers or Third Parties |
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Personal Information Category |
Business Purpose Disclosures |
Sales
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Sharing and Disclosure |
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Identifiers |
Payment processing, marketing, delivery services, customer relationship management, web hosting, or data storage
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None |
Application Service Providers, Financial Service Providers, Website Hosting and/or IT Consultancy Service Providers, Marketing and promotion service providers, Data analysis service providers, Security Service Providers
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Account information
|
Marketing, customer relationship management, or data storage
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None |
Application Service Providers, Financial Service Providers, Website Hosting and/or IT Consultancy Service Providers, Marketing and promotion service providers, Data analysis service providers, Security Service Providers
|
|
Protected Classification Characteristics and Sensitive personal information
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Include but are not limited to race, age, marital status, religion, sexual orientation, gender identity and military or veteran status |
None |
Financial service providers, such as independent agents, brokerage firms, and insurance companies Website hosting or information technology consulting service providers Marketing and promotion service providers Data analysis service providers Legal service providers Accounting service providers Administrative service providers Security service providers Application service providers
|
|
Communications |
Customer relationship management, or data storage
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None
|
Financial service providers, such as independent agents, brokerage firms, and insurance companies Website hosting or information technology consulting service providers Marketing and promotion service providers Data analysis service providers Legal service providers Accounting service providers Administrative service providers Security service providers Application service providers
|
|
Internet network activity |
Marketing, delivery services, customer relationship management, web hosting, or data storage
|
Remarketing, retargeting, and advertising providers |
Application service providers, Website hosting or information technology consulting service providers, Marketing and promotion service providers, Data analysis service providers, Legal service providers, Accounting service providers, Administrative service providers, Security service providers
|
|
Geolocation information |
Marketing, customer relationship management, web hosting, or data storage |
Remarketing, retargeting, and advertising providers |
Application Service Providers, Accounting Service Providers, Financial Service Providers, Website or Hosting Service Providers, Marketing and promotion service providers, Data analysis service providers. |
We retain personal information in identifiable form only for as long as necessary to fulfill the purposes for which the personal information was provided to us or, if longer, to comply with legal obligations, to resolve disputes, to enforce agreements and similar essential purposes. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
We are required to satisfy one or more of the reasons set out by applicable data privacy law before we can collect and use your personal information.
Generally, our business purpose for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally rely on the following reasons to collect and use your personal information:
Using your information may be necessary for us to perform our obligations under a contract with you or with a view to entering into such a contract. For example, where you have: (i) purchased services and/or products from us, we will need to use your information to provide those services and/or products; or (ii) approached us in relation to employment opportunities, the collection and use of your personal information is necessary to enable us to offer you the job role, process your acceptance of the offer, on-board you as an employee and fulfil our obligations as an employer.
The collection and use of your personal information may be necessary to enable us to meet our legal obligations. For example, to verify your identity and undertake necessary due diligence checks.
Where such processing is not overridden by your interests or fundamental rights, we are permitted to use your personal information where it is necessary in order to pursue our legitimate interests, for example to operate the website and our other digital offerings, to improve our products and services, content and our other digital offerings or to undertake marketing. We may have other legitimate interests and if appropriate we will make this clear to you at the relevant time.
In some limited circumstances, we may rely on your consent to collect and use your personal information. For example, we may rely on consent: (i) where you have approached us in relation to employment opportunities and have provided us with sensitive personal information, such as information in relation to your racial and ethnic origin, sexual orientation, religion, physical and mental health, disabilities or trade union membership; or (ii) in relation to the sending of e-marketing or communications.
In some instances, we may need to use your personal information to protect your vital interests or those of another person.
You may not always be required to provide the personal information that we have requested. However, if you choose not to provide certain information, you may not be able to take advantage of some of our services. Any information that is so required is clearly marked as mandatory. If you would prefer that we not collect certain personal information from you, please do not provide us with any such information, or opt out of providing this information where applicable.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), these interests will normally be as set out in this Notice; however, if this changes we will make clear to you at the relevant time what those legitimate interests are.
If you have any questions or need further information concerning the business purpose on which we collect and use your personal information, please contact us using the contact details provided in the section below marked “How do I contact Orveda?"
In addition to the third parties identified under the “Do we Sell or Share Personal Information” section, during the past 12 months, we may have disclosed the categories of personal information listed in the section marked “what categories of personal information does Orveda collect about me?” to the following categories of recipients:
State consumer privacy laws may provide their residents with additional rights regarding our use of personal information. The following Section applies to individuals who reside in specific jurisdictions that provide additional privacy rights, including California, Virginia, Colorado, Connecticut, and Utah.
6.1 Your Rights and Choices
Right to Access Specific Information and Data Portability Right. You have the right to request that we disclose certain information to you about our collection and use of personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
Right to Correct Information. You have the right to request we update personal information about you that is incorrect in our systems.
Right to Delete. You have the right to request that we delete any personal information about you 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) the personal information from our records, unless an exception applies.
Right to Opt-out of the sale or sharing of Personal Information for Cross-Contextual Behavioral Advertising.
Residents of California, Colorado, Connecticut, Virginia and Utah have or will soon have the right to opt-out of certain data sharing and usage arrangements, and may do so by either:
Right to Limit Sensitive Personal Information Use. You have the right to limit the use of sensitive personal information regarding you.
Non-Discrimination. We will not discriminate against you for exercising any of your rights.
6.2 How to Exercise these Rights
To submit a request to exercise these rights you may use one of these three methods:
For all requests, please clearly state that the request is related to “Your Privacy Rights,” indicate which type of request you are making, and provide your name, street address, city, state, zip code and an e-mail address or phone number where we may contact you. We are not responsible for notices that are not labeled or sent properly or that do not include complete information.
To appeal a decision regarding a consumer rights request, please submit your appeal using one of the three methods above. Your appeal should include an explanation of the reason you disagree with our decision. Within 60 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
Only you, or a person registered with the applicable Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to personal information about you. You may also make a verifiable consumer request on behalf of your minor child.
You may only make such a 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 and 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.
We endeavor to respond to a verifiable consumer request within forty-five (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. We will deliver our written response electronically. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request. 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 the personal information that is readily usable 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.
6.3 Opt-out Preference Signals
Through your browser configuration, our website honors your opt-out preference signal.
You can get further help in configuring your browser by visiting: https://globalprivacycontrol.org/
6.4 Personal Information Sales Opt-Out
If you are age 16 or older, you have the right to direct us to not sell personal information about you 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 old, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 15 years old, or the parent or guardian of a consumer less than 13 years old. 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 Internet Web page link:
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.
The website may contain links to or from third party sites. Please be aware that we are not responsible for the privacy practices of such third parties. This Notice applies only to the personal information we collect as described above. We encourage you to read the privacy policies of third-party sites you access from links on the website or otherwise visit.
We will only send you marketing communications if you have agreed to this, or if we are otherwise permitted by law. If at any time you decide that you no longer wish to receive marketing communications from us, you may opt out by clicking on the relevant ‘unsubscribe’ link in the emails you receive, by texting STOP in response to any text message or by contacting us using the details found in the section “How do I contact Orveda”.
Please note, while we will honor your request to stop receiving marketing communications, we will continue to send you service-related communications such as emails confirming purchases through the website.
In order to provide our services, we may need to transfer and process your personal information internationally (including to destinations outside the country in which you are located).
As a result, your information may be transferred to and/or processed in countries which may not guarantee the same level of protection for personal information as the country in which you reside. However, we have taken appropriate safeguards to ensure that your personal information will remain protected in accordance with this Notice.
Further information can be provided on request: please contact us using the details found in the section “How do I contact Orveda?" We have also implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.
We understand that you care how your personal information is used and/or shared with others, and we value your trust and seek to safeguard your personal information.
We implement appropriate technical and organizational security measures, including physical, administrative and technical safeguards to protect your personal information from unauthorized access, use and disclosure.
The measures we use to protect your personal information are designed to provide a level of security appropriate to the risk of processing your personal information. However, please be aware that no electronic transmission of information can be entirely secure. We cannot guarantee that the security measures that we have in place to safeguard personal information will never be defeated or fail, or that those measures will always be sufficient or effective.
Orveda and its preferred third-party service providers or business partners may offer sweepstakes, contests, promotions and surveys (each, a “Promotion”).
Where we do this, we will use your personal information as set out in this Notice, or as otherwise notified to you. However, in certain cases, a third party’s privacy policy may apply to any personal information that you provide in connection with such Promotion. Before entering any Promotion, we encourage you to check who is operating the Promotion in question, and the terms, conditions, policies and rules that apply to it.
You must be aged 13 or over to use the Orveda sites and our other digital offerings.
We take your privacy very seriously and we understand the importance of taking extra precautions to protect the privacy and safety of children who use our products and services. We do not solicit or knowingly collect personal information from children aged 13 and under. If we are made aware that we have received such information, or any information in violation of our policy, we will use reasonable efforts to locate and remove that information from our records.
California Minors: If you are a California resident who is under age 18 and you are unable to remove publicly-available content that you have submitted to us, you may request removal by contacting us at: concierge@orveda.com. When requesting removal, you must be specific about the information you want removed and provide us with specific information, such as the URL for each page where the information was entered, so that we can find it. We are not required to remove any content or information that: (1) federal or state law requires us or a third party to maintain; (2) was not posted by you; (3) is anonymized so that you cannot be identified; (4) you don’t follow our instructions for removing or requesting removal; or (5) you received compensation or other consideration for providing the content or information. Removal of your personal information from the Services does not ensure complete or comprehensive removal of that content or information from our systems or the systems of our service providers. We are not required to delete the content or information posted by you; our obligations under California law are satisfied so long as we anonymize the content or information or render it invisible to other users and the public.
We may update or modify this Notice from time to time in response to changing legal, technical or business developments. We will obtain your consent to any material Notice changes if and where this is required by applicable data protection laws. The date of the most recent version of this Notice will appear at the top of the page.
When we update our Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. for example, we will notify you of any changes to this Notice by posting a new Notice and updating the “last modified" date at the top of this page or by sending the new Notice to you via email, where appropriate.
We have taken great measures to ensure that your visit to the website is an excellent one and that your privacy is respected. If you have any questions, comments, or concerns about our privacy practices and/or would like to submit a privacy request, please contact us either:
California Shine the Light Law
California Civil Code Section 1798.83 permits users who are California residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed personal information (if any) for direct marketing purposes in the preceding calendar year. If you are a California resident and you wish to make such a request, please send an e-mail with “California Privacy Rights” in the subject line to concierge@orveda.com or write us at: Coty DTC Holdings, LLC, Attn: Privacy Inquiries, at 350 5th Avenue, 19th Floor, New York, NY 10118-0110
Contact Information
If you have any questions or comments about this notice, the ways in which we collect and use your information described in this Notice, or your choices and rights regarding such use please do not hesitate to contact us at
Phone - 1-833-7ORVEDA (1- 833-767-8332) +44 808 196 0312 (UK) +33 1 86 47 22 86 (FR)
E-mail - concierge@orveda.com
Postal Address - Coty DTC Holdings, LLC, Attn: Privacy Inquiries, 350 5th Avenue, 19th Floor, New York, NY 10118-0110
