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Privacy Policy

Last updated on 05/03/2026

1. Preamble

Welcome to the website of LA ROSÉE COSMÉTIQUES ( https://www.larosee-cosmetiques.ca) or any other address that may be substituted for it, the "Website"), owned by La Rosée Cosmétiques Canada Inc ("La Rosée"), a joint-stock company legally incorporated under the Business Corporations Act, whose registered office is located at 400 Laurier Ouest, Suite 600, Montreal, Quebec H2V 2K7, Canada, registered with the Registraire des Entreprises du Québec under number (NEQ) 1180153976

La Rosée collects and processes Personal Data relating to Users on the Website.

This privacy policy (hereinafter the “Privacy Policy ”) describes the methods of collecting and processing Personal Data relating to Website Users and informs them of their rights.

It is supplemented by a Cookie Policy available in Appendix 1.

As Privacy Officer, La Rosée is concerned to protect the privacy of Website Users as much as possible and makes every effort in this context. La Rosée undertakes in particular to ensure a level of protection of Users' Personal Data in accordance with the provisions of the Act respecting the protection of personal information in the private sector (Quebec), and the Personal Information Protection and Electronic Documents Act (Canada) (hereinafter referred to together as the "Applicable Law").

2. Definitions

  • Recipient: means a natural or legal person, public authority, agency or any body, to which the Personal Data are disclosed, whether a third party or not;
  • Personal Data or Data: refers to any information that concerns a natural person and makes it possible to identify them directly or indirectly. This includes, but is not limited to, name, postal address, email address, telephone number, financial information, location data, an online identifier, or any information relating to the personal, social or professional characteristics of that person. Data is deemed personal if it identifies a person, alone or in combination with other information;
  • Privacy Officer: refers to the person responsible for ensuring compliance with and implementation of the obligations provided for by the Applicable Law and the protection of the User's Personal Information collected during the use of the Website;
  • Processor: means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Privacy Officer or the initial Processor;
  • Processing: means any operation or set of operations performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, extraction, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Other words and expressions used in the Privacy Policy starting with a capital letter have the meanings given to them in the General Terms and Conditions of Sale or in the General Terms and Conditions of Use available on the Website.

The use of the Website and/or the services of La Rosée implies that the User consents in a clear and informed manner to the collection, use and communication of their Personal Data, in the manner specified in this Privacy Policy. This consent is deemed to be given within the limits of the choices made by the User, and does not apply to authorisations expressly refused or withdrawn in accordance with this Privacy Policy. 

By accessing the services of La Rosée, Users also confirm that they meet the age criteria required by the applicable Law for this consent to be valid, and thus that they are at least 14 years of age, or are a parent or legal guardian who has authorised the processing of the Personal Data of a minor under their responsibility. 

La Rosée does not voluntarily collect any Personal Data relating to a minor without first obtaining the permission of a parent or legal representative. If data of this nature is collected without proper authorisation, La Rosée undertakes to delete it as soon as possible. 

Personal Information is processed by La Rosée in order to provide the services requested by the User and to fulfil its contractual obligations, always in compliance with the principles established by this Privacy Policy.

When a User transmits Personal Data concerning a third party to La Rosée, it is the User's responsibility to have obtained the consent of the latter to allow such sharing. This Data will then be used and retained by La Rosée in accordance with the Privacy Policy and the privacy preferences expressed, subject to applicable laws. 

The User may withdraw their consent at any time with respect to certain uses of their Personal Data, subject to the legal or contractual obligations in force. Such withdrawal could nevertheless prevent La Rosée from offering certain services or from ensuring their maintenance. 

Unless expressly permitted by applicable law, La Rosée will not disclose any Personal Data to third parties, except as provided in this Privacy Policy. 

4. Personal Data collected via the Website

La Rosée collects the following Personal Data directly from Users:

  • Identification Data, such as surnames, first names;
  • Contact data used to manage Orders and/or to send commercial prospects to Users (email address, postal address);
  • Data relating to Product Orders placed on the Website, such as the Product(s) purchased, the transaction number, the delivery address, the User's telephone number, etc.
  • Data relating to job applicants.

It is specified that payment information (credit card number/Paypal information/bank details) is not collected by La Rosée but directly by the payment service providers (Paypal/Lydia/Stripe/Apple Pay) used on the Website.

The Personal Data collected for the execution of the User's Order, compliance with La Rosée's legal or regulatory obligations or those that condition the conclusion of the General Terms and Conditions of Sale must be provided. Otherwise, La Rosée will not be able to deliver the Products to Users.

The table below allows Users to have an overview of the procedures for the Processing of their Personal Data by La Rosée.

Personal Data concerned

  1. Identification data, Contact data, Login data, Data collected during the purchase procedure on the Website;
  2. Identification and contact data, subject of the message and any information transmitted via the free field;
  3. Identifying information;
  4. All information transmitted via the online virtual assistant (text, photos, videos)
  5. Login information;
  6. Identification data and Payment data;
  7. Data collected during the purchase procedure carried out on the Website;
  8. Contact information.

Purposes

  1. Management and administration of the User's Personal Space, management of the contractual relationship (delivery of Products, invoicing, payment, parcel tracking, after-sales service, satisfaction surveys)
  2. Provision of information relating to the Products on the Website via the contact form, at the request of the User
  3. Chat bot management;
  4. Accounting and tax obligations;
  5. Pre-litigation and litigation management;
  6. Commercial prospecting for Users (sending newsletters), for the purposes of promoting and marketing the Products

Legal Basis

  1. Execution of the contract concluded between the User and La Rosée (General Terms and Conditions of Sale)
  2. Obtaining the User’s consent
  3. Execution of pre-contractual measures taken at the request of the User
  4. La Rosée's legitimate interest in responding to the User's requests
  5. Legitimate interest of La Rosée to provide appropriate information on its Products
  6. Compliance with a legal obligation of La Rosée for the retention of Personal Data;
  7. La Rosée’s legitimate interest for establishing proof of a right or a contract

Retention period

  1. Term of the contract. The Data is then archived for the duration of the legal prescription;
  2. Duration necessary to manage the User's request
  3. Immediate erasure or necessary duration of the Processing of the request (for example in the case of a complaint)
  4. Prescribed legal period for the retention of tax and accounting documents
  5. Data collected during the purchase procedure carried out on the Website: duration of legal prescription;
  6. Until the User's consent is withdrawn, and no later than 3 years after a last active contact from the User

6. Recipients of the Personal Data of the Users

La Rosée does not transmit the Personal Data of Users to third parties, except in the following main cases:

  • The employees of La Rosée, in particular in charge of the commercial relationship with Users, required to ensure the confidentiality of Personal Data;

  • The Processors of Personal Data, required to guarantee the confidentiality of the Personal Data and in particular:

  • The service provider responsible for hosting the Website (Shopify), including the Users' Personal Data;

  • The service provider responsible for emailing (KLAVIYO);

  • The service providers in charge of the routing and delivery of the Products (DELMAR);

  • The service providers in charge of the payment services on the Website (Stripe, Paypal, Lydia, Apple Pay);

  • Communication of Users' Personal Data to the competent authorities pursuant to applicable law and/or a court decision.

7. Personal Data retention period

La Rosée only retains the Personal Data of Users for the period strictly necessary for the purposes set out in Article 4.

The Personal Data of Users are subsequently sorted and archived, for those that have not been deleted, with restricted access for an additional period in order to allow La Rosée to comply with its legal and/or regulatory obligations regarding the archiving and storage of Personal Data. At the end of this additional period, the Personal Data of the Users are permanently deleted from the databases of La Rosée.

8. Security

La Rosée undertakes to implement all technical and organisational measures to ensure the security and confidentiality of Users' Personal Data in accordance with the Applicable Law.

As such, La Rosée takes appropriate precautions with regard to the nature of the Personal Data and the risks presented by the Processing, to preserve the security of the Personal Data, and in particular prevent them from being distorted, damaged or unauthorised third parties having access to them (physical protection of the premises, authentication process for Users with personal and secure access via confidential username and password, logging of connections, encryption of certain Personal Data, etc.).

9. Rights of Users

In accordance with the applicable law, Users have several rights with regard to the Personal Data collected by La Rosée. 

9.1 Right of access and right to portability 

The User may, at any time, ask La Rosée to confirm the existence of Personal Data concerning them, obtain communication thereof in an intelligible form, and be informed of the categories of persons within La Rosée who have access to it. 

Access to Personal Data is free of charge, subject to reasonable fees in the event of a request for transcription, reproduction or physical transmission. Where applicable, La Rosée will inform the User in advance. 

The User may also obtain the Personal Data that they have provided to La Rosée in a structured, commonly used and machine-readable format, and request its transmission to another organisation when the processing is based on consent or on a contract, and is carried out by technological means. 

9.2 Right of rectification and erasure

The User may have any Personal Data rectified that is inaccurate, incomplete or equivocal, or whose collection, communication or storage is not authorised by law. 

The User may also, in the cases provided for by the Applicable Law, request the erasure of their Personal Data, in particular when it is no longer necessary for the purposes of its collection, when consent is withdrawn and no other legal basis justifies its Processing, or when the Processing is contrary to the Applicable Law. 

9.3 Right to withdraw consent 

Where the Processing is based on the User's consent, the User may withdraw it at any time, subject to the restrictions provided for by the Applicable Law. This withdrawal is only effective for the future and may limit access to certain services offered by La Rosée. 

9.4 Right of limitation and objection

The User may, in the circumstances provided for by the Applicable Law, ask La Rosée to limit the use of certain Personal Data or to object to its Processing. 

9.5 Communications, complaints and requests to exercise rights 

The User may send any request relating to the exercise of the rights mentioned above, as well as any question or complaint to the La Rosée Privacy Officer:

In the event of dissatisfaction with the processing of their request, the User may also contact the Commission d'Accès à l'Information du Québec (CAI) in order to file a complaint. 

10. Transfer of Users' Personal Data outside Quebec

Users' Personal Data may be transferred to the European Union, in particular to companies belonging to the La Rosée Cosmétiques group.

The Users' Personal Data may be transferred outside Québec, in particular to the service provider located in Ontario which provides hosting services for the La Rosée Website (Shopify). 

La Rosée implements the necessary guarantees to secure these transfers outside Quebec, in particular by signing standard contractual clauses, carrying out a Privacy Impact Assessment (EFVP) and regularly updating the latter.

11. Modifications of the Privacy Policy

La Rosée reserves the right to modify and/or update this Privacy Policy. The revised Privacy Policy will be posted on the Website with an indication of the last update date.