# Privacy Policy

> Terms Of Use    UPDATED JANUARY 2 2019    PLEASE READ THE FOLLOWING CAREFULLY AS IT AFFECTS YOUR LEGAL RIGHTS THESE TERMS CONTAIN AN AGREEMENT TO ARBITRATE T

Source: https://help.roots.com/en_us/privacy-policy-HJC8DQO35

Last updated: 2026-03-16T14:04:57.998Z

  
This page contains privacy policies for customers located in the United States and Internationally.

  

United States Privacy Policy

**Updated: March 1, 2026**

_This policy applies to customers located in the United States._

Roots America Corporation (“Roots”) takes our relationship with all our customers seriously, and this includes how we handle your personal information. Roots is committed to respecting applicable privacy laws.

Personal information is information about you, that can be used to identify you. This Privacy Policy (“Policy”) sets out the ways we collect, use and share your personal information.

*   [WHAT PERSONAL INFORMATION DO WE COLLECT?](#us-1)
*   [HOW DO WE COLLECT YOUR PERSONAL INFORMATION?](#us-2)
*   [HOW DO WE USE INFORMATION ABOUT YOU?](#us-3)
*   [WITH WHOM DOES ROOTS SHARE YOUR PERSONAL INFORMATION?](#us-4)
    *   [Affiliates and Subsidiaries](#us-4-1)
    *   [Service Providers](#us-4-2)
    *   [Other Third Parties](#us-4-3)
*   [WEB ANALYTICS AND USE OF COOKIES](#us-5)
*   [MARKETING CHOICES](#us-6)
*   [WITHDRAWING CONSENT](#us-7)
*   [WHAT DO WE DO TO SAFEGUARD PERSONAL INFORMATION?](#us-8)
*   [STORAGE OF DATA IN OTHER JURISDICTIONS](#us-9)
*   [HOW DO WE RETAIN YOUR PERSONAL INFORMATION?](#us-10)
*   [LINKS TO OTHER WEBSITES](#us-11)
*   [CHANGES TO THIS POLICY](#us-12)
*   [REQUESTS ABOUT YOUR PERSONAL INFORMATION](#us-13)
    *   [California Residents](#us-13-1)
*   [AUTOMATED DECISION-MAKING](#us-14)
*   [CONCERNS OR QUESTIONS](#us-15)

## 1\. WHAT PERSONAL INFORMATION DO WE COLLECT?

We collect personal information from you when you interact with Roots, including by visiting one of our stores or our website at Roots.com, engaging with us by email, text message or through social media, participating in our promotions, contests, and surveys, attending an event with us, applying for a job with us, or other ways in which you may engage with us. We may collect personal information such as:

*   your full name, age, date of birth and gender;
*   your billing and delivery postal addresses, phone (including mobile phone) and e-mail details;
*   transaction information, such as payment method, credit card and other payment related information and identifiers, order details and purchase history;
*   where you have chosen to register a user account with us, your user name and password;
*   your communication and shopping preferences;
*   details regarding your browsing on our website and shopping activities including inferences based on your browsing and purchase history;
*   your interests, feedback and survey responses;
*   information that you provide when you apply for a job with us;
*   information that you provide about your friends through any “refer a friend” programs you participate in;
*   information about your device, including your IP address, operating system and browser type;
*   your location;
*   security video and audio recordings at our stores, and phone call and chat recordings through our customer support lines; and
*   any other correspondence with us.

## 2\. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

Personal information is primarily collected directly from you, such as information voluntarily provided to us through our website, mobile applications, social media channels or in store, and other ways you contact us.

We may also collect personal information about you from your use of other Roots websites and social media networks (Facebook, Instagram, Pinterest, Twitter/X, YouTube, Yelp, Snapchat and Google) you participate in.

We may also obtain personal information from our subsidiaries and affiliates, public sources, third party service providers, individuals who have indicated you have agreed for them to provide your personal information, government, tax or law enforcement agencies and other third parties. For example, if you are on another website and you opt-in to receive information from Roots, that website may give us your email address and other information about you so that we may contact you as requested.

If you chose to use a third party application or feature that connects your social media account or other online profile (e.g. Facebook or Twitter/X) with our website, the third party may give us information about you, such as details of your friends/connections, "likes", comments you have shared, groups and location. In addition, we may receive information about you if other users of a third party website give us access to their profiles and your personal information is accessible through your friends'/connections´ web page, profile page, or similar page on a social media channel or other third party website or interactive service.

Roots is not responsible for obtaining your consent for any personal information shared with us by a third party; the third party is responsible for obtaining your meaningful consent to its collection, use and disclosure of your personal information. Please see the sections below entitled “Links to Other Websites,” “With Whom Does Roots Share Your Personal Information” and “Web Analytics and Use of Cookies” for more information on how we exchange information with third parties and how we engage with our digital marketing and web analytics partners.

We may supplement the information we collect about you directly with the information we receive from third parties in order to enhance our ability to serve you, to tailor our content to you and send you details of promotions and/or offers which we believe may be of interest to you.

If we receive your personal information from a customer who sends our products as a gift, we will use and store that personal information for the purpose of completing the customer’s order.

Our website is not intended for children under the age of 14 and Roots does not knowingly collect personal information from children in this age group. Users under the age of majority in their region must have consent of their legal guardian before providing us with any personal information.

## 3\. HOW DO WE USE INFORMATION ABOUT YOU?

Roots will use your personal information for the purposes described in this Policy or explained to you at the time it is collected. If we want to use your personal information for new or additional purposes, we will provide you with notice of these purposes and give you an opportunity to provide or withdraw your consent.

We will use your personal information in connection with the purposes for which you have provided it. This may include:

*   when you make purchases or returns on our website, mobile applications, over the telephone or in-store;
*   to respond and/or deal with your request or enquiry, including as a result of searches on our website;
*   to enter you in contests and notify you of results if you have agreed to participate in such contests;
*   to administer our website, mobile applications and social media networks and personalize content for you;
*   for internal record keeping;
*   to provide direct or other marketing;
*   to record and update your marketing preferences;
*   to develop and personalize offers, promotions and advertising provided to you or others based on our understanding of your browsing and shopping habits or purchase history (including sending you reminders of items left in your shopping cart);
*   to register you for certain features on our website;
*   for internal research and development purposes; and
*   to assess, improve and tailor our products and services to you.

We may also use your personal information for other business purposes including management analysis, audit, forecasting, business planning, restructuring and transactions, ensuring our compliance with applicable laws, regulatory requirements, security, fraud-prevention, and dealing with legal claims and related administrative activities and related records retention requirements. We may also use your personal information as required or permitted by law enforcement, other government agency requests or court orders.

We may de-identify your personal information and use it for aggregated research, statistical and other purposes, such as improving our website, products and services or measuring the effectiveness of our advertising. We may also anonymize personal information and use it for research and other purposes as permitted by law.

## 4\. WITH WHOM DOES ROOTS SHARE YOUR PERSONAL INFORMATION?

### Affiliates and Subsidiaries

We may disclose your personal information to our corporate affiliates and subsidiaries for the uses described in this Policy.

### Service Providers

We may hire service providers to perform services on our behalf, such as such as advertising and marketing, order management, shipping, customer service and payment services. In order for them to perform these services, we may have to share your personal information with them. These service providers may then use your personal information for the following purposes on our behalf:

*   to complete your order or enable product or payment offers;
*   to provide you with customer support or otherwise communicate with you;
*   to analyze and improve the products and services we provide (e.g., business-related data analysis and customer surveys);
*   to assist with advertising and other promotional activity about or products and services; and
*   to protect you, us and our digital platforms from fraud, theft, and other security risks.

We will provide these service providers with only the information necessary for them to provide the services to Roots. Roots prohibits service providers from using or disclosing personal information for purposes other than to facilitate and carry out those services. We will strive to protect personal information shared with them by requiring that they adhere to applicable privacy laws, confidentiality and security procedures and protections that are, at a minimum, equivalent to those employed by Roots.

The social media networks who may provide advertising about our products and services to you may also process some of your personal information in their own capacity (for example when carrying out their own targeted advertising). Roots is not responsible for the processing of your personal information by any social media networks, when acting in their own capacity and not as a service provider to Roots. Please refer to the privacy policies of the relevant social media networks for further details on how your personal information will be used by them.

### Other third parties

We may also disclose your personal information to other third parties as follows:

*   with your consent;
*   to government authorities, law enforcement and regulatory authorities where required or permitted by law;
*   for debt collection purposes;
*   to partners who offer and provide financing and payment services to you;
*   to our web analytics and advertising partners for digital marketing and analytics purposes;
*   for security, loss and fraud prevention purposes; and
*   other entities (including actual or prospective buyers and our affiliates) in the event that Roots is involved in a bankruptcy, merger, reorganization or sale of any of its businesses and/or assets.
*   Roots does not share your information with third party brands for their own marketing purposes.

## 5\. WEB ANALYTICS AND USE OF COOKIES

If you browse our website, you may receive personalized advertisements while browsing other websites. Through our advertising, we try to provide you with information on products and offers which are relevant to you. This service is provided by Roots via reputable service providers that use 'cookies' or similar tools placed on your computer or other device. We may also use tools to personalize advertising to you based on your browsing history on our website and past purchases online or in-store (e.g., cart or browser reminders). Where required by law, we will ask for your consent before using cookies to deliver ads or otherwise engage in profiling based on your interests.

We may also use cookies and similar tools in order to provide a better service or identify which pages on our website and social media networks are of special interest.

A cookie is a small piece of information which a website stores via your web browser on your computer or other device either during your visit to our website or which can later be retrieved on subsequent visits to our website. The main objective is to personalize a user’s visit by customizing web pages for them, for example, by remembering your log-in name or preferred language. Cookies cannot be read by a website other than the one for which it is set.

As noted in the section above, third party websites may also use cookies to show you advertisements about our products on those third party sites, including offers based on products you have viewed or purchased.

You can adjust your web browser settings to inform you when cookies are set and to prevent cookies from being set or used to track your browsing online. Depending on your browser, you may find those options under the browser’s menu tabs for tools, options, settings, preferences or similar tabs. You can also opt out of interest-based advertising from many advertising partners, third-party websites and apps by visiting [youradchoices.ca](https://youradchoices.ca). Please note that although our website will respect your browser settings, Roots is not able to process requests to disable cookies on your device because we cannot control those settings.

We also engage the following partners for the purposes of collecting information about how you use your websites and engage with our targeted advertisements:

**Rakuten Advertising:** Rakuten Advertising may collect personal information when you interact with our website or mobile apps, including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes. You can learn more about the collection, use and sale of your personal data by Rakuten [here](https://rakutenadvertising.com/legal-notices/services-privacy-policy/) and about your privacy rights in relation to Rakuten [here](https://rakutenadvertising.com/legal-notices/services-privacy-rights-request-form/).

**Google Analytics:** We also use Google Analytics to provide analytics about how you engage with our websites and ads. You can learn more about how Google uses information from sites or apps that use Google’s services [here](https://www.google.com/policies/privacy/partners), and how to adjust your browser settings to opt out of Google Analytics [here](https://support.google.com/analytics/answer/181881?hl=en).

## 6\. MARKETING CHOICES

From time to time, Roots may send you special offers and announcements by email or text message. You can unsubscribe from receiving email offers at any time by clicking on the Unsubscribe link in the message you’ve received. To unsubscribe from promotions sent via text message, visit our Text Message Terms of Use site. You can also email [customer\_service@roots.com](mailto:customer_service@roots.com) to unsubscribe from email or text communications.

If you have asked us to stop sending marketing offers via e-mail or text message and this hasn't happened, it may be because the email address or phone number to which we are sending them is not the same as the address or number you sent your request from. Please check the address we are using and include this information in your request. The easiest way to do this is to return to us the whole of the unwanted email. If you still experience problems please contact the Roots Privacy Office using the contact information listed below under “Concerns or Questions.”.

## 7\. WITHDRAWING CONSENT

You may choose to withdraw your consent to the collection, use and disclosure of your personal information at any time, unless legal or contractual reasons prevent you from doing so. However, if you withdraw your consent, we may be unable to offer or provide you with certain goods and services.

If you would like to withdraw your consent or modify your preferences, please contact the Roots Privacy Office using the contact information listed below under “Concerns or Questions.”

## 8\. WHAT DO WE DO TO SAFEGUARD PERSONAL INFORMATION?

We use administrative, technical and physical safeguards to protect personal information and fulfill your privacy choices. We have internal policies and procedures that govern how we use and protect personal information, handle complaints and access requests, respond to privacy breaches and delete data when no longer required.

We require that our service providers agree to protect personal information that they must access in order to provide those services. Internally, we limit access to personal information about you to only those employees who need that information to provide products or services to you or in order to do their jobs.

You are responsible for keeping the password to any Roots account or profile you create confidential. We ask you not to share a password with anyone, not to reuse passwords for different accounts, and to notify us if you believe your password has been compromised.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will take appropriate measures to protect your personal information, we cannot guarantee the security of your personal information transmitted to our website and/or social medial channels. Any transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to try to prevent unauthorized access.

## 9\. STORAGE OF DATA IN OTHER JURISDICTIONS

We may use service providers that handle data outside of your state or country. If you use our website, mobile apps, or otherwise provide us with personal information, we may use and store it outside of your home region. Although any transfer of your personal information outside of the jurisdiction in which it was collected will be done in accordance with all applicable legal requirements, law enforcement in the countries where it is stored may have the right to access this data.

## 10\. HOW DO WE RETAIN YOUR PERSONAL INFORMATION?

We may retain your personal information, including any content you may have provided to us, in our internal databases and systems, for as long as we need it for the purposes for which we collected it. We will not retain your personal information for longer than is necessary to fulfil these purposes unless required or permitted by law. Although you can always ask us to access your personal information we have on file, we will not notify you in advance of deleting it when we no longer need your personal information. Where permitted by law, we may retain anonymized information for longer for our own research or other purposes.

## 11\. LINKS TO OTHER WEBSITES

We may offer links to third party websites. However, we are not responsible for the content or information collection policies of third party websites. If you visit a third party website, we advise you to review their privacy and other policies. We do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to the third party websites.

## 12\. CHANGES TO THIS POLICY

We review and update our policies and procedures as required to keep current with rules and regulations, new technologies, standards and customer concerns. Our Policy may therefore change from time to time; the current version of the Policy will always be posted on our website. If we materially change the way we handle your personal information, we will notify you.

## 13\. REQUESTS ABOUT YOUR PERSONAL INFORMATION

You can request to access, correct, delete or transfer your personal information. If we are unable to fulfill your request, we will explain the reasons for this. To submit a request about your personal information, please contact the Roots Privacy Office using the contact information provided in the section below entitled “Concerns or Questions”.

### California Residents

If you are a California resident and have an established business relationship with us, in addition to the above rights you can request a notice disclosing the categories of personal information we have shared with or (if applicable) sold to third parties in the previous year. You may also request to opt out of this sharing or limit how some of your personal information is processed. Please submit requests to: Roots Privacy Officer, Roots Corporation, 1400 Castlefield Avenue, Toronto ON M6B 4C4 Canada. Please allow 30 days for a response.

If you are a California resident under 18 years old and you have registered for an account through the website, you can request that we remove content or information that you have posted to our websites. Note that fulfilment of the request may not ensure complete or comprehensive removal (e.g., if the content or information has been reposted by another user). To request removal of content or information, please email [privacy@roots.com](mailto:privacy@roots.com) or call +1 416 781 3574.

## 14\. AUTOMATED DECISION-MAKING

We may use automated decision-making to display recommended products or offers on our website, to determine whether and how to serve targeted advertisements and other promotional communications, and to verify your address if you provide it to us. We do not use automated decision-making for any profiling purposes. If you would like more information, please contact the Roots Privacy Office using the contact information provided in the section below entitled “Concerns or Questions”.

## 15\. CONCERNS OR QUESTIONS

If you have any questions, wish to access, update or delete information, wish to opt out of receiving future communications, or have questions about this Policy, please contact our Privacy Officer at [privacy@roots.com](mailto:privacy@roots.com), or at 1400 Castlefield Avenue, Toronto, ON, Canada M6B 4C4 Attention: Roots Privacy Officer.

International Privacy Policy

**Updated: March 1, 2026**

_This policy applies to customers located outside of Canada and the United States._

Roots Corporation (“Roots”) takes our relationship with all our customers seriously, and this includes how we handle your personal information. Roots is committed to respecting applicable privacy laws.

Personal information is information about you, that can be used to identify you. This Privacy Policy (“Policy”) sets out the ways we collect, use and share your personal information.

*   [WHAT PERSONAL INFORMATION DO WE COLLECT?](#intl-1)
*   [HOW DO WE COLLECT YOUR PERSONAL INFORMATION?](#intl-2)
*   [HOW DO WE USE INFORMATION ABOUT YOU?](#intl-3)
*   [LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA](#intl-4)
*   [WITH WHOM DOES ROOTS SHARE YOUR PERSONAL INFORMATION?](#intl-5)
*   [YOUR RIGHTS](#intl-6)
*   [PERSONALIZED ADVERTISING](#intl-7)
*   [USE OF COOKIES](#intl-8)
*   [MARKETING CHOICES](#intl-9)
*   [WITHDRAWING CONSENT](#intl-10)
*   [WHAT DO WE DO TO SAFEGUARD PERSONAL INFORMATION?](#intl-11)
*   [STORAGE OF PERSONAL DATA](#intl-12)
*   [HOW DO WE RETAIN YOUR PERSONAL INFORMATION?](#intl-13)
*   [LINKS TO OTHER WEBSITES](#intl-14)
*   [CHANGES TO THIS POLICY](#intl-15)
*   [UPDATING YOUR PERSONAL INFORMATION](#intl-16)
*   [AUTOMATED DECISION-MAKING](#intl-17)
*   [CONCERNS OR QUESTIONS](#intl-18)

## 1\. WHAT PERSONAL INFORMATION DO WE COLLECT?

We collect personal information from you when you interact with Roots, including by visiting one of our stores or our website at Roots.com, engaging with us by email, text message or through social media, participating in our promotions, contests, and surveys, attending an event with us, applying for a job with us, or other ways in which you may engage with us. We may collect personal information such as:

*   your full name, age, date of birth and gender;
*   your billing and delivery postal addresses, phone (including mobile phone) and e-mail details;
*   transaction information, such as payment method, credit card and other payment related information and identifiers, order details and purchase history;
*   where you have chosen to register a user account with us, your user name and password;
*   your communication and shopping preferences;
*   details regarding your browsing on our website and shopping activities including inferences based on your browsing and purchase history;
*   your interests, feedback and survey responses;
*   information that you provide when you apply for a job with us;
*   information that you provide about your friends through any “refer a friend” programs you participate in;
*   information about your device, including your IP address, operating system and browser type;
*   your location;
*   security video and audio recordings at our stores, and phone call and chat recordings through our customer support lines; and
*   any other correspondence with us.

## 2\. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

Personal information is primarily collected directly from you, such as information voluntarily provided to us through our website, mobile applications, social media channels or in store, and other ways you contact us.

We may also collect personal information about you from your use of other Roots websites and social media networks (Facebook, Instagram, Pinterest, Twitter/X, YouTube, Yelp, Snapchat and Google) you participate in.

We may also obtain personal information from our subsidiaries and affiliates, public sources, third party service providers, individuals who have indicated you have agreed for them to provide your personal information, government, tax or law enforcement agencies and other third parties. For example, if you are on another website and you opt-in to receive information from Roots, that website may give us your email address and other information about you so that we may contact you as requested.

If you chose to use a third party application or feature that connects your social media account or other online profile (e.g. Facebook or Twitter/X) with our website, the third party may give us information about you, such as details of your friends/connections, "likes", comments you have shared, groups and location. In addition, we may receive information about you if other users of a third party website give us access to their profiles and your personal information is accessible through your friends'/connections´ web page, profile page, or similar page on a social media channel or other third party website or interactive service.

We may supplement the information we collect about you directly with the information we receive from third parties in order to enhance our ability to serve you, to tailor our content to you and send you details of promotions and/or offers which we believe may be of interest to you.

If we receive your personal information from a customer who sends our products as a gift, we will use and store that personal information for the purpose of completing the customer’s order.

Our website is not intended for children under the age of 14 and Roots does not knowingly collect personal information from children in this age group. Users under the age of majority in their region must have consent of their legal guardian before providing us with any personal information.

We will indicate where any personal information we have requested is mandatory or optional. We will also explain the consequences should you decide not to provide information which we have indicated is mandatory. In some cases, this may mean we are unable to provide you with a certain service or product.

## 3\. HOW DO WE USE INFORMATION ABOUT YOU?

Roots will use your personal information for the purposes described in this Policy or explained to you at the time it is collected. If we want to use your personal information for new or additional purposes, we will provide you with notice of these purposes and give you an opportunity to provide or withdraw your consent.

We will use your personal information in connection with the purposes for which you have provided it. This may include:

*   when you make purchases or returns on our website, mobile applications, over the telephone or in-store;
*   to respond and/or deal with your request or enquiry, including as a result of searches on our website;
*   to enter you in contests and notify you of results if you have agreed to participate in such contests;
*   to administer our website, mobile applications and social media networks and personalize content for you;
*   for internal record keeping;
*   to provide direct or other marketing provided that we have the requisite permission to do so, including combing your personal data with third party analytics data to inform our marketing strategy;
*   to record and update your marketing preferences;
*   to develop and personalize offers, promotions and advertising provided to you or others based on our understanding of your browsing and shopping habits or purchase history (including sending you reminders of items left in your shopping cart);
*   to register you for certain features on our website;
*   for internal research and development purposes; and
*   to assess, improve and tailor our products and services to you.

We may also use your personal information for other business purposes including management analysis, audit, forecasting, business planning, restructuring and transactions, ensuring our compliance with applicable laws, regulatory requirements, security, fraud-prevention, and dealing with legal claims and related administrative activities and related records retention requirements. We may also use your personal information as required or permitted by law enforcement, other government agency requests or court orders.

We may de-identify your personal information and use it for aggregated research, statistical and other purposes, such as improving our website, products and services or measuring the effectiveness of our advertising. We may also anonymize personal information and use it for research and other purposes as permitted by law.

## 4\. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

We will only process your personal information where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your personal information. In almost every case the legal basis will be one of the following:

*   **Consent:** For example, where you have provided your consent to receive certain marketing from us. You can withdraw your consent at any time, including by clicking on the "unsubscribe" link at the bottom of any marketing email we send you.
*   **Our legitimate business interests:** Where it is necessary for us to understand our customers, promote our services and operate effectively as a premium manufacturer and retailer provided in each case that this is done in a legitimate way which does not unduly affect your privacy and other rights. For example, we will rely on this legal basis when we conduct certain market analysis to understand our customers in sufficient detail so we can create new services and improve the profile of our brand.
*   **Performance of a contract with you:** For example, where you have purchased goods from our website and we need to use your contact details and payment information in order to process your order and send the goods to you.
*   **Compliance with law:** Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation.

## 5\. WITH WHOM DOES ROOTS SHARE YOUR PERSONAL INFORMATION?

### Affiliates and Subsidiaries

We may disclose your personal information to our corporate affiliates and subsidiaries for the uses described in this Policy.

### Our International E-Commerce Partner: ESW

To deliver a seamless international shopping experience, we have partnered with ESW to facilitate your purchase. When you buy from our website, your transaction is with ESW. ESW will take your payment and fulfil your order.

**ESW’s Role as an Independent Controller:** For certain activities, ESW determines how your data is processed independently from us. This includes processing your payment securely, performing fraud checks to comply with legal requirements, and managing customs clearance borders (if applicable).

**Our Joint Responsibilities (Joint Controllership):** In other areas, Roots Corporation and ESW work together as "Joint Controllers" to ensure your order is fulfilled. This partnership covers:

*   **The Checkout Experience:** We collaborate on the information collected at the checkout, and the data sent and received between us to facilitate your purchase.
*   **Customer Support:** We also jointly manage data to resolve customer service inquiries, or manage disputes.
*   **Cookies and tracking technologies:** We jointly manage the placing of cookies and other tracking technologies on the checkout.
*   **Marketing consent:** We jointly manage the collection of consent for marketing, on the checkout.

**How We Protect You:** We have executed a formal agreement with ESW that clearly defines our respective duties to protect your data.

You are free to exercise your privacy rights regarding this joint processing by contacting either us or ESW directly. For more details on how ESW handles your data, please review the ESW Privacy Notice.

### Other Service Providers

We may hire other service providers to perform services on our behalf, such as such as advertising and marketing, order management, shipping, customer service and payment services. In order for them to perform these services, we may have to share your personal information with them. These service providers may then use your personal information for the following purposes on our behalf:

*   to complete your order or enable product or payment offers;
*   to provide you with customer support or otherwise communicate with you;
*   to analyze and improve the products and services we provide (e.g., business-related data analysis and customer surveys);
*   to assist with advertising and other promotional activity about or products and services; and
*   to protect you, us and our digital platforms from fraud, theft, and other security risks.

We will provide these service providers with only the information necessary for them to provide the services to Roots. Roots prohibits service providers from using or disclosing personal information for purposes other than to facilitate and carry out those services. We will strive to protect personal information shared with them by requiring that they adhere to applicable privacy laws, confidentiality and security procedures and protections that are, at a minimum, equivalent to those employed by Roots.

The social media networks who may provide advertising about our products and services to you may also process some of your personal information in their own capacity (for example when carrying out their own targeted advertising). Roots is not responsible for the processing of your personal information by any social media networks, when acting in their own capacity and not as a service provider to Roots. Please refer to the privacy policies of the relevant social media networks for further details on how your personal information will be used by them.

### Other third parties

We may also disclose your personal information to other third parties as follows:

*   with your consent;
*   to government authorities, law enforcement and regulatory authorities where required or permitted by law;
*   for debt collection purposes;
*   for security, loss and fraud prevention purposes; and
*   other entities (including actual or prospective buyers and our affiliates) in the event that Roots is involved in a bankruptcy, merger, reorganization or sale of any of its businesses and/or assets.

Roots does not share your information with third party brands for their own marketing purposes.

## 6\. YOUR RIGHTS

You have certain rights in relation to your personal information. These include: the right to object to the processing of your information for certain purposes, the right to access your personal information, and the ability to erase, restrict or receive a machine-readable copy of your personal information.

We will handle any request to exercise your rights in accordance with applicable law and any relevant legal exemptions. If you wish to exercise any of these rights please contact us using the contact details below.

You may also have the right to complain to a data protection authority if you think we have processed your personal information in a manner which is unlawful or breaches your rights. If you have such concerns we request that you initially contact us (using the contact details below) so that we can investigate, and hopefully resolve, your concerns.

## 7\. PERSONALIZED ADVERTISING

If you browse our website, you may receive personalized advertisements while browsing other websites. Through our advertising, we try to provide you with information on products and offers which are relevant to you. This service is provided by Roots via reputable service providers that use 'cookies' or similar tools placed on your computer or other device (see further information on the use of cookies in the section below). We may also use tools to personalize advertising to you based on your browsing history on our website and past purchases online or in-store (e.g., cart or browser reminders). Where required by law, we will ask for your consent before using cookies to deliver ads or otherwise engage in profiling based on your interests.

## 8\. USE OF COOKIES

We may also use cookies and similar tools in order to provide a better service or identify which pages on our website and social media networks are of special interest.

A cookie is a small piece of information which a website stores via your web browser on your computer or other device either during your visit to our website or which can later be retrieved on subsequent visits to our website. The main objective is to personalize a user’s visit by customizing web pages for them, for example, by remembering your log-in name; preferred language; device, operating system and IP address; browser type; and information about your visit, including URL, clickstream (i.e., your journey to, through and from our site), length of visits to certain pages, and page interaction information. Cookies cannot be read by a website other than the one for which it is set.

Our cookies will never contain information that will enable anyone to contact you via telephone, e-mail, or any other means. As noted in the section above, third party websites may also use cookies to show you advertisements about our products on those third party sites, including offers based on products you have viewed or purchased.

You can adjust your web browser settings to inform you when cookies are set and to prevent cookies from being set or used to track your browsing online. Depending on your browser, you may find those options under the browser’s menu tabs for tools, options, settings, preferences or similar tabs. You can also opt out of interest-based advertising from many advertising partners, third-party websites and apps by visiting [youradchoices.ca](https://youradchoices.ca). Please note that although our website will respect your browser settings, Roots is not able to process requests to disable cookies on your device because we cannot control those settings. For more information about how to reject cookies using your internet browser settings please consult the “Help” section of your internet browser (or alternatively visit [http://www.aboutcookies.org](http://www.aboutcookies.org)).

The names of the cookies used on our website and the purposes for which these cookies are used are set out in the table below:

Cookie:

Purpose:

Duration:

SiteID:

Stores user preferred site, and redirects user to preferred store as long as this cookie is present

Ranges from session to 7 days.

emailHopUpUS:

Stores user preferred site, and redirects user to preferred store as long as this cookie is present

Ranges from session to 7 days.

emailHopUpCA:

Restricts users from seeing email hop in CA site, until this cookie is removed.

Ranges from session to 7 days.

exitIntent:

Restricts users from seeing email hop in CA site, until this cookie is removed.

  

viewedPromo:

Will be created once user opens promo notification tab on header dropdown, and then restricts user from seeing notification count until cookie is removed or fresh promos are loaded.

30 days.

latitude:

Temporarily stores user latitude until it is moved to session storage's userLocation variable.

session

longtitude:

Temporarily stores user longitude until it is moved to session storage's userLocation variable.

session

We also engage the following partners for the purposes of collecting information about how you use your websites and engage with our targeted advertisements:

**Rakuten Advertising:** Rakuten Advertising may collect personal information when you interact with our website or mobile apps, including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes. You can learn more about the collection, use and sale of your personal data by Rakuten [here](https://rakutenadvertising.com/legal-notices/services-privacy-policy/) and about your privacy rights in relation to Rakuten [here](https://rakutenadvertising.com/legal-notices/services-privacy-rights-request-form/).

**Google Analytics:** We also use Google Analytics to provide analytics about how you engage with our websites and ads. You can learn more about how Google uses information from sites or apps that use Google’s services [here](https://www.google.com/policies/privacy/partners), and how to adjust your browser settings to opt out of Google Analytics [here](https://support.google.com/analytics/answer/181881?hl=en).

## 9\. MARKETING CHOICES

From time to time, Roots may send you special offers and announcements by email or text message. You can unsubscribe from receiving email offers at any time by clicking on the Unsubscribe link in the message you’ve received. To unsubscribe from promotions sent via text message, visit our Text Message Terms of Use site. You can also email [customer\_service@roots.com](mailto:customer_service@roots.com) to unsubscribe from email or text communications.

If you have asked us to stop sending marketing offers via e-mail or text message and this hasn't happened, it may be because the email address or phone number to which we are sending them is not the same as the address or number you sent your request from. Please check the address we are using and include this information in your request. The easiest way to do this is to return to us the whole of the unwanted email. If you still experience problems please contact the Roots Privacy Office using the contact information listed below under “Concerns or Questions”.

## 10\. WITHDRAWING CONSENT

You may choose to withdraw your consent to the collection, use and disclosure of your personal information at any time, unless legal or contractual reasons prevent you from doing so. However, if you withdraw your consent, we may be unable to offer or provide you with certain goods and services.

If you would like to withdraw your consent or modify your preferences, please contact the Roots Privacy Office using the contact information listed below under “Concerns or Questions.”

## 11\. WHAT DO WE DO TO SAFEGUARD PERSONAL INFORMATION?

We use administrative, technical and physical safeguards to protect personal information and fulfill your privacy choices. We have internal policies and procedures that govern how we use and protect personal information, handle complaints and access requests, respond to privacy breaches and delete data when no longer required.

We require that our service providers agree to protect personal information that they must access in order to provide those services. Internally, we limit access to personal information about you to only those employees who need that information to provide products or services to you or in order to do their jobs.

You are responsible for keeping the password to any Roots account or profile you create confidential. We ask you not to share a password with anyone, not to reuse passwords for different accounts, and to notify us if you believe your password has been compromised.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will take appropriate measures to protect your personal information, we cannot guarantee the security of your personal information transmitted to our website and/or social medial channels. Any transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to try to prevent unauthorized access.

## 12\. STORAGE OF PERSONAL DATA

Our business is headquartered in Canada. If you are located in the European Economic Area (the “EEA”), or in another country outside Canada, you should be aware that we will collect, process, and maintain your information in Canada and in other jurisdictions including the United States.

Personal data may also be processed by staff operating outside the EEA, or in another country outside Canada, who work for us or for one of our service providers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

Whenever we transfer information as described in the paragraph above, we will take steps which are reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this Policy. In these cases, we rely on approved data transfer mechanisms (such as the EU "Standard Contractual Clauses") to ensure your information is subject to adequate safeguards in the recipient country.

## 13\. HOW DO WE RETAIN YOUR PERSONAL INFORMATION?

We take steps to ensure that the personal information that you provide is retained for only as long as it is necessary for the purpose for which it was collected. After this period it will be deleted or in some cases anonymised. For example, where you have made a purchase with us, we will keep a record of your purchase for the period necessary for invoicing, tax and warranty purposes. We may also keep a record of correspondence with you (for example if you have made a complaint) for as long as is necessary to protect us from a legal claim.

We may retain your personal information and any anonymized information, as well as any other information, including but not only, any content you may have provided to us, in our internal databases and systems, for as long as we need it for business and legal purposes but subject to the terms and conditions of this Policy. Even so, we have no obligation to you to retain any information about you or any of your content.

Where we have collected the personal information based on your consent and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent then we will delete your personal information.

## 14\. LINKS TO OTHER WEBSITES

We may offer links to third party websites. However, we are not responsible for the content or information collection policies of third party websites. If you visit a third party website, we advise you to review their privacy and other policies. We do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to the third party websites.

## 15\. CHANGES TO THIS POLICY

We review and update our policies and procedures as required to keep current with rules and regulations, new technologies, standards and customer concerns. Our Policy may therefore change from time to time; the current version of the Policy will always be posted on our website. If we materially change the way we handle your personal information, we will notify you.

## 16\. UPDATING YOUR PERSONAL INFORMATION

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. If you wish to update your personal information, please contact the Roots Privacy Officer.

## 17\. AUTOMATED DECISION-MAKING

We may use automated decision-making to display recommended products or offers on our website, to determine whether and how to serve targeted advertisements and other promotional communications, and to verify your address if you provide it to us. We do not use automated decision-making for any profiling purposes. If you would like more information, please contact the Roots Privacy Office using the contact information provided in the section below entitled “Concerns or Questions”.

## 18\. CONCERNS OR QUESTIONS

If you have any questions, wish to access, update or delete information, wish to opt out of receiving future communications, or have questions about this Policy, please contact the Roots Privacy Officer at [privacy@roots.com](mailto:privacy@roots.com), or at 1400 Castlefield Avenue, Toronto, ON, Canada M6B 4C4 Attention: Roots Privacy Officer.
