Privacy Policy

Updated January 26, 2021.

General

This Website is operated by JANUS et Cie (“we,” “us,” or “our”). We believe that the privacy and security of your information and data is very important. This Privacy Policy (“Policy”) explains the type of information (“Information”) we collect from users of the Website, how that Information is used, how the Information may be shared with other parties, and what controls our users have regarding their Information. We encourage you to read this Policy carefully. Any updates or modifications to this Policy will be posted to our website on this page. By using or accessing the Website, you signify that you have read, understand and agree to be bound by this Policy.

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Information We Collect

There are two types of Information that may be collected through our Website: (1) “Personal Information” which is information that can be used to directly identify you such as your name, e-mail address, physical address, phone number, credit card number; (2) “Usage Data” which is anonymous information not linked to you personally that is related to your use of the Website, including information about the computer and mobile device you use when visiting the Website, as well as data regarding your activity, such as the actions you take within and outside of the Website, the browser and/or device you use, and the date and time of your use of the Website. In California, certain Usage Data may be considered Personal Information. For more information on your rights as a California resident under California law, please scroll down to Your California Privacy Rights below.

You may enter the Website and browse its contents without submitting any Personal Information. However, if you wish to establish an account, make a purchase, contact us, subscribe to our newsletter or other mailings, post any comments, participate in certain promotions, or otherwise communicate with us, whether through our Website, our social media pages or any of our e-mail addresses, we may at that time require that you provide Personal Information or give you the ability to provide Personal Information. When you submit Personal Information in any manner, you are giving your consent to the collection, use and disclosure of your Personal Information as set forth in this Privacy Policy.

If you choose to connect to our Website through a third-party social network such as Facebook (each, a “Social Network”), we may collect Personal Information from your profile on such Social Network, such as your name, username, and e-mail address, and we may publish your activity on our Website through such Social Network. In addition, our Website may offer social sharing features which will allow you to “Share” or “Like” on a Social Network. If you decide to use such features, it may allow the sharing and collection of Information both to and from such Social Network so you should check the privacy policy of each Social Network before using such features.

Whether or not you submit Personal Information, whenever you visit the Website, click on our advertisements (including those appearing on third party sites), or visit our social media pages, we or our Service Providers (as defined below) may collect, store or accumulate certain Usage Data based on your use of our Website, such as information regarding which of our pages or products are most popular, the browser you use, your computer’s IP address, and the URLs you visited before and after using our Website. For more information on how this Usage Data is collected, please see the Cookies section below. When you visit the Website on a mobile device, our Service Providers may create or read a unique mobile device identifier. We and our Service Providers also need to record your IP address, at least temporarily, so that we may send you the pages of our Website that you request.

Please note that we will only collect your credit card information if you choose to purchase our products online via our Website. If you do make such an online purchase, our payment processing partner will collect your payment information and process your payment. We do not store any credit card information or share it with anyone other than our payment processor.

Uses and Sharing of Information

We use the Personal Information that we collect to process your requests, fulfill your orders, authenticate website visits and usage, inform you of relevant products and specials through promotional e-mails, maintain and develop our Website, and otherwise communicate with you. You always will be given the opportunity to unsubscribe from further emails in any promotional messages we send you. If you would like to preemptively opt out of receiving any communications from us, please fill out the Contact Us form here and type “EMAIL OPT OUT” as the first words in the message box.

Except as described above, we will not disclose, rent, sell or share any Personal Information to unaffiliated third parties for direct marketing purposes.

We do contract with companies or individuals to provide us and you with certain services including email and hosting services, software development, credit card processing, shipping, fulfillment, data management, surveys and marketing, promotional services, etc. We call them our “Service Providers.” We may share both your Personal Information and Usage Data with Service Providers solely as required for them to perform their functions. We do not share your credit card or other account information with third parties unless you authorize us to do so, or if it is necessary to fulfill our responsibilities including, but not limited to, delivering a product or service that you order.

In addition, aggregated, non-personally-identifiable Usage Data may be used by us, or shared with our Service Providers for use, in connection with general operational, administrative, advertising, analytical, research, optimization, and security purposes, but no such information will be linked with your Personal Information or be used to identify or contact you. For more information about how Usage Data may be used for interest-based advertising, please see the section entitled “Targeted Advertising” below.

Finally, we may share your Information: (i) In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us; (ii) When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company, our users, or others; and in connection with our Terms of Use and other agreements; or (iii) In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

Privacy and Security

It is entirely your choice whether or not you provide Personal Information to us. We take reasonable precautions to protect our customers' Personal Information against loss, misuse, unauthorized disclosure, alteration, and destruction. However, please remember that no transmission of data over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, we cannot ensure or warrant the security of any information that you transmit to us or from us, and you do so at your own risk. You hereby acknowledge that we are not responsible for any intercepted information sent via the Internet, and you hereby release us from any and all claims arising out of or related to the use of intercepted information in any unauthorized manner.

In addition, while we take reasonable steps to govern our Service Providers’ use and protection of your Personal Information, we ultimately have no control over and are not responsible for the privacy practices of such parties. As a condition to your use of the Website, you expressly agree we bear no responsibility, and are not liable in any way, for the acts, omissions or policies of our Service Providers or any other external sources with respect to your Information.

If you believe your Personal Information is being improperly used by us or any third party, please immediately notify us at privacy@janusetcie.com.

Cookies

As part of our collection and use of Usage Data (as described in more detail herein), we, or our Service Providers, may use cookies, web beacons, tracking pixels, or similar tracking technologies. These “Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive. Generally, Cookies work by assigning to your computer a unique number that has no meaning outside of the Website but can be used to gather Usage Data. While Cookies may record certain persistent identifiers related to your computer or device, they do not contain any Personal Information.

Most web browsers automatically accept Cookies, but you can usually configure your browser to prevent this. However, not accepting Cookies may make certain features of the Website unavailable to you.

Targeted Advertising

We engage certain third party ad network Service Providers to serve advertisements on our behalf across the Internet and to provide analytics services. These entities may utilize Cookies (including within the ads) to collect Usage Data from you such as your IP address, web browser, pages viewed, time spent on pages, how you use our Website, items you put in your basket, any links you click on, and conversion (purchase) information. This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content or products, measure the effectiveness of ad campaigns, determine the proper amount of repeat views of a given ad, and deliver advertising and content targeted to your interests on our websites and other websites (also known as “interest-based advertising”).

To learn more about advertising networks and to opt out of interest-based advertising served by participating companies, visit the Digital Advertising Alliance at www.aboutads.info/choices or the Network Advertising Initiative at www.networkadvertising.org/choices.

Types of Cookies on our Website and Specific Opt-Outs

a. Essential Cookies. Essential cookies make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies. We use Google Tag Manager on our Website to manage tags on our Website. It is not really a cookie, but it is essential to the functioning of our Website and cannot be opted out of. We use other cookies controlled by us to identify trusted web traffic and preserve your session across page requests.

b. Analytics Cookies. Analytics cookies help website owners to understand how visitors interact with their website by collecting and reporting information anonymously. We use Google Analytics to do this. You can opt out of Google Analytics by downloading and installing the browser plug-in from the following link: http://tools.google.com/dlpage/gaoptout.

c. Social. Facebook Connect is a single sign-on application which allows users to interact on other websites, including our Website, through their Facebook account. When you do this, we receive certain information about your Facebook account, according to your Facebook account setting. To opt out of this, do not sign in with your Facebook account.

d. Customer Interactions. We use Live Chat to facilitate live chats with you when you are on our Website. We use DotDigital to evaluate when visits to our Website are the result of a click on a link in our marketing email campaigns. To block these trackers, opt out at the browser level, as explained here: Browser and Device Opt-Outs. 

e. Advertising Cookies. As explained above, marketing cookies are used to track visitors across websites, for the purpose of displaying ads that are relevant and engaging for the individual user and thereby more valuable for website publishers and third party advertisers.

i. Retargeting and Remarketing. We may, in conjunction with third party marketing services, gather information from your visit to our Website for purposes of reminding you about our products in the future. This means that we may display advertisements to you about our products on other websites, such a Facebook, based on usage data collected during your visit to our Website. We use Google Dynamic Retargeting for this purpose. To opt out of seeing personalized ads via the Google platform, please visit: https://support.google.com/ads/answer/2662922?hl=en. For more information regarding how Google uses cookies in advertising and how you can control advertising cookies, please visit: http://www.google.com/policies/technologies/ads/. To personalize the ads you see via the Google platform, visit http://www.google.com/settings/ads. For more information on how Google uses data when you visit its partners’ websites or apps, visit http://www.google.com/policies/privacy/partners/.

ii. Behavioral Advertising. When trackers are used to monitor your traffic across websites in order to discern your interests for the purpose of showing you ads from companies other than the website owners, this is behavioral advertising. We do not have behavioral advertising trackers on our Website.

Browser and Device Opt-Outs

You have the ability to manage your cookie settings on your devices. For example, you can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. If you disable cookies, however, it may interfere with the functionality of our Website and you may not be able to use all of its features. Details on how you can control and delete these cookies through your browser settings can be found through your browser’s vendors specific settings or options page.

You can also use cookie management and disposal tools at your own prerogative such as downloading and installing certain browser plug-ins.

To limit interest-based advertising in Apps on your mobile device, you can review and adjust the settings provided by your device manufacturer, such as “ Limit Ad Tracking” for iOS or “Opt-out of interest-based ads” for Android.

Children Under 13

This website is targeted to adults. We do not knowingly collect or solicit Personal Information directly from anyone under the age of 13. If you are under 13, please do not send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected Personal Information from a child under age 13 we will delete that information as quickly as possible. If you are a parent or guardian of a child under 13 years of age and you believe your child has provided us with Personal Information, please email us at privacy@janusetcie.com.

Opting Out Of Marketing Messages

When registering for an account on our Website, you will have the ability to “opt in” to receiving further promotional communications from us. Alternatively, if you initially decide to receive information from us but at a later date wish to remove your information from our database, you can do so by using the unsubscribe link at the bottom of our emails. You may also at any time opt out of receiving e-mails from us or our affiliated or related companies by filling out the Contact Us form here with the subject line “Email Opt Out.”

Please note that even if you unsubscribe from our promotional email messages, we may still need to contact you with important transactional information related to your account and your purchases. For example, even if you have unsubscribed from our promotional emails, we will still send you confirmation of a purchase you have made on our Website.

Links to Third Party Websites

Our Website or emails may contain links to third party websites to which we have no affiliation (including social networks). Except as set forth in this Policy, we do not share your Personal Information with those websites and are not responsible for the privacy policies of any other website or their management of your Personal Information. Because they may treat your Information differently than we do, we suggest you read the privacy policies on those third party websites prior to submitting any Personal Information.

Your Rights and Obligations

We ask that you keep the Personal Information that you provide to us current and that you correct any information you have provided us by emailing us at privacy@janusetcie.com. You represent and warrant that all Personal Information you provide us is true and correct and relates to you and not to any other person.

If you wish to review, delete and/or revise the Personal Information we have stored about you, please email us at privacy@janusetcie.com; provided, however, that we reserve the right to retain an archive of such Personal Information for a commercially reasonable time to ensure that its deletion does not affect the integrity of our data; and we further reserve the right to retain an anonymous version of such Information.

If you use the Website, you are responsible for maintaining the confidentiality of your account and for restricting access to your computer or device, and you agree to accept responsibility for all activities that occur under your account.

Changes to this Privacy Policy

We reserve the right to change this Policy at any time. In the event we make material changes to this Policy, such policy will be re-posted in the "Privacy" section of our Website with the date such modifications were made indicated on the top of the page. Therefore, please review this Policy from time to time so that you are aware when any changes are made to this Policy. If you have any questions about the changes that were implemented, please email us at privacy@janusetcie.com and include “Information Regarding Updated Policy” in the subject line. In any event, your continued use of the Website after such change constitutes your acceptance of any such change(s), and if you do not accept any changes, you may choose not to use the Website or opt out by sending us an appropriate notice.

General Legal

This Policy will be governed by and construed in accordance with the laws of the State of California, without regard to any principles of conflicts of law. You agree that any action at law or in equity that arises out of or relates to any use of the Website will be filed only in the state or federal courts located in Los Angeles County, and you hereby consent and submit to the personal jurisdiction of such courts for the purposes of litigating any such action. If you have questions or comments about this Policy, please email us at privacy@janusetcie.com with “Website Privacy” in the subject line of your email.

Your California Privacy Rights – Supplemental Privacy Policy for California Residents

This Supplemental Privacy Policy supplements the information above and applies solely to California residents. It applies to Personal Information we collect on or through the Website and through other means (such as information collected offline, and over the telephone). It does not apply to information we collect from job applicants or retain about our employees. “Personal Information” has a broad definition under California law; specifics are in the table below.

Summary of Information

We Collect California law, including the California Consumer Privacy Act of 2018 and related regulations (the “CCPA”), requires us to disclose information regarding the categories of Personal Information that we have collected about California consumers, the categories of sources from which the information was collected, the business or commercial purposes (as those terms are defined by applicable law) for which the information was collected, and the categories of parties with whom we share Personal Information.

a. California Notice of Collection

We or our Service Providers may collect the below categories of information for the following business or commercial purposes (as those terms are defined in the CCPA):

  • providing the Services (e.g., account servicing and maintenance, customer service, analytics, and communication about the Services);
  • our or our Service Provider’s operational purposes;
  • auditing consumer interactions on our Website;
  • detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;
  • bug detection and error reporting;
  • customizing content that we or our Service Providers display on our Website;
  • improving our existing products and services;
  • other uses that advance our commercial or economic interests, such as communicating with you about relevant products and services available to you from third party partners; or
  • other uses about which we notify you.

Examples of these types of uses are identified below and discussed more generally above. We may also use the below categories of Personal Information for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any particular user or device.

b. Summary Categories of Personal Information, Sources, and Third Parties we share it with

The table below describes the collection, use, and sharing of Personal Information collected by us or our Service Providers within the last twelve (12) months. The first column lists the categories of Personal Information we or our Service Providers have collected. The second column lists the categories of sources of that information. The third column lists how that information is used. The fourth column lists the categories of third parties we share it with.  The fourth column lists the categories of third parties we share it with.

Category of Personal Information Collected Categories of Sources Examples of Uses Categories of Third Parties We Share That Information With
Identifiers, such as your real name, postal address, mobile device identifiers, Internet Protocol (IP) address, email address, account name You, if you choose to provide to us.Automatically collected from you when you use the Website.Affiliates.Third parties (such as Service Providers and other users who, for example, may refer you to the Website). Responding to your requests for information.We need your IP address to serve pages of the Website to you. Affiliates.Service Providers.Third party shippers such as FedEx and UPS.Other individuals or companies at your request.Service providers, such as analytics providers.Third parties relating to legal requests, if required by law or if we believe in good faith that it is reasonably necessary.Third parties for sales of transfers of our business or assets
Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.Some Personal Information included in this category may overlap with other categories You, if you choose to provide it to us. To fulfill your orders.To confirm your identity. Affiliates.Service Providers.Third party shippers such as FedEx and UPS.Other individuals or companies at your request.

Third parties relating to legal requests, if required by law or if we believe in good faith that it is reasonably necessary.
Third parties for sales of transfers of our business or assets
Commercial information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. You, by using our Website and buying our products.Affiliates.Service Providers. To fulfill your orders and anticipate future orders. Affiliates.Service Providers.Other individuals or companies at your request.Third parties relating to legal requests, if required by law or if we believe in good faith that it is reasonably necessary.Third parties for sales of transfers of our business or assets.
Financial data, such as credit or debit card number, verification number, and expiration date, to process payments and information about your transactions and purchases with us. You, if you choose to provide to us.Service Providers and third parties confirming payments made on your behalf.Affiliates. Fulfilling your orders. Service providers, such as payment processors.Other individuals or companies at your requestThird parties relating to legal requests, if required by law.
Device information and identifiers, such as IP address; browser type and language; operating system; platform type; device type; software and hardware attributes; and unique device, advertising, and app identifiers You, by using our Website. We and our Service Providers collect this info automatically. Personalizing your experience on our Website to your browser and language. Service Providers.Third parties relating to legal requests, if required by law or if we believe in good faith that it is reasonably necessary.Third parties for sales of transfers of our business or assets.
Internet network and electronic activity device information, such as information about files you download, domain names, landing pages, browsing activity, content or ads viewed and clicked, dates and times of access, pages viewed, forms you complete or partially complete, search terms, uploads or downloads, the URL that referred you to our Website, the websites you visit after our Website; if you share our content to social media platforms; and other web usage activity and data logged by our web servers, whether you open an email and your interaction with email content, access times, error logs, and other similar information.

See Types of Cookies on our Website and Specific Opt-Outs above for more information about how we collect and use this information
Your, through your device, by using our Website.Analytics providers.Advertising providers.Cookies and tracking technologies.

Personalizing your experience on our Website.Marketing and advertising our products, specifically, understanding which of our marketing campaigns resulted in your visit to our Website. Service Providers.Third parties relating to legal requests, if required by law or if we believe in good faith that it is reasonably necessary.Third parties for sales of transfers of our business or assets.
Geolocation data, such as your postal address and your IP address, and if you provide permission, your precise GPS location. We infer your general location from your IP address. You, if you choose to provide to us.We collect IP address automatically when you use the Website.Third parties (such as Service Providers). Responding to your requests for information.Mailing your products to you.Personalizing your experience on our Website to your language and national market. Service Providers.Affiliates.Other individuals, services, and partners at your request.

Third parties relating to legal requests, if required by law or if we believe in good faith that it is reasonably necessary.Third parties for sales of transfers of our business or assets.
Inferences drawn from other Personal Information, such as profile reflecting a person’s preferences Third parties who create profiles based on your Internet browsing behavior Targeting our ads to you on other websites Our advertising Service Providers
Social media information (which may include personal identifiers, photos, location, user generated content, demographic information).

If you link your account or access the Website through a third-party connection or log-in, we may have access to any information you provide to that social network depending on your privacy settings such as your name, email address, friend list, photo, gender, location, and current city; and information you provide to us directly through our pages on social networking and blogging platforms (e.g., Facebook, Instagram, YouTube, and Twitter).
You, if you choose to provide to us.Social media networks, in accordance with your privacy preferences on such services Understanding the demographics and preferences of our potential customers Service Providers.Affiliates.Other individuals, services, and partners at your request.

Third parties relating to legal requests, if required by law or if we believe in good faith that it is reasonably necessary.Third parties for sales of transfers of our business or assets.
Research, survey, or sweepstakes information (including personal identifiers and user generated content)

collected if you participate in a survey or sweepstakes; includes information needed for you to participate (such as contact information), and to fulfill your prize.
You, if you choose to provide to us.Survey or sweepstakes partners.Researchers and analysts. To administer the survey or sweepstakes.To understand our customers and their experiences with our products and services. Affiliates.Service Providers.Other individuals or companies at your request.Third parties relating to legal requests, if required by law or if we believe in good faith that it is reasonably necessary.Third parties for sales of transfers of our business or assets.
Sensory data, such as audio recordings if you call our customer service. You, if you choose to provide to us.
Your use of our services/automatically collected from you.
Service Providers.
To evaluate our customer service.To respond to your requests. Service Providers.Affiliates.Other individuals or companies at your request.Third parties relating to legal requests, if required by law or if we believe in good faith that it is reasonably necessary.Third parties for sales of transfers of our business or assets.

c. Rights for California Consumers

If you are a California resident, you may have certain rights. Effective as of January 1, 2020, you may request that we:

  • Provide you the categories of Personal Information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your Personal Information; and the categories of third parties with whom we shared Personal Information. 
  • Provide access to and/or a copy of certain information we hold about you. 
  • Delete certain information we have about you. 

We will take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name, email address, and physical address. You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

d. Exercising Your California Rights

If you are a California resident and would like to exercise your three legal rights listed above ((1) right to know the categories of information, sources, purposes, and third parties we share with; (2) right to know the specific information we have about you; (3) right to delete that information) complete and submit this form. This form will be the most efficient way to exercise your rights. You may also call us at 1-866-477-0018.

You may have the right to receive information about the financial incentives that we offer to you (if any). You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide our products and services to you. If you ask us to delete it, you may no longer be able to access or use our Website or purchase our products without providing the information again.

e. We Do Not Sell Your Info

Effective January 1, 2020, California residents may opt out of the “sale” of their Personal Information. Under the CCPA, “sale” is defined such that it may include allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior, to deliver targeted advertising on the Website or other websites. We do not allow our service providers to use information gathered on our Website for such targeted advertising. Nor do we sell your Personal Information as the term “sale” is normally used.

f. California Shine the Light Law

Under certain circumstances, California Civil Code Section 1798.83 states that, upon receipt of a request by a California customer, a business may be required to provide detailed information regarding how that business has shared that customer’s Personal Information with third parties for direct marking purposes. However, the foregoing does not apply to businesses like ours that do not disclose Personal Information to third parties for direct marketing purposes without prior approval or give customers a free mechanism to opt out of having their Personal Information disclosed to third parties for their direct marketing purposes. California users may request further information about their rights under this law and our policy by emailing us at privacy@janusetcie.com, using the subject line “CA Request for Information,” and requesting further information.

g. California Do Not Track Disclosures

For a variety of reasons, including technical limitations, our Website may not yet recognize browser "Do Not Track" signals.