ROMWE PRIVACY POLICY
Learn more about Interest-based Advertising and your Ad Choices here .
Effective Date: September 25, 2023
Introduction and Overview
This Privacy Policy ( "Policy" ) explains how SHEIN Distribution UK Ltd., which does business as “ROMWE”, collects, uses, shares, and processes your Personal Data when you use or access this website (collectively, the “Site” ) or use any of our services, including our mobile applications ( “Apps” ), communication platforms, and any other related services we own (collectively the “Services”). The Policy also describes your rights regarding your personal data and explains how you can contact us to learn more about our data practices or to exercise your rights.
SHEIN Distribution UK Ltd. uses the Site and Apps and sells products offered there under license from Roadget Business Pte. Ltd., 12 Marina Boulevard, #15-01, Marina Bay Financial Centre, Singapore 018982, therefore, SHEIN Distribution UK Ltd. is the controller of your personal data, and responsible for processing and protecting your personal data. In this Policy, the terms “ROMWE,” “Company”, “we”, “us” or “our” refer to SHEIN Distribution UK Ltd.
Please read our Terms and Conditions and this Policy before accessing or using our Services. If you cannot agree with this Policy or the Terms and Conditions, please do not access or use our Services.
Right to modify this Policy: We may change this Policy from time to time, to reflect how we are processing your data, and if we make changes, we will notify you by revising the effective date or last modified date at the top of this Policy. If we make significant changes that materially affect your privacy rights, we will provide advanced notice and make that clear on the ROMWE website or other ROMWE services, or by some other means of contact such as email, so that you are able to review the changes before you continue to use the Services. If you do not agree with the modified Policy, please discontinue the use of the Services or do not consent to the updates.
Instant information: In addition, we may provide you with real-time disclosures or additional information about the personal information handling practices of specific parts of our Services. Such notices may supplement this Policy or provide you with additional choices about how we process your personal information.
CONTENTS
Click on the links below to go to a specific section of this Policy.
1. How We Collect and Use Your Personal Information
We respect the privacy of the visitors to our digital properties and the users of our products and services, and we are committed to protecting it through our compliance with this Policy. We collect personal information when you use our Services.
Pursuant to the EU General Data Protection Regulation the Data Protection Act 2018, and the United Kingdom General Data Protection Regulation (collectively, for purposes of this Privacy Policy, "GDPR" ), personal information in this Policy is referred to as "personal data" as defined in the GDPR, and in this Policy can be interchangeably used with the term "personal information." For residents of the United Kingdom, “personal data” is any information that, alone or in combination with other information, identifies or makes an individual identifiable.
Personal Information does not include data that has been effectively irreversibly anonymized or aggregated so that it can no longer enable us or others, whether in combination with other information or otherwise, to identify you.
Your personal data is collected and used by us to support a range of different activities or business purposes. The purposes and types of information we collect are listed in the chart below and should be understood to include uses of your personal data that are compatible with the purposes listed.
Purpose The Personal Data We Collect Legal Basis for Processing
To create an account with us and to manage your account, to provide you our Services;
  • Contact information, including email address and password, to register with our website or app.
Necessary for the performance of a contract or to take steps at your request prior to entering into a contract
  • Profile data, including your style preference, if you voluntarily choose to provide it for personalization purposes.
Consent
To fulfill or process orders;
  • Identity and contact information such as name, phone number and shipping address, as well as financial information or payment account information, for delivery, returns, refund, sales tax determinations, and payment operations;
  • Transaction details, such as return and refund details, gift card number, and order history, in our Services, in order to fulfill basic functions, including processing your payment and return requests, and keeping you informed of the order status and shipping logistics.
Necessary for the performance of a contract or to take steps at your request prior to entering into a contract
  • Location data at an IP address-based level, to tailor your experience in terms of displaying the appropriate local website, language, or user experience.
Our legitimate interest is to better understand you, to maintain and improve the accuracy of the information we store about you, and to better promote or optimize our Services
To provide customer service and support, or to provide you with service-related communications;
  • Photographs you upload to our Services in accordance with our Terms and Conditions, to provide product advice and to allow you to voluntarily show other potential customers what items may look like when purchased or worn.
Consent
  • Your communication history with us via various channels, such as email, phone, social media, mail, instant chat, and our customer service platform, to respond to your requests, as well as to keep you updated about your account and the Services.
Our legitimate interest is to better understand you, to maintain and improve the accuracy of the information we store about you, and to better promote or optimize our Services
To undertake marketing, advertising, or other promotional activities;
  • Contact information, such as phone number and email address, for telemarketing and email marketing purposes;
  • Non-directly identifiable device identifiers, operating system information, and cookie information, to direct and measure the effectiveness of the advertising we offer;
  • Data about how you engage with our Services, such as browsing, adding to your shopping cart, saving items, placing an order, and returns) for market research, statistical analysis, and the display of personalized advertising based on your activity on our site and inferred interests;
  • Contact and identity information, such as name, email address, and phone number, when you voluntarily enter into a competition, market survey, event, or other marketing campaigns organized by us;
  • To share your personal data with third-party advertisers.
Consent
  • Postal address to send advertising brochures, via traditional mail to the address of individual customers who previously purchased products on the website.
  • No Advertising materials will be sent to individuals who are on national lists of Objections or Mailing Preference Services which will be reviewed and updated based on the applicable national legal requirements.
Our legitimate interest is to better promote or optimize our Services
To improve our product or service, or for personalization;
  • Collect your device information, and usage data in our website or app for fault analysis, troubleshooting, and system maintenance, as well as setting default options for you, such as language and currency;
  • When you optionally provide such information, we may collect general personal data that cannot identify you, such as body shape, personal height, chest/waist/hip circumference, and weight. For example, this information may be used by us to recommend clothing sizes or styles, personalization, or to provide fit prediction services for you;
  • To share your personal data within and across our corporate organization for our business needs and personalization;
  • Collection of your “like” records and votes when prompted as to your preference between two items, to provide preference setting options;
  • The display of information you choose to post on public areas of the Services, for example a customer review.
Our legitimate interest to better understand you, to maintain and improve the accuracy of the information we store about you, and to better promote or optimize our Services
To prevent and investigate fraud and other illegal activities;
  • Information automatically collected through the Services, such as browser type, device information, operating system and account setting information for fraud prevention and detection and credit risk reduction;
  • Log-in data for risk control and fraud reporting;
  • Billing address to verify payment information.
Our legitimate interest is to better understand you, to maintain and improve the accuracy of the information we store about you, and to better promote or optimize our Services
To comply with legal or compliance requirements;
  • Identity information, such as ID- or passport-related information, for customs clearance purposes;
  • Transaction history and certain identity information to handle and resolve legal disputes, for regulatory investigations purpose, and to comply with lawful requests from a competent law enforcement agency or court.
Compliance with legal obligations or your vital interests
Other Purposes.
  • We may use your information for any other purpose disclosed to you prior to you providing us your personal information or which is reasonably necessary to provide the Services or other related products and/or services requested, with your permission or upon your direction.
Consent
Please note: When communicating with us by email or through forms on our Services, or when you publicly share content through our Services, we ask that you please do not send us any sensitive information pertaining to yourself or to others. We do not collect or store sensitive information or special categories of information.
2. Sharing Your Personal Information
We may disclose and share your personal information with the parties as described below.
  • A. Within Our Corporate Organization . The Company is a part of a corporate organization that has several legal entities, business processes, management structures, and technical systems. We may share your personal information with our related group companies and, in some cases, other affiliates of our corporate group, based on our legitimate interests for business maintenance and personalization continuity purposes, for instance, so that you may enjoy a personalized user experience across our digital properties, to provide you with the Services, or to take actions based on your requests or preferences.
  • B. Service Providers . We may share your personal information with the following types of third-party service providers as set out in the table below:
  • Supplier/Service Provider/Processor
    Services Offered
    IT system and software service provider Website hosting services (including cloud storage), mobile app or software optimization services, customer relationship management software, email service providers, or system maintenance services.
    Payment service provider Third-party payment processing services.
    Marketing and advertising services Assistance in reaching potential new customers across multiple communications channels, or sharing with affiliated companies that promote our products on their websites.
    Order fulfillment service provider Provision of logistics, warehousing and distribution services, return and exchange services, and order status notification services for your purchased items.
    Customer service provider Assistance with customer services and support.
    Fraud prevention and information security service provider Identity verification, fraud prevention, or credit risk reduction services to protect our website/app and our business.
    Other Service providers selected by you Other third parties, such as size recommendations and fit prediction services providers, if you have chosen to help us provide you with product recommendations.
  • We strive to ensure that our third-party service providers can only use your data for the contractual purposes for which it was provided to them and to the extent necessary for such purposes, in accordance with our written instructions (where they act as our data processors).
  • C. To Maintain Legal and Regulatory Compliance . We have the right to disclose your personal information for compliance with a legal obligation, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, or any other legal process served on us. We also may disclose your information where we reasonably believe that the disclosure is necessary to enforce our agreements or policies, or if we believe that disclosure will help us protect the rights, property, or safety of the Company or our customers.
  • D. Co-Branded Services and Features . Portions of our Services may be offered as part of co-branded services and features. We will share your personal information with our co-branded partners based on your voluntary use of or participation in a co-branded service or feature. The co-branded partners will be identified on the co-branded feature or service, along with an applicable co-branded partner's privacy policy. Use of your personal information by a co-branded partner will be subject to a co-branded partner’s privacy policy. If you wish to opt-out of a co-branded partner’s future use of your personal information, you will need to contact the co-branded partner directly.
  • E. Consent . We may disclose your personal information for any purpose with your consent.
  • F. Corporate Transactions . We may disclose personal information—including account information, Wallet balance or points information—to a buyer, prospective buyer, corporate affiliate, or other successor based on our legitimate interests in the event of a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding in which personal information held by us about our Services users is among the assets transferred. You acknowledge and agree to our assignment or transfer of rights to your personal information.
Please note that we may disclose, without restriction, aggregated or anonymized information about the users of our Services, which is information that does not identify any specific individual.
3. Cookies, Interest-Based Advertising, Ad Choices
We may use cookies, tags, web pixels, and similar technologies to automatically collect information on our Services. Cookies or tags are bits of code that allow our technology partners to collect information that usually does not directly identify you. If required by law, we will request your consent before using cookies or other tracking technologies. Information within this section describes our use of cookies and your ability to control the use of cookies for advertising-related purposes. As described below, we will not use cookies or similar tracking technologies that process your personal data, unless they are Strictly Necessary Cookies, or you opt-in, i.e. consent, by using the cookie banner or consent manager found on our Site. You may withdraw your consent or update your preferences at any time by clicking the "Manage Cookies" link within the website footer.
  • A. Cookies . Cookies are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the site’s or provider’s system to recognize your browser and remember certain information.
  • Generally, we use first-party and third-party cookies for the following purposes: to make our Services function properly; to provide a secure browsing experience during your use of our Services; to collect passive information about your use of our Services; to measure how you interact with our marketing campaigns; to help us improve our Services; and to remember your preferences for your convenience.
  • We use the following types of cookies on our Services:
    • Strictly Necessary Cookies. These cookies are essential because they enable you to use our Services. For example, strictly necessary cookies allow you to access secure areas on our Services. Without these cookies, some services cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Services to work and they cannot be disabled.
    • Functional Cookies. We use functional cookies to remember your choices so we can tailor our Services to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our Services. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Services.
    • Performance or Analytic Cookies. These cookies collect passive information about how you use our Services, including webpages you visit and links you click. We use the information collected by such cookies to improve and optimize our Services. We do not use these cookies to target you with online marketing. You can disable these cookies as set forth below.
    • Advertising or Targeting Cookies. These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests. Our third-party advertising partners may use these cookies to build a profile of your interests and deliver relevant advertising on other sites. You may disable the use of these cookies as set forth below.
  • B. Your Choices . Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies served on our Services by taking the steps outlined below.
    • First-Party Cookies. You can use the browser with which you are viewing this Site to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Site. Also, if you disable cookies other parts of the Services may not work properly. You can find more information about how to change your browser cookie settings at https://www.allaboutcookies.org .
    • Third-Party Cookies. If you wish to opt-in or opt-out of third-party advertising networks and similar entities that use advertising cookies, please click the "Manage Cookies" link in our website footer or visit https://www.aboutads.info/choices . For more information about third-party advertising networks and similar entities that use these technologies, please see https://www.aboutads.info/consumers . You may withdraw your consent or update your preferences at any time by clicking the "Manage Cookies" link within the Site footer or within the App menu. Residents of the European Union and U.K. may opt-out of online behavioral advertising served by the European Interactive Digital Advertising Alliance’s participating member organizations by visiting https://www.youronlinechoices.eu/ .
    • Mobile Applications. To opt-out of data collection for interest-based advertising across mobile applications by participating companies, download the Digital Advertising Alliance’s AppChoices mobile application opt-out offering here: https://youradchoices.com/appchoices .
  • We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. In addition, most web browsers provide help pages relating to setting cookie preferences. More information may be found for the following browsers here: Google Chrome , Internet Explorer , Mozilla Firefox , Safari (Desktop) , Safari (Mobile) , Android Browser , Opera Mobile .
    SHEIN adheres to the Digital Advertising Alliance's Self-Regulatory Principles.
  • C. Web Pixels . To see how successfully our marketing campaigns or other goals of the Services are performing we sometimes use conversion pixels, which fire a short line of code to tell us when you have clicked on a particular button or reached a particular page (e.g. a thank you page once you have completed the procedure for subscribing to one of our services or have completed one of our forms). We also use web pixels to analyze usage patterns on our Services. The use of a pixel allows us to record that a particular device, browser, or application has visited a particular webpage.
  • D. Analytics . We may use third-party service providers to monitor and analyze the use of our Services. Presently, we use Google Analytics . Google Analytics is a web analytics service that tracks and reports Site traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en . Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout .
  • If Google Analytics is structured to collect personal data, the cookie banner on our Site will provide you the opportunity to consent to Google Analytics and the data controller will be Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland. We have implemented Google Analytics with the “AnonymizeIP” function, which makes sure that your IP address will be shortened before it is sent to servers in the U.S. Exceptionally, the shortening may take place after such transfer to the U.S. Google uses this data to evaluate your use of our Services, to compile reports on activities on our online services and to provide us with other services related to Site, App and internet use.
  • E. Behavioral Remarketing . We also use remarketing services to advertise on third-party websites to you after you visited our Services. For this purpose, visitors are grouped by certain actions on our Services, e.g., by duration of a visit. This enables us to understand your preferences and to show you personalized advertising even if you are currently surfing on another website that also participates in the Google advertising network.
  • We use the following tools and services for these purposes:
    • Google Ads remarketing service is provided by Google. You can opt-out of this by visiting the Google Ads Settings page: https://www.google.com/settings/ads .
    • If Google Ads is structured to collect personal data, the data controller will be Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland.
    • Bing Ads is a service operated by Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. Please read Microsoft’s privacy statement for more information on how Microsoft processes your information https://privacy.microsoft.com/en-US/ . When you access our Site via advertisements on Bing Ads, a cookie is set on your computer. In addition, a Universal Event Tracking tag is integrated on our Site. This is a code that, in combination with the cookie, stores data about the use of the Site, e.g. length of time spent on the Site, areas accessed, and ads used to reach the Site. In addition, Microsoft may track your usage patterns across multiple of your electronic devices through so-called cross-device tracking. The information collected is transferred to a Microsoft server in the United States. If Bing Ads is structured to collect personal data, the cookie banner on our Services will provide you the opportunity to consent to Bing Ads.
    • Facebook Ads. Using Facebook Business Tools , we may show you interest-based ads when you use Facebook. To change your preferences or opt out of personalization for ads served by Facebook, you can visit Facebook Ads Preferences in addition to the Your Choices section below. We may also show ads to audiences who share similar characteristics to yours. To this end, a list of email addresses is irreversibly hashed encrypted and uploaded or transmitted from our site, and Facebook compares the hashed data with its users, generating a lookalike audience and deleting the uploaded list. We don't have access to the identity of anyone in the "lookalike" audience, unless they choose to click on one of our ads.
  • F. Other Tracking Technologies . We may also use Tracking Technologies to collect "clickstream" data, such as the domain name of the service providing you with Internet access, your device type, IP address used to connect your computer to the Internet, your browser type and version, operating system and platform, the average time spent on our Site, webpages viewed, content searched for, access times and other relevant statistics, and assign unique identifiers to the device or other credentials you use to access the Site for the same purposes.
  • Pages of our Site may also use Java scripts, which are code snippets embedded in various parts of websites and applications that facilitate a variety of operations including accelerating the refresh speed of certain functionality or monitoring usage of various online components; entity tags, which are HTTP code mechanisms that allow portions of websites to be stored or “cached” within your browser to accelerate website performance; and HTML5 local storage, which allows data from websites to be stored or “cached” within your browser to store and retrieve data in HTML5 pages when the website is revisited.
  • G. Do Not Track . Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT" signals have not been adopted, our Site does not currently process or respond to “DNT” signals.
  • H. Location Information . You may be able to adjust the settings of your device so that information about your physical location is not sent to us or third-parties by (a) disabling location services within the device settings, or (b) denying certain websites or mobile applications permission to access location information by changing the relevant preferences and permissions in your mobile device or browser settings.
4. Security Precautions
We maintain physical, electronic, and procedural safeguards designed to guard and prevent misuse of your personal information. Our security measures include industry-standard physical, technical, and administrative measures to prevent unauthorized access to or disclosure of your information.
The Internet is not an absolutely secure environment. We strongly recommend that you use a secure method and use a complex password to help us ensure the security of your account. We also strongly advise that you neither share your password with others nor re-use passwords on our Services that you use on other sites or apps, as doing so increases the likelihood of your being the victim of a credential stuffing attack or other malicious cyber behavior. If you feel that the security of your account or personal data has been compromised, please immediately contact us at our dedicated Privacy Center or as otherwise described in the Contact Us section below.
5. Your Rights
We attach great importance to your attention to personal information and do our best to protect your rights to access, correct, delete, cancel your account, and withdraw your consent to our processing your personal information so that you have the full ability to protect your privacy and security. To exercise your rights, you may contact us at our dedicated Privacy Center .
5.1 Access, Rectification, Portability, and Deletion of your Personal Information. You have the right to correct or update your personal data, object to processing of your personal data, ask us to restrict processing your personal data or to request portability of your personal data. To protect the privacy and the security of your personal data, we may request data from you to enable us to confirm your identity and your right to access such data, as well as to search for and provide you with the personal data we maintain upon your request. There are instances where applicable laws or regulatory requirements allow or require us to refuse to provide or delete some or all of the personal information that we maintain.
To exercise your rights, you may make updates within your customer account on the Site or App, or you may contact us our dedicated Privacy Center . If you no longer wish to be our customer, or cease using or accessing our Services, you can request us to close your account and delete all personal information we hold about you via the Privacy Center (See Section 10), subject to certain legal requirements.
5.2 Withdrawal of consent. You have the right to withdraw your consent to the processing of your personal data, as well as to access, correct, or delete the personal information that we collect, subject to certain exceptions.
Please be aware that there are instances where applicable laws or regulatory requirements allow or require us to refuse to provide or delete some or all of the personal information that we maintain.
5.3 Unsubscribe from Our Marketing Communications. If you no longer wish for us to use your email account to send you marketing emails or non-transactional promotional materials, please directly click on the unsubscribe link at the bottom of any of our email messages to you or contact us at our dedicated Privacy Center .
5.4 Object to the receipt of advertising brochures via traditional mail. If you no longer wish for us to use your postal address to send you marketing brochures by means of traditional mail, please contact Customer Service or (via the return address provided with each advertising brochure), to submit your request to unsubscribe from further postal advertising.
5.5 Lodging Complaints. If you believe we have infringed or violated your privacy rights, please contact us at our dedicated Privacy Center so that we may attempt to resolve any issues to your satisfaction. Notwithstanding the approaches of exercising your rights stated above or in the Privacy Center , this is without prejudice to your right to lodge a claim or complaint with the United Kingdom Information Commissioner’s Office (more details on the supervisory authority and its contact info can be found at https://ico.org.uk/).
6. Retention
We will retain your personal Data , including any correspondence you have with us, only for as long as is necessary for the purposes set out in this Policy, including retaining Personal Data in order to comply with our legal obligations, to resolve disputes,for information security purposes, and to and enforce our legal rights, terms, and policies.
7. Third-Party Websites
Our Apps or Site may contain links to third-party sites. This Policy does not apply to those third-party sites. We recommend that you read the privacy statements of any other sites that you visit as we are not responsible for the privacy practices of those sites.
8. Children
Our Services are not directed to, and we do not knowingly collect personal information from, children under the age of 16 or minors (as defined by applicable law). If you are a minor, please do not attempt to fill out our forms or send any personal information about yourself to us. If a minor has provided us with personal information without parental or guardian consent, the parent or guardian should contact us (See Section 10) immediately to remove the relevant personal information and unsubscribe the minor.
If we become aware that a minor has provided us with personal information, we will take steps to promptly delete such information from our files. As described further in our Terms and Conditions , please do not upload photographs showing other people, in particular if they are minors.
9. Transfer of Your Personal Data
When you access or use our Services, your personal data may be processed or transferred outside the United Kingdom, including to the United States, the European Union, China and/or Singapore. Some countries or jurisdictions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside.
For these transfers we rely on appropriate safeguards as permitted under the GDPR such as Standard Contractual Clauses, and/or we transfer the personal information pursuant to Article 49 (1) (b) of the GDPR to provide our Services pursuant to the Terms & Conditions. If you do not want your information transferred to, processed, or maintained outside of the country or jurisdiction where you reside, you should immediately stop accessing or using the Services. For further details about these transfers and the safeguards that we use to facilitate such transfers, please contact us at our dedicated Privacy Center .
10. Contact Us
If you have questions or concerns regarding any information in this Privacy Policy, please contact us at our dedicated Privacy Center .
Our Privacy Office can be contacted via the email address below or via our postal address below in writing:
ROMWE Privacy Office
12 Marina Boulevard,#15-01,
Marina Bay Financial Centre
Singapore 018982