Privacy policy

This Privacy Policy explains how Roma Costume, Inc. ("Roma Costume," "Roma,"
"we," "us," or "our") collects, uses, shares, and protects information when
you visit romacostume.com (the "Site"), open or use a wholesale account, place
an order, participate in our drop ship program, sign up for our emails, or
otherwise interact with us.

Roma Costume is a wholesale manufacturer and distributor. This Site and this
Policy are directed to businesses and business buyers — retailers,
distributors, and drop shippers — and to the individuals who act on their
behalf. Our separate retail store operates under its own privacy policy.

Roma Costume is a United States business and this Policy is written for
customers in the United States. See Section 16.

1. INFORMATION WE COLLECT FROM YOU

We collect information you give us directly, including:

Business account information. When you apply for or maintain a wholesale
account, we collect your company name and trade name, business type and
structure, business address, business email address and phone number, website
and social media accounts, federal employer identification number or other tax
identification number, seller's permit or resale certificate, business
license, sales tax exemption documents, estimated order volume, and the retail
channels in which you sell.

Credit and payment terms information. If you apply for credit terms, we
collect the information in your credit application, including bank references,
trade references, credit history you provide, personal guarantees where
requested, and the results of any credit checks we obtain.

Buyer contact information. We collect the name, job title, business email
address, and business phone number of the individuals authorized to place
orders, receive invoices, or manage the account on your company's behalf.

Order information. We collect the products you buy, quantities, sizes, order
and reorder history, purchase orders, shipping and billing addresses, routing
instructions, and delivery preferences.

Account credentials. We collect your username and password. See Section 7 for
how we treat account credentials.

Payment information. The card or bank details you enter at checkout are
transmitted directly to our payment providers. We receive only limited
information such as the last four digits of the account, the card brand, and
the billing ZIP code. Bank account information you provide on a credit
application is collected by us directly. See Section 8.

Drop ship information. If you participate in our drop ship program, you
provide us with the name, shipping address, and order details of your own
customers so we can ship on your behalf. See Section 6 for how we handle that
information.

Communications. We collect messages, emails, chat transcripts, returns and
claims correspondence, and customer service tickets you send us, including any
images you attach.

Marketing preferences. We collect your subscription status for our email list
and the product categories you tell us you are interested in.

We collect this information because we need it to evaluate and open your
account, verify your resale status, fulfill your orders, extend and manage
credit, respond to your requests, and meet our legal obligations. If you
choose not to provide certain information, we may not be able to open a
wholesale account or process your order.

2. INFORMATION WE COLLECT AUTOMATICALLY

When you visit the Site, we and our service providers automatically collect
certain information about your device and your activity, including:

- Device and connection data: IP address, device type, operating system,
  browser type and version, screen resolution, language settings, and unique
  device or advertising identifiers.
- Usage data: the pages and products you view, the links you click, search
  terms you enter, items you add to your cart, referring website, time zone,
  and the dates and times of your visits.
- Approximate location: a general geographic location (such as city, state,
  or country) inferred from your IP address. We do not collect precise GPS
  location from the Site.
- Cookies and similar technologies: cookies, pixels, web beacons, tags, local
  storage, and software development kits placed by us and by our partners.
  See Section 9 for details.

We collect this information whether or not you have a wholesale account.

3. INFORMATION WE RECEIVE FROM THIRD PARTIES

We may receive information about you or your business from:

- Our e-commerce platform and hosting provider, which processes orders,
  accounts, and site activity on our behalf.
- Payment processors and fraud-prevention providers, which return
  authorization results, fraud risk scores, and chargeback information.
- Credit reporting agencies, commercial credit bureaus, and the bank and
  trade references you give us, when you apply for credit terms.
- State tax authorities and verification services, when we validate a resale
  certificate or seller's permit.
- Shipping and freight carriers, which provide delivery status and address
  validation.
- Advertising, social media, and analytics platforms, which provide campaign
  performance data and audience information.
- Wholesale marketplaces and retail partner platforms through which you place
  orders, which supply us with your buyer identity and contact details.
- Trade shows, showroom and sales representative networks, industry
  directories, publicly available sources, and business partners, where
  permitted by law.

4. HOW WE USE YOUR INFORMATION

Except for drop ship customer information, which we use only as described in
Section 6, we use the information we collect to:

- Evaluate wholesale account applications and verify that an applicant is a
  legitimate reseller, including validating resale certificates, seller's
  permits, and business licenses.
- Assess creditworthiness, set and adjust credit limits and payment terms,
  invoice you, and collect amounts owed.
- Create and manage your account, authenticate users, and control who may
  place orders on the account.
- Process, fulfill, ship, and track orders, including drop ship orders sent
  to your customers, and handle returns, exchanges, credits, and defect or
  shortage claims.
- Communicate with you about orders, shipments, back-orders, line sheets,
  new releases, restocks, and customer service inquiries.
- Send you marketing emails about new collections, seasonal lines, closeouts,
  and trade shows, and measure how you engage with them.
- Operate, maintain, secure, test, and improve the Site and our products.
- Detect, investigate, and prevent fraud, unauthorized reselling, chargebacks,
  unauthorized account access, and other illegal or prohibited activity.
- Perform analytics, forecast demand, plan production, and measure
  advertising performance.
- Comply with our legal obligations, including tax, sales and use tax,
  accounting, customs, product safety, and record-keeping requirements, and
  establish, exercise, or defend legal claims.

We do not use your information to develop or train our own artificial
intelligence models, and we do not sell or license it to anyone for the
purpose of training their models. Some vendors we use may improve their own
services, including machine learning features, using data they process on our
behalf, as permitted by their terms.

5. EMAIL AND DIRECT MARKETING

If you subscribe to our list, open a wholesale account, or place an order, we
may send you promotional emails about new collections, seasonal lines,
closeouts, catalog and line sheet releases, and trade show appearances.

You can opt out at any time by clicking the "unsubscribe" link at the bottom
of any marketing email, or by emailing us at Sales@RomaCostume.com. We will
honor your request within ten business days. Opting out of marketing does not
stop transactional messages about an account or order, such as order
confirmations, shipping notices, invoices, statements, and collections
correspondence.

6. HOW WE MAY SHARE INFORMATION

We do not exchange your personal information for money. However, because we
use advertising and analytics cookies and pixels, our sharing of online
identifiers, activity data, purchase information, and the preferences we infer
from them with advertising platforms is treated as a "sale" or "sharing" of
personal information under California law, and as "targeted advertising" under
other state privacy laws. You can opt out at any time — see Sections 10
and 13.

We share information in the following ways:

- Service providers. We share information with companies that perform
  services for us, including our e-commerce platform and hosting provider,
  payment processors, fraud-prevention services, shipping and freight
  carriers, warehouse and fulfillment vendors, accounting and collections
  providers, email marketing platforms, security and anti-fraud tools such as
  the CAPTCHA on our contact form, and analytics providers. We require these
  companies by contract to use the information only to provide services to us
  and not for their own purposes.
- Affiliated brands and commonly operated companies, where you place a
  combined order across our brands or where we fulfill from a shared facility.
- Wholesale marketplaces, retail partner portals, independent sales
  representatives and showroom agencies who represent our lines, and the feed
  and integration providers that connect us to them. Marketplaces and sales
  representatives use buyer contact information for their own purposes as
  well as ours.
- Factors, receivables finance companies, credit insurers, and asset-based
  lenders, in connection with financing or insuring our accounts receivable.
- Credit and collections. We share credit application information with
  commercial credit bureaus, the references you provide, credit insurers, and,
  if an account becomes delinquent, with collection agencies and our
  attorneys. We may also report your payment history to commercial credit
  bureaus.
- Advertising and analytics partners. We share online identifiers, device
  information, and browsing or purchase activity with advertising networks,
  social media platforms, and analytics providers so we can measure
  performance and show relevant ads.
- Legal and safety. We may disclose information if we believe disclosure is
  required by law, subpoena, court order, or other legal process; to
  cooperate with law enforcement, tax authorities, or regulators; to enforce
  our Terms of Service or our agreements with you; or to protect the rights,
  property, or safety of Roma Costume, our customers, or the public.
- Business transfers. If we are involved in a merger, acquisition,
  financing, reorganization, bankruptcy, or sale of all or part of our
  assets, information may be transferred as part of that transaction.
- With your direction or consent. We share information in other ways when you
  ask us to or agree to it.

Drop ship customer data. When you send us the names and addresses of your
customers so that we can ship on your behalf, we act as your service provider
under a written contract that limits what we may do with that information. We
use it only to pick, pack, ship, and track the order, to handle returns and
claims, and to comply with law. We do not use it for our own marketing, we do
not add those individuals to our email list, and we do not sell or share it.
You remain responsible for having a lawful basis to give us that information
and for the privacy notice you provide to your own customers. If one of your
customers contacts us directly about their information, we will tell them we
cannot act on the request and will refer them to the retailer that placed the
order. We also share this information with the carriers and international
consolidators that deliver the shipment.

7. SENSITIVE PERSONAL INFORMATION

Under California law, "sensitive personal information" includes account log-in
credentials and a payment card or financial account number in combination with
a security or access code. Card and account numbers and security codes entered
at checkout are transmitted directly to our payment providers; we do not
retain them. Bank account and financial information you provide on a credit
application is collected by us directly and retained as described in
Section 12. We collect account credentials only to create and secure your
account.

We do not use this information to infer characteristics about any individual,
and we use and disclose it only for the purposes described in this Section.
Because some of those purposes — evaluating and securing credit, reporting
payment history, and collections — go beyond what California law permits
without a right to limit, you may direct us to limit our use and disclosure of
your sensitive personal information. See Section 13.

Where a credit application includes a personal guarantee, we may collect a
Social Security number and personal financial information from the guarantor.
We use that information only to evaluate and secure the credit we extend. We
share it only with credit bureaus, credit insurers, our advisors, and — if the
account becomes delinquent — collection agencies and our attorneys, as
described in Section 6. We do not include a guarantor's Social Security number
in any inquiry we make to a trade or bank reference, and we store guarantor
information with access restricted to the staff who need it.

We do not seek to collect information revealing racial or ethnic origin,
religious or philosophical beliefs, union membership, health or medical
information, genetic or biometric data, citizenship or immigration status, or
data concerning sex life or sexual orientation. Please do not submit this
information to us.

8. PAYMENT AND CREDIT INFORMATION

Payments on the Site are processed by third-party payment providers. When you
enter payment card or bank account details at checkout, that information is
transmitted directly to the payment provider. We do not store full payment
card numbers or card security codes on our systems. Bank account information
you provide on a credit application is collected and retained by us as
described in Sections 7 and 12. From checkout we receive limited information
such as the last four digits, the card brand, the billing ZIP code, and
whether the transaction was approved. Your use of a payment provider is also
governed by that provider's own privacy policy and terms.

If you apply for credit terms, we obtain and use commercial credit reports
about your business and, where you provide a personal guarantee, a consumer
credit report about the guarantor with the guarantor's written authorization.
If we decline your credit application or approve it on terms other than those
you requested, we will notify you as required by the Equal Credit Opportunity
Act and Regulation B, and will provide a statement of the specific reasons for
that decision on request. Commercial credit reports about a business are not
"consumer reports" under the Fair Credit Reporting Act. Where we obtain a
consumer report about a personal guarantor, we use it only to evaluate that
guarantee, we tell the guarantor which reporting agency supplied it and how to
obtain a free copy and dispute its accuracy, and we dispose of it securely.
Where a report about a sole proprietor, or a blended report, includes an
individual's personal credit information, we treat it as a consumer report.

9. COOKIES AND TRACKING TECHNOLOGIES

Cookies are small text files placed on your device that let a site recognize
your browser and remember information about your visit. We use:

- Strictly necessary cookies, which are required for the Site to work,
  including cookies that keep you logged in, maintain your cart, apply your
  wholesale pricing, and protect against fraud. These cannot be turned off
  through our Site.
- Performance and analytics cookies, which tell us how visitors use the Site
  so we can improve it.
- Functional cookies, which remember your preferences such as region,
  language, and previously viewed items.
- Advertising cookies and pixels, which are used by us and our advertising
  partners to measure campaigns and show ads on other sites and apps.

Some of these technologies are operated by third parties who receive
information about your interaction with the Site directly. By using the Site,
you consent to that collection.

You can manage cookies through your browser settings, including deleting
existing cookies and blocking new ones, and through the opt-out options in
Section 10. Blocking cookies may cause parts of the Site to stop working
correctly, including wholesale pricing. Independent information about cookies
is available at allaboutcookies.org.

10. INTEREST-BASED ADVERTISING AND YOUR CHOICES

We work with advertising platforms to show ads for our products on other
websites, apps, and social media. These partners may use cookies, pixels, and
advertising identifiers to build a profile of your interests.

Global Privacy Control. We are implementing support for the Global Privacy
Control (GPC) signal, which lets your browser tell every site you visit that
you want to opt out of the sale and sharing of personal information. Until
that support is complete, please use the "Your Privacy Choices" link or email
us, and we will apply your opt-out. We do not require you to verify your
identity or create an account to opt out.

Do Not Track. Some browsers send a "Do Not Track" signal. There is no common
industry standard for how to respond to it, and we do not currently respond to
Do Not Track signals. See above for how to opt out.

You can also limit interest-based advertising by:

- Using the "Your Privacy Choices" link in the footer of any page on the Site
  to submit an opt-out request.
- Emailing Sales@RomaCostume.com with the subject line "Do Not Sell or Share
  My Personal Information."
- Adjusting the ad settings offered by the advertising and social media
  platforms you use.
- Using the industry opt-out tools at optout.aboutads.info (Digital
  Advertising Alliance), optout.networkadvertising.org (Network Advertising
  Initiative), and youradchoices.com/appchoices for mobile apps.
- Enabling "Limit Ad Tracking" or an equivalent setting on your mobile
  device.

Opting out means you will see less relevant ads, not fewer ads. If you are
signed in to your account when you opt out, or you give us your email address
with your request, we apply your opt-out to the profile we maintain for you as
well as to that browser or device. If you are not signed in, your opt-out
applies to that browser or device, and you may need to renew it if you clear
your cookies or use a different browser.

11. CHILDREN'S PRIVACY

The Site is a business-to-business site intended for adults acting on behalf
of a business. We do not knowingly collect personal information from anyone
under 13, and we do not knowingly sell or share, or process for targeted
advertising, the personal information of any consumer under 18. If we learn
that we have collected information from a child under 13, we will delete it
promptly. If you believe a child has provided us with personal information,
contact us at Sales@RomaCostume.com.

12. DATA RETENTION

We keep information only as long as we need it for the purposes described in
this Policy. Our retention periods are:

- Order, invoice, and transaction records: 7 years from the date of the
  transaction, to meet tax, sales and use tax, accounting, and customs
  requirements.
- Resale certificates, seller's permits, and exemption documents: for as long
  as the account is open and 7 years after it closes, because tax authorities
  may audit exempt sales for that period.
- Credit applications, credit reports, and payment history: 7 years from the
  date the account closes or the last activity, whichever is later.
- Wholesale account and buyer contact information: for as long as the account
  is active, then 24 months after closure so we can resolve disputes and
  prevent fraud.
- Drop ship customer information: 18 months from shipment, so we can handle
  returns, claims, and carrier disputes, unless you ask us to delete it
  sooner.
- Customer service records and communications: 3 years from the last contact.
- Marketing contact information: until you unsubscribe. We keep a suppression
  record indefinitely so that we do not contact you again by mistake.
- Cookie, analytics, and advertising data: up to 24 months, or the shorter
  period set by the relevant platform.

When we no longer need information, we delete it or aggregate it so it no
longer identifies anyone. We dispose of credit reports, guarantor information,
and other sensitive records by shredding, burning, or secure erasure.

We may retain the minimum contact and order information needed to identify and
notify purchasers in the event of a product safety recall or a report to the
Consumer Product Safety Commission, for as long as that obligation may apply.

We may also retain information longer where necessary to resolve a dispute,
collect a debt, prevent fraud, or comply with a legal obligation.

13. YOUR PRIVACY RIGHTS

Business contacts are covered in California. California's exemption for
business-to-business contact information has expired. If you are a California
resident whose information we hold because you work for one of our wholesale
customers, suppliers, or partners, you have the same rights described below as
any other consumer, and we handle your request the same way. Other state
privacy laws generally do not cover individuals acting in a commercial
capacity.

This Policy does not cover personal information we collect from job applicants
or employees, which is described in a separate notice.

Depending on where you live, you may have some or all of the following rights:

- Right to know or access the personal information we have collected about
  you, including the categories, sources, purposes, and recipients.
- Right to correct inaccurate personal information.
- Right to delete personal information we have collected from you, subject to
  legal exceptions. Those exceptions include completing a transaction,
  detecting and preventing fraud and security incidents, resolving disputes,
  collecting a debt, keeping a suppression record so we can continue to honor
  your opt-out, and complying with tax, accounting, credit, and other legal
  obligations. Section 12 describes how long we keep each type of record.
- Right to obtain a portable copy of your information.
- Right to opt out of the sale or sharing of personal information and of
  targeted advertising and certain profiling.
- Right to withdraw consent you have given us, such as consent to receive
  marketing email (see Section 5).
- Right to limit our use and disclosure of sensitive personal information to
  the purposes permitted under California law. To exercise it, use the "Limit
  the Use of My Sensitive Personal Information" link in our footer or email us
  with the subject line "Limit Sensitive Information."
- Right not to receive discriminatory treatment for exercising your rights.

CALIFORNIA DISCLOSURES

In the twelve months before the date of this Policy:

Categories of personal information we collected: identifiers (name, job title,
business email address, business phone number, business address, IP address,
account and device identifiers, and — for drop ship orders placed by our
wholesale customers — the name and shipping address of the individual
recipient); customer records; commercial information (products purchased,
considered, or returned, and order history); financial
information (payment and credit application details); professional or
employment-related information (job title, employer, purchasing authority);
internet or other electronic network activity (browsing and search history and
interactions with the Site and our ads); audio, electronic, and visual
information (chat transcripts, support tickets, and images submitted with
claims); approximate geolocation; sensitive personal information (account
credentials, and Social Security numbers where a personal guarantee is given,
as described in Section 7); and inferences drawn from the non-sensitive
categories above, such as product and category preferences.

Categories we disclosed for a business purpose, and the recipients: all of the
categories above — except sensitive personal information, which we disclose
only to our e-commerce platform and hosting provider, our payment processors,
our fraud-prevention providers, and, for guarantor information, credit
bureaus, credit insurers, collection agencies, and our advisors — disclosed to
our e-commerce platform and hosting provider, payment processors,
fraud-prevention providers, credit bureaus and collections providers, factors,
receivables finance companies, credit insurers and asset-based lenders,
shipping and freight carriers, warehouse and fulfillment vendors, affiliated
and commonly operated companies, wholesale marketplaces and retail partner
portals, independent sales representatives and showroom agencies, customer
support platforms, email marketing platforms, analytics providers, and our
professional advisors. Drop ship customer information goes only to our
e-commerce platform and hosting provider, our warehouse and fulfillment
vendors, and the carriers and consolidators that deliver the shipment.

Categories we sold or shared, and the third parties: online and device
identifiers (including IP address, cookie identifiers, and advertising IDs)
and, for audience matching, hashed business email addresses; internet or other
electronic network activity; commercial information; and inferences about
product preferences — shared with advertising networks, social media
platforms, and analytics providers for cross-context behavioral advertising.
We do not sell or share sensitive personal information, we do not sell or
share credit application information, and we do not sell or share drop ship
customer information.

Shine the Light. California residents may request information about personal
information we disclosed to third parties for their own direct marketing
purposes. We do not disclose personal information for that purpose.

U.S. STATE PRIVACY LAWS

Residents of states with comprehensive consumer privacy laws — including
California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky,
Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon,
Rhode Island, Tennessee, Texas, Utah, and Virginia — may exercise the rights
available under their state's law. Additional states have passed laws that
take effect after the date of this Policy. If you live in a state with a
comprehensive privacy law, contact us and we will tell you which rights apply
to you.

If you are an Oregon or Minnesota resident, you may request a list of the
specific third parties to which we have disclosed your personal data. If you
are a Connecticut resident, you may request a list of the third parties to
which we have sold your personal data. If you are a Colorado, Connecticut, or
Minnesota resident, you may have rights regarding profiling that produces
legal or similarly significant effects. Credit decisions that we make are
reviewed by a person. Where you buy through a third-party wholesale
marketplace, that marketplace may make its own credit decisions about you
using automated processing under its own terms.

Nevada residents may submit a verified request that we not sell covered
information by emailing Sales@RomaCostume.com with the subject line "Nevada
Opt-Out." We do not currently sell covered information as Nevada law defines
it.

HOW TO EXERCISE YOUR RIGHTS

Email Sales@RomaCostume.com with the subject line "Privacy Request," call us
toll-free at 1-866-699-ROMA, or write to us at the address in Section 18. Tell
us which right you want to exercise and give us enough information to find
your records, such as the email address or account number associated with your
business.

We confirm receipt of a request to know, correct, or delete within ten
business days.

We verify your identity before acting on a request to know, correct, or
delete. We do not require verification for a request to opt out of the sale or
sharing of your information, and we never require you to create an account to
submit one.

We respond within 45 days. Where the law allows an extension and we need one,
we will tell you before the original deadline.

Authorized agents. You may use an authorized agent to submit a request for
you. We may ask the agent for proof of authorization and may ask you to
confirm the request directly.

Appeals. If we decline to act on your request, we will tell you why, and you
may appeal by replying to our response or emailing Sales@RomaCostume.com with
the subject line "Privacy Appeal." We will respond in writing within 45 days
of receiving your appeal and explain our decision, or sooner where your
state's law requires. If we deny your appeal, we will give you a method to
submit a complaint to your state Attorney General.

14. SECURITY

We maintain administrative, technical, and physical safeguards designed to
protect information, including access controls and monitoring of our systems.
Credit application materials and guarantor information are held with access
limited to the staff who need them. No method of transmission or storage is
completely secure, so we cannot guarantee
absolute security. Please protect your account by using a strong, unique
password, by not sharing it, and by telling us promptly when an employee who
had account access leaves your company. Do not send full payment card numbers,
bank account numbers, or Social Security numbers to us by email.

If a security incident affects your personal information, we will notify you
and the appropriate authorities as required by applicable state law.

15. THIRD-PARTY LINKS AND SERVICES

The Site may contain links to third-party websites, social media pages, and
services that we do not control. This Policy does not apply to those sites,
and we are not responsible for their content or their privacy practices. We
encourage you to review the privacy policy of any site you visit.

16. WHERE WE OPERATE

Roma Costume, Inc. is located in the United States, and this Site and our
services are directed to customers in the United States. We do not offer goods
or services to, or monitor the behavior of, individuals in the European
Economic Area, the United Kingdom, or Switzerland.

We store and process information in the United States. If you access the Site
from outside the United States, you understand that your information will be
handled in the United States, where privacy laws may differ from those where
you live. If you believe we hold information about you and you are located
outside the United States, contact us at Sales@RomaCostume.com.

17. CHANGES TO THIS POLICY

We may update this Policy from time to time. When we do, we will revise the
"Last Updated" date at the top of the page and post the updated Policy on the
Site. If the changes are significant, we will provide a more prominent notice,
which may include emailing account holders. Where the law requires consent for
a materially new use of information we have already collected, we will ask for
it before making that change.

18. CONTACT US

If you have questions about this Policy or how we handle information, contact
us:

Roma Costume, Inc.
2501 N. Ontario St.
Burbank, CA 91504
United States

Email: Sales@RomaCostume.com
Toll-free: 1-866-699-ROMA

The California disclosures in Section 13 describe our practices for
romacostume.com. Our retail store at romaretailshop.com is described in its
own privacy policy.

If you have a disability and need this Policy in an alternative format,
contact us at Sales@RomaCostume.com or 1-866-699-ROMA and we will provide it.