Service: is the set, including but not limited to, the functionality made available by Roar via App or Website. It therefore includes (but is not limited to) the browsing experience, registration, consultation, content entry, purchase, product activation, deadline tracking,etc.

Environment: alternately App or Website.

Shop or Ecommerce: is the part of the Service dedicated to the remote sale of products or goods, regulated by the Distance Selling Terms and Conditions Agreement..

Terms and Conditions: is the document that governs the use of the Service.

Public: is the indeterminate set of individuals who can use the service.

Professional (also called Seller in some cases): is the person who prepares, manages and executes, directly or through the help of third parties, the online sales process and in general the Panesalmina.com Site. This is ROAR Europe Ltd.

User: is the person who uses the service. The User can also be a Registered User in case he/she uses the service after creating his/her own Account.

Buyer (also called Customer): is the person who purchases goods online for a fee. Before making the purchase, or activating the purchase procedure, then in just browsing the service, the same is referred to as the User.

Guest Logout: a procedure that allows purchase by unregistered Users by capturing shipping information from the payment provider (for example, where it is paypal, the good will be sent and accounted for at the name and address provided by the payment provider).

Beauty passport: set of physical, aesthetic and style characteristics, derived on the basis of what is indicated by the User according to preset options proposed by Roar to the User himself, which describe his profile.
Beauty wallet: section of the Service in which result the goods purchased by the Customer, with an indication of the date of purchase, NFC activation (see below), expiration of the product.
Whislist: List of goods "desired" expressly by the User by entering them, with the appropriate function made available by ROAR, in the wish list or Whislist precisely.

Video Tutorials: Demonstration and training videos to guide and teach the use of cosmetics, and in particular those offered for sale through the Service.

NFC activation: matching of the NFC chip embedded in the good (and containing its unique serial number of the individual piece and information about the individual product and production chain) to the App. It sends ROAR notification of successful activation, and thus deemed start of product use.

Feedback: Manifestation of approval (or not) of the product by the Customer. It can consist of either the posting of predefined ratings (stars, numbers, etc.), the "positive-negative" choice, or finally a comment about the Customer's user experience. Third-party services (such as Google, TrustPilot, and similar others) may also be used for feebacks.
Profiling: an automated process of analyzing the User's characteristics (from those indicated by the same in the Beauty Passport), other data (Purchase History, consumption, Beauty Passport changes, etc.) aimed at identifying the User's probable product preferences and sending the same Product recommendations or Video tutorials.



1.0 Foreword: IMPORTANT: The Service must be understood as an overall experience that is proposed to the User through both Site and App, which should therefore be considered complementary environments of experience and related to a Service that therefore remains unique. Therefore, the fact that some functionalities are usable exclusively in one Environment (App or Site) is only a choice oriented to improve the so-called User experience (see also what is indicated on the point in privacy policy, i.e., that "the data collected by the two environments converge in a single database, as the two environments are two points of data collection and service delivery that are part of a single overall project").

1.1 This service is governed by the following texts:

  • A) Navigation Terms and Conditions: they regulate the navigation of the User. They therefore indicate rules, rights, duties, obligations, burdens and faculties of the parties (where parties are understood to mean the Professional who manages the service on the one hand, and the clients and users who use it on the other) in relation to what is the experience - precisely - of browsing.
    It should be emphasized that the User cannot use the service without accepting these terms and conditions: the mere use of the service therefore implies implicit acceptance of the regulations provided for herein.
  • B) Distance Selling Conditions: is the text that regulates the conditions of sale of products in Ecommerce.
  • C) Information on the processing of personal data: contains all information required by law (and deemed appropriate by the Professional) in relation to personal data of the User or third parties.
  • D) Consent forms for the processing of personal data: in the event that the service makes use of the user's personal data beyond the minimum use necessary for the performance of the service itself or to comply with the law, it will be necessary to ask for consent from the User himself, who will be free to give it or not for each category of use provided by the professional, without preventing the User from using the service.
  • E) Alerts, disclaimers, pop-ups, push notifications and warnings: these are information that appear in different ways on the User's screen. Some of them are only intended to inform or draw the User's attention to particularly important aspects, others ask for explicit consent or otherwise positive action (such as closing the pop-up, selecting the "ok" button, or the like) from the User. The User himself is urged to always read such notices, and not to close them or give consent without learning their content.
  • F) Definitions: a list of terms of particular importance and the meaning given to them within and for the purposes of the legal relationship between ROAR and User.

1.2 All the above texts govern the service. Those who use, for whatever reason, the service must therefore read them all carefully.

1.3 In any case, the User is invited, before using the service or otherwise before making consents of any kind, to send a request for information where the contents of the above texts are unclear to the following address: legal@roarcosmetics.com

1.4 The Service is intended for both Consumer Users, i.e., individuals who use it for reasons unrelated to their business, and Professional Users (the Activities), i.e., individuals who use it for reasons related to their business. It may happen that some clauses apply only to one or the other category. In that case it will be specified whether the clause or text applies only to consumers or professionals, or whether it does not apply to either category. It is therefore understood that if no such specification is made, the clauses apply to both categories.



2.1 The above texts are written taking into account the state of the technical art, current law, and the status, characteristics, and economic capabilities of the Service. It is therefore entirely likely that over time change in any of these factors may impose or simply suggest a change in the texts. Indeed, it is not possible to guarantee that the texts (and the Service) will always remain the same. This, in fact, would force the service not to improve. Therefore, ROAR has the authority to change the terms and conditions and related texts. Changes will be notified to Users in advance. The Users themselves - if they do not intend to accept the new terms or otherwise the new texts - will be able to withdraw from the service, using the provided account deletion procedure. If, on the other hand - despite the notification - they continue to use the service, such use will be deemed to imply tacit acceptance of the change. Only where, in the opinion of the Manager (Professional), the changes result in a substantial change to the Service-User relationship, will they be asked to explicitly renew their acceptance of the terms.

2.2 You confirm that you have the right and ability to understand this document and that you are able to comply with all the terms and conditions contained herein, as well as all the texts mentioned above, and further ensure that you do not violate any laws or rules in force in your country of residence or otherwise use the service.



3.1 The official language of the service is Italian. Any texts written or readable in different languages are translations of the original text. Therefore, any interpretation of the clauses must be made taking into account the lexical and legal meaning that the words have in the Italian language.

3.1.1 Equally, customer care is rendered in Italian and English: therefore, Users who wish to write to the service should write in Italian and will be answered in those languages.

3.2 Any disputes that have as their object the legal relationship between the User and the Professional shall fall under the jurisdiction of the judge of the place of residence or domicile of the User Consumer, i.e., the person who interacts with the Service for reasons unrelated to his or her commercial, entrepreneurial, artisan or otherwise work activity.

3.2.1 Otherwise, where the dispute is between a Professional on the one hand, and a legal person, or otherwise a party not acting as a consumer (e.g. the Promoter User), the court of jurisdiction will be Mosta - Malta


ART. 4 CONTACTS and the Parties

4.1 The professional "ROAR Europe Limited" may be contacted at the following addresses:

Registered Office: The Victoria Centre, Unit 2, Lower Ground Floor, Valletta Road

E-mail: eu@roarcosmetics.com

4.2 The Registered User will be contacted at the e-mail address (or telephone number) declared by the User when registering for the Service. The e-mail address and telephone number declared by the User shall be understood as the computer address to which all communications, including e-mails and messages, sent by ROAR are addressed. Therefore, all communications that the service will make to the User will be addressed to the e-mail or telephone number indicated by the User, who will have the burden of reading them and communicating any changes in his or her e-mail.

4.3: The Service is currently provided by ROAR as specified above. It is the option of the owner of the service to alienate part or all of the Service, and it is understood that the assignee company shall succeed to all legal and business relations with Users, Assets, administrations, third parties, and collaborators to the assignor, and that no exception may be raised in this regard by or against the assignee. Therefore, it shall succeed to all rights, obligations, charges and faculties, as well as to all actions exercised or suffered by the assignor.

4.4: The Service may be used only by persons 16 years of age or older.

4.5: The Service provides for different figures of Users (see definitions) with different faculties and levels of use of the Service:

4.5.1: Guest User: is the individual user of the Service who uses it for browsing only.

4.5.2: Registered User: these are the Users who can perform certain actions provided by the site only upon activation of an account.



5.1 The Service consists of the provision of an App (called ROAR ID) and a website (www.roarcosmetics.com) that enable the following functions (not all functions are usable from both Environments for reasons of User Experience):

For Guest Users:

  • A) Browsing only in the form of browsing part of the Web Site;
  • B) Newsletter subscription;

5.2 For Registered Users, in addition to Guest functions (see definitions for description):

  • A) Account Creation;
  • B) Beauty Passport creation;
  • C) Using Beauty Wallet;
  • D) Wishlist;
  • E) Purchase products on the Online Shop;
  • F) Activating products with NFC;
  • G) Monitoring deadlines;
  • H) Product Recommendation or Video Tutorials;
  • I) Video Tutorial fruition;
  • J) Feedback Creation (possibly through or on third-party services such as Google, Truspilot, etc.);
  • K) Other functions (evolving) that will be proposed directly in the Service.

5.2 The service performs a statistical data processing activity (see privacy policy on the point to be aware of the type of data used) of usage, consumption, profile of users.

5.3 The service performs a Profiling activity to identify the products and videos considered suitable for the User's characteristics. These processes are the result of statistical analysis of the characteristics of the User and therefore the output has an indicative value. ROAR can therefore not be considered in any way responsible for the possible NON-appreciation by the User of recommended products or videos.

5.5 The browsing-only service is free of charge. This does not mean that the User is not asked to give up something of his/her own. In fact, ROAR may, subject to the User's consent and specific indication in privacy policy, use User's data for profiling purposes, transfer to third parties (see privacy policy), etc.

On this aspect, a clarification is necessary: the user "may" but "is not obliged" to give consent to the processing of data that are not indispensable for the provision of the service. This means that if the user denies consent to the transfer of data for marketing purposes the user can still use the service.

5.5.1 The service does not include provision of internet connection, but requires constant use of network connection and consumes data. Connection costs depend on the user's subscription. The onus is therefore on the user to monitor whether the thresholds included in his or her rate plan are exceeded. The service cannot be held accountable for any excessive data usage by the user in using the service.

5.6 Goods for sale in the Service are chargeable. The costs are indicated in the respective product sheets. Users are encouraged to consult the Terms and Conditions of Distance Selling document.

5.7 The service has a social page on Facebook, Instagram, Pinterest, Twitter and YouTube. Navigation on these pages responds to rules and terms provided by each social, it being understood that users, in case they are allowed to post content on the social page, must also comply with the rules and prohibitions provided in this text of terms and conditions.



6.1 Users may enroll in the Service after reaching the age of sixteen;

6.2 The User signs up with a single account that will allow access to both the App and the Website.

6.3 Registration for the service implies the provision of data (identification, etc.), while it is only optional to activate the Beauty Passport with the entry of aesthetic and style data. In case the Beauty Passport is not activated, it will not be possible to provide the User with personalized product recommendations or video Tutorials.

6.4 Once registered, the User may log in with e-mail and password. The responsibility for preserving the confidentiality of the password is entirely the responsibility of the User, who agrees never to use the account, username or password of other Users and not to disclose their password to third parties (it is represented that not even the administrators of the system are entitled to ask about credentials). the User also agrees to inform the administrators of the system immediately if they suspect that unauthorized access to their account has occurred. Responsibility for the use of the account, in any form, rests entirely with the User. The subscriber is expressly prohibited from alienating or transferring his or her account to third parties in any capacity. The subscriber is directly responsible for the preservation and secrecy of login credentials. Consequently, he/she is directly responsible for all activities that are put in place through his/her account even outside of his/her knowledge, which is assumed.
6.5 The data to be entered can be modified (only those that can be modified, of course) by accessing the User's personal page.
WARNING: Not all data can be modified. For example, first name, last name and data that cannot change cannot be changed.



7.1 The services provided do not expire, not even in case of inaction of the same User and failure to use them.

7.2 However, the termination of the Service may be caused either by the termination of the Service (for its own unquestionable business choices), or by the User's own request to unsubscribe through the appropriate functionalities or by means of an ACCOUNT CANCELLATION request to be sent to the following legal@roarcosmetics.com ATTENTION: since the account is unique for App and Website, the cancellation of the account in one of the two Environments implies the cancellation for the entire Service, and therefore the Account will be deleted also in relation to the other Environment.

7.2.1 In the event of a request for cancellation, the service will deactivate immediately, or in any case no later than 30 days after receipt of the request.

7.3 Deletion does not have retroactive effect, so the processing, and any communication or dissemination of data made up to the date of deletion in accordance with the consents given by the user remains legitimate. In addition, data that, according to the law, must be retained for a longer period of time (such as, for example, data related to business transactions, communications, any reports and follow-up activities, etc.) will still be retained beyond this period (but see privacy notices).

7.4 WARNING: Simply deleting or uninstalling the App does not in fact imply deletion of the Account, which will remain active.

7.5 In any event, ROAR reserves the right to cancel Accounts in the event of prolonged inactivity (i.e. non-access or browsing). In such case ROAR will send notice of cancellation to the User who may object to the cancellation in response to the notice received. In case of opposition the Account will not be deleted.

7.6 Finally, it is understood that aggregate data used for statistical purposes may as such be retained even after the Account is closed.



7bis.1 The right of access to the data of deceased persons is excluded in the cases provided for by law or when the deceased person has expressly prohibited it by written declaration communicated to the Data Controller. This prohibition may not produce detrimental effects on the exercise by third parties of their property rights arising from the death of the person concerned as well as' the right to defend their interests in court.



8.1 Registered users are expected to conduct themselves according to diligence and good faith.

8.1.1 In particular they:

  • may not activate accounts in other people's names, or otherwise using references that lead to a substitution of people (profile picture of others, etc.);
  • can not make purchases for the sole purpose of exercising the right of withdrawal later and harm ROAR;
  • in the case of feeback they should express opinions that are correct, truthful, not offensive, discriminatory, or violent, but should adhere to a fair, polite, and objective assessment of the good.


8.2 ROAR does not check the accounts, and does not verify that the identifying information matches the person actually enrolled.

8.2.1 In case of reports of violations of the above rules, without prejudice to the possibility of claiming compensation for any image damage suffered by ROAR, the following happens:

  1. ROAR receives the Report and independently assesses its truthfulness or at least its plausibility and will take action to identify the person responsible (in any case, the service is understood to be explicitly authorized by the user who has put in place the reported violation to cooperate and communicate data requested by Public Authorities, including administrative ones, as well as by defenders - only in case of criminal relevance of the fact and if provided with regular appointment and pursuant to and for the purposes of articles 327 bis c.p.p.).
  2. ROAR will send the identified User a notice stating the conduct complained of and the rule violated. ROAR will not be required in such a case to inform the User of the particulars of the reporter.
  3. The reported User may respond (if he does not respond within the allotted time, his response will be understood as tacit admission of the conduct attributed to him);
  4. Based on the response ROAR will decide whether to dismiss the Report or proceed with the sanction;
  5. Depending on the severity (and possible repetitiveness, especially if preceded by other sanctions) of the reported conduct ROAR may then (multiple sanctions may also be taken):
  • A) Send a simple recall;
  • B) Inhibit some functions (such as purchases, feedback);
  • C) Suspend the account;
  • D) Delete account (retaining generalities for subsequent attempts to activate another account).



9.1 ROAR's liability for the following is excluded:

9.1.1 On system operation: ROAR does not guarantee that the service will work properly. It may happen that - due to variable causes (such as, for example, a line drop or server shutdown, such as due to causes attributable to Apple, etc.) - the service is interrupted. In this case, ROAR cannot be held liable for any damages that may be suffered by users or third parties as a result of the service failure. In fact, ROAR is not able to guarantee constant and perfect service.

9.1.2 On costs: Connection costs depend on the user's subscription. It is the user's responsibility, therefore, to monitor any exceeding of the thresholds included in his or her rate plan. ROAR cannot be held liable for any excessive data usage by the user in using the service.

9.1.3 About Links: ROAR may contain links to other sites, resources and shopping opportunities belonging to third parties posted on the Service. Upon clicking such links, you may be redirected to third party services that are governed by their own terms of use and privacy policies that differ from those of the Service. The posting of third-party links does not imply endorsement by ROAR of the content, sites, or resources provided by them. ROAR informs all users that it has no control over the content of third-party sites or resources and that it is not responsible for the items just mentioned or for the compliance of such sites with applicable laws and regulations. ROAR therefore urges users to check the policies and terms of use governing such third-party services. Note that landing on such third-party services (sites, apps or the like) activates a third-party and exclusive legal relationship between them and the user.

9.1.4 ROAR provides indications and suggestions of products that, based on the data received from the User and collected by the Service, it considers suitable for the User's characteristics. Since these are evaluations made through automated methods that are based on statistics and make a judgment of probability, ROAR may not be held liable in any way, not even by recasting the price, in the event that the product recommended and then purchased does not meet the Customer's expectations or tastes.

9.1.5 Because ROAR cosmetics are highly innovative products, and because they propose a new concept of the cosmetic user experience (by means of concentrating cosmetics usually divided into several units in one good), the User assumes all responsibility and risk in the use of the cosmetics themselves and therefore cannot claim from ROAR any damages, compensation or recoupment of the price where the use of the product does not meet its expectations or tastes.



10.1 The Service hosts content of various types. In particular, templates, texts, photographs, videos are hosted on the Service. All rights of economic use of the authored content on the Service belong exclusively to ROAR.

10.2 In any case, the text, graphics, interfaces, trademarks, logos, videos, texts, sound effects, if any, design and software for the realization of the Service are the exclusive property of ROAR and are therefore subject to intellectual property rights in the same. ROAR grants the User a royalty-free, non-transferable and non-exclusive personal license for the sole purpose of enabling the User to make use of the Service and as far as may be necessary to do so. The license shall be for the sole purpose of enabling the User to use and enjoy the Services as provided by ROAR in the manner permitted by these Terms. No other rights are then granted to the User. Any other use must be authorized in writing by the service provider.

10.3 ROAR reserves the use of the data and metadata contained in, or otherwise detectable or obtainable through use, access, browsing of the Service.

All forms of automated data mining operating on data, metadata, and content on the Service are therefore prohibited.

10.4 The datasets collected in the Service, as well as the statistical outputs, constitute the exclusive property of the ROAR Owner, and may not be used by third parties unless explicitly authorized, even for consideration, by ROAR itself.

10.5 As such data sets are created from information conferred by the User and information gleaned from the User's browsing, purchasing and consumption experience, the User himself declares that he accepts such use of data as a necessary part of a complete and satisfactory rendering of the Service (vis-à-vis his own and in general the Users who benefit from a constantly improving Service) and declares that he does not claim anything, in the form of compensation, consideration, indemnification or other form of payment for such uses by ROAR or third parties authorized by ROAR.

10.6 The User expressly authorizes, by using the service and accepting these terms of use, ROAR to allow third party companies access to the database containing the data sets referred to in the preceding paragraphs, on the condition that such access is carried out after pseudonymization of the data in such a way as to make it difficult for third parties authorized for access to re-identify the User. In any case, the User disclaims to authorize such use, as well as any use of the data for statistical purposes, without claiming any consideration, compensation or other form of remuneration or payment, considering himself fully remunerated through the provision of the Service by ROAR.


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