Image Skincare California Privacy Notice

Effective Date: January 1, 2021

This California Privacy Notice (“Notice”) applies to “Consumers” as defined by the California Consumer Privacy Act (“CCPA”) and, with respect to Section 4 of this Notice only, certain other Californians as a supplement to Image International Manufacturing, LLC’s and its affiliates’ and subsidiaries’ (collectively referred to as “Image Skincare” “us” “we” “our”) other privacy policies or notices. In the event of a conflict between any other Image Skincare policy, statement or notice and this Notice, this Notice will prevail as to California Consumers and their rights under the CCPA. Please see also any general privacy policy or notice posted or referenced on our websites, apps, products, or services including, without limitation, https://imageskincare.com/pages/privacy.

Sections 1 and 2 of this Notice covers our collection, use, disclosure, and sale of California Consumers’ “Personal Information” (“PI”) as defined by the CCPA, except to the extent such PI is exempt from the notice obligations of the CCPA, for the twelve months preceding the Effective Date. Sections 3 and 4 of this Notice also explain the rights California Consumers have under the CCPA, and provides other notices to Californians required by other laws. The description of our data practices in this Notice, as required by the CCPA, covers only calendar year 2020 through the Effective Date and will be updated annually. Our practices in calendar year 2021 after the Effective Date may differ; however, if materially different from this Notice we will provide pre-collection notice of the current practices, which may include reference to our general privacy policy or other applicable privacy notices, which will reflect current practices.

Consistent with the CCPA, job applicants, current and former employees and independent contractors (“Personnel”), and subjects of certain business-to-business communications acting solely in their capacity as representatives of another business, are not considered “Consumers” for purposes of this California Privacy Notice or the rights described herein. However, our Personnel may obtain information by contacting our Human Resources department. Publicly available information is also not treated as PI under the CCPA, so this notice is not intended to apply to that data and your Consumer privacy rights do not apply to that data.

To aid in readability, in some places we have abbreviated or summarized CCPA terms or language, but a full copy of the CCPA is available at Title 1.81.5 of the California Civil Code, Sections 1798.100 - .199 for your review. Terms defined in the CCPA that are used in this Notice with initial capitalizations shall have the same meaning as in the CCPA.

You can click on the following blue links to navigate to the different sections in this Notice.

Table of Contents

1. PI We Collect 
   1. Sources of PI 
   2.  Purposes
2. Sharing of PI 
3. California Privacy Rights 
   1. The Right to Know
      1. Categories 
      2. Specific Pieces 
   2.  Do Not Sell
   3. Delete
   4. Non-Discrimination and Financial Incentive Programs 
   5.  Authorized Agents 
   6. Our and Others' Rights
4. Additional California Notices
   1. Third Party Marketing and Your California Privacy Rights
   2. Online Privacy Practices
      • Tracking and Targeting
      • California Minors
   3. eCommerce
5. Contact Us

Based on our 2020 data practices, we give you notice that we collect the following types of PI about California Consumers. This notice will be updated annually, and our current privacy notices at the point of collection, and general privacy policies, may reflect more current practices.

The chart above reflects that categories of PI required by the CCPA. There may be additional information that we collect that meets the CCPA’s definition of PI but is not reflected by a category, in which case we will treat it as PI as required by the CCPA, but will not include it when we are required to describe our practices by category of PI.

As permitted by applicable law, we do not treat deidentified data or aggregate consumer information as PI and we reserve the right to convert, or permit others to convert, your PI into deidentified data or aggregate consumer information, and may elect not to treat publicly available information as PI. We have no obligation to re-identify information or keep it longer than we need it to respond to your requests.

Return to navigation

We may collect your PI directly from you or from service providers, vendors and suppliers, our affiliates, or other individuals and businesses, social networks, advertising networks, data analytics providers, data brokers as well as public sources of data such as government entities.

Return to navigation

Generally, we collect, retain, use, and share your PI to provide you services and as otherwise related to the operation of our business. For more detail on our disclosure of PI, see the next section Sharing of PI. 

We may collect, use and share the PI we collect for one or more of the following business purposes:

• Processing Interactions and Transactions;
• Services and Operations;
• Research and Development;
• Quality Assurance;
• Security and Audit Compliance;
• and Debugging.

Additional Business Purposes include sharing PI with third parties for other than a sale or one of the foregoing Business Purposes as required or permitted by applicable law, such as to our vendors that perform services for us, to the government or private parties to comply with law or legal process, to the consumer or other parties at the consumer’s request, for the additional purposes explained in our Privacy Policy, and to assignees as part of a merger or asset sale (“Other Business Purposes”).

Subject to restrictions and obligations of the CCPA, our vendors may also use your PI for some or all of the above listed Business Purposes. Our vendors may themselves engage Services Providers or subcontractors to enable them to perform services for us, which sub-processing is, for purposes of certainty, an Other Business Purpose for which we are providing you notice.

In addition, we may collect, retain, and use PI for the purpose of sharing it as set forth in the next section.

Return to navigation

We may share PI with our service providers, other vendors, and/or affiliates, including without limitation during calendar year 2020 as follows:

Return to navigation

The CCPA is a new law and there remain differing interpretations of it and the regulations that implement it. Accordingly, we may from time-to-time update information in our notices regarding our data practices and your rights, modify our methods for you to make and for us to respond to your requests, and/or supplement our response(s) to your requests, as we continue to develop our compliance program to reflect the evolution of the law and our understanding of how it relates to our data practices.

We provide California Consumers the privacy rights described in this section. You have the right to exercise these rights via an authorized agent who meets the agency requirements of the CCPA and related regulations. As permitted by the CCPA, any Right to Know or Right to Delete request you submit to us is subject to an identity and residency verification process (“Verifiable Consumer Request”). To protect consumer privacy, we will not provide or delete PI unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI. Please follow the instructions at our California Privacy Rights Request page here and respond to any follow up inquires we may make.

Some PI we maintain about Consumers is not sufficiently associated with enough PI about the Consumer for us to be able to verify that it is a particular Consumer’s PI when a Consumer request that requires verification pursuant to the CCPA’s verification standards is made (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA we do not include that PI in response to those requests. If we cannot comply with a request, we will explain the reasons in our response. You are not required to create an account with us to make a Verifiable Consumer Request, but if you have an account we may require you to use it to be verified. We will use PI provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave it to us for another purpose.

We will make commercially reasonable efforts to identify Consumer PI that we collect, process, store, disclose and otherwise use and to respond to your California Consumer privacy rights requests. In some cases, particularly with voluminous and/or typically irrelevant data, we may suggest that you receive the most recent or a summary of your PI and give you the opportunity to elect whether you want the rest or not. We reserve the right to direct you to where you may access and copy responsive PI yourself. We will typically not charge a fee to fully respond to your requests; provided, however, that we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded or overly burdensome. If we determine that the request warrants a fee, or that we may refuse it, we will give you notice explaining why we made that decision. You will be provided a cost estimate and the opportunity to accept such fees before we will charge you for responding to your request.

Consistent with the CCPA and our interest in the security of your PI, we will not deliver to you your financial account number, an account password, or security questions or answers in response to a CCPA request; however, you may be able to access some of this information yourself through your account if you have an active account with us.

Your California Consumer privacy rights are as follows:

Return to navigation

You have the right to send us a request, no more than twice in a twelve-month period, for the following information about your PI for the period that is twelve months prior to the request date:

• The categories of PI we have collected about you.
• The categories of sources from which we collected your PI.
• The business or commercial purposes for our collecting or selling your PI.
• The categories of third parties to whom we have shared your PI.
• A list of the categories of PI disclosed for a business purpose in the prior 12 months and, for each, the categories of recipients, or that no disclosure occurred.
• • A list of the categories of PI sold about you in the prior 12 months and, for each, the categories of recipients, or that no sale occurred.

To make a request, follow the instructions at our California Privacy Rights Request page here or call us at 1-800-796-7546 and indicate that you are making a right to know categories request. In order for us to look into your request, we first need to verify your identity, meaning that we need to make sure that you are the consumer we may have collected personal information about or a person who has been duly authorized to make the request on behalf of the consumer. We are required to verify a consumer’s request to know categories of PI to a reasonable degree of certainty, which may include matching at least two data points provided by the consumer with data points maintained by us, which we have determined to be reliable for the purpose of verifying the consumer. If you fail to do so we will be unable to verify you sufficiently to honor your request. If we cannot verify you to a reasonable degree of certainty, we will refer you back to this Notice. This is required by the CCPA and designed to protect your privacy.

Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.

In accordance with California Business and Professions Code § 17538 et al., our online return and refund policy is available here. The legal name under which we conduct business online is Image International Manufacturing, LLC and our business address is 7130 Seacrest Boulevard, Lantana, FL 33462. Within five (5) days of our receipt of your request, California residents may receive verification of this information by email by contacting us here.

Residents of California are also entitled to the following specific Consumer rights information: you may contact the Complaint Assistance Unit of the Division of Consumer Services of the Department of Consumer Affairs by mail at: 1625 North Market Blvd., Suite N 112, Sacramento, California, 95834, or by telephone at (916) 445-1254. Hearing-impaired users can reach the Complaint Assistance Unit at TDD (800) 326-2297 or TDD (916) 322-1700. Their website is located at: http://www.dca.ca.gov.

Return to navigation

For more information on your California privacy rights contact us at 1-800-796-7546 or email us here.

Return to navigation