Privacy Policy for Image International Manufacturing, LLC

This Privacy Policy applies to personal information collected online by Image International Manufacturing, LLC, its affiliates and subsidiaries (collectively referred to as “Image Skincare”) in connection with its U.S.-based websites, microsites, mobile sites or mobile apps that expressly adopt, display or link to this Privacy Policy (collectively referred to as our “Sites”). It also applies to personal information Image Skincare collects in connection with the Image Skincare pages on social media sites, such as Facebook®, Instagram ®, YouTube®, Twitter®, Pinterest®, LinkedIn®, or others (collectively referred to as our “Social Media Pages”). California and Nevada residents have additional privacy rights explained here.

We may collect information about you from a variety of sources, including when:

• you provide us information
• we observe or collect information through technology
• we receive information about you from third parties
• we collect information on our Social Media Pages.

We may ask you to provide information about yourself directly to our Sites, such as the following:

• name
• address
• email address
• telephone number
• birthday
• social security number
• username and password
• payment card information
• financial information
• user generated content
• demographic information
• customer satisfaction surveys
• personal preferences
• employment history

We may allow you to use your personal social media account associated with third party social media sites (“Personal Social Media Account”), to provide information to us when you participate in certain features on our Sites.

This information may include any information you have shared on your Personal Social Media Accounts, such as the following:

• name
• profile picture
• gender
• networks
• user ID
• list of friends
• language
• birthday
• education
• work history
• address
• interests
• likes
• friends

It is also possible that we will be able to continue collecting this information from your Personal Social Media Accounts should the information be revised by you later. You may choose not to provide us with certain requested information, but then you might not be able to take advantage of some of the features on our Sites.

a. Navigational Information. Navigational information, such as the following, is collected by us and our third party service providers when you use our Sites:

• browser type and version
• operating system
• the Internet service provider used to access our Sites
• IP Address and other unique identifiers
• use of links to arrive at our Sites
• web pages requested and viewed
• time spent on our Sites
• for our mobile websites and apps, technical information about the device used, such as screen size, cookie support by the device and how images may appear 

b. Location Information. Our Sites and emails include features that may require collecting different types of location information that we then use for the specific feature you have selected, such as:

• Retail locator. Our Sites may allow you to search for an authorized reseller of Image Skincare products near you. If you access one of our Sites through a mobile device and you have enabled location-based services, specific location information may be collected for these features. If you access these features through a desktop device, you may be able to choose to have your browser provide us your location information to respond to your request. The specificity of the desktop device location information can vary depending on the browser you are using and how you are connected to the internet.
• Email. Our emails may use your IP Address to determine the postal code where you are located when you open the email. This allows us to tailor content to you, such as a map of nearby Image Skincare locations. The specificity of the location can vary depending on the device used to open our emails.
• Mobile offers. If you consent to receive them, we may send offers to your mobile devices when you are in certain locations.

c. Cookies and other similar technology. We and our third-party service providers use “cookies.” Cookies assign a unique identification to your device and are typically stored on your device by your web browser. We may also use pixel tags (also known as web beacons, web bugs, and clear GIFs) on the Sites and in emails. A pixel tag is a nearly invisible pixel-sized graphic image on a webpage or in an email message.

Image Skincare uses cookies to collect information around abandoned shopping carts. A cart is considered abandoned after one hour of inactivity/lack of purchase. Once the timer has expired an SMS message will be sent as a reminder.

The information we and our third-party service providers collect through cookies, pixel tags and similar technology includes the following:

• your interactions with our Sites and with our advertisements
• the time of your visit to our Sites
• confirmation when you open email from us, including the time you open the email and whether you click on any links in the email
• sites you visit after visiting our Sites

Some information about your use of our Sites and certain third-party services may be collected using tracking technologies across time and services and used by us and third parties for purposes such as to associate different devices you use and deliver relevant ads and/or other content to you on the Sites and certain third-party services.

You can block cookies using your browser controls but if you do so certain features and functionality of our Sites may not work. For easy access, here are links on how to manage cookies from some of the more popular browsers:

• Google Chrome
• Firefox
• Internet Explorer
• Edge
• Safari
  

For additional information on the use of cookies for advertising, see “3. How is technology used to serve our advertisements on other Sites that you visit and what choices do you have?”.

We may combine information about you from other sources with the information we have collected about you on our Sites or Social Media Pages. For example, in connection with searching and applying for jobs with us, we may use a third party to collect and process the applicant profiles and preferences, monitor website activity, maintain the database based in the U.S and provide plug-ins (such as LinkedIn) at your request.

We may also engage third-party service providers for the purpose of identifying users and delivering to them marketing on our behalf (i.e. email or direct mail). These third-party service providers may collect information directly from your device, such as your IP address, device ID, and information about your browser or operating system; may combine personal and non-personal information about you with information from other sources; and may place or recognize a unique cookie on your browser. This activity enables them to identify you to facilitate the delivery of marketing on our behalf, including Interest-based Advertising. To opt out of recognition services, please go to https://idx.listrakbi.com/opt-out.html. To learn more about the choices you have regarding Interest-based Advertising see “3. How is technology used to serve our advertisements on other Sites that you visit and what choices do you have?”.

Personal information may be collected directly by us through our Social Media Pages. The type of information we would collect is similar to what is described above under “Information You Provide.” Personal information may also be collected by the social media site hosting our Social Media Pages. Our Privacy Policy does not cover the privacy and security practices of the social media sites on which Image Skincare has its Social Media Pages.

We may use your personal information and other information about your in connection with the Sites and our business as permitted by applicable law. The information we learn from you helps us personalize your experience with us and our communications to you and helps us continually improve your experience on our Sites.

We use the information you provide, information collected through your Personal Social Media Accounts, and information collected on our Social Media Pages, including your personal information, for things like:

• opening an online account
• improving and developing our products
• servicing our customers
• advertising and marketing, including emails, texts and postal mail
• personalizing your experience when visiting our Sites
• responding to your inquiries
• market research and surveys
• conducting events, promotions, contests and sweepstakes
• analytics
• processing job applications

We use navigational information gathered through technology for determining things like:

• which parts of our Sites are most visited or used
• what features/products are browsed
• how to improve and better transact business
• the effectiveness of our Sites
• lead generation
• difficulties visitors may experience in accessing our Sites
• monitoring the number of visitors to our Sites
• average time spent on our Sites
• any programming errors or failures on any of our Sites

We use information collected through cookies and similar technology to determine many of the same things listed for navigational information above. In addition, cookies and similar technology are used for things like:

• personalizing your experience on our Sites
• serving tailored ads on other sites, as described below
• tailoring email marketing to you based on your preferences on, or use of, our Sites
• determining return visitors
• measuring the effectiveness of our advertising

We use third-party analytics providers, such as Google Analytics, to measure traffic and usage trends, and to help us better understand your use of and interaction with our Sites and Social Media Pages. You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on. Like the navigational information described above, the social media sites where we have our Social Media Pages may provide aggregate information and analysis to us about visitors to our Social Media Pages. This allows us to better understand and analyze our user growth, general demographic information about the users of, and interaction with content on, our Social Media Pages.

The Sites and/or Social Media Pages may permit you to post or submit content (“User Content”) including, without limitation, written content, user profiles, audio or visual recordings, computer graphics, pictures, data, or other content, including personal information. If you choose to submit User Content to any public area of the Sites, or Social Media Pages, your User Content will be considered “public” and will be accessible by anyone, including us. Notwithstanding anything to the contrary, unless otherwise explicitly agreed by us, personal information included in User Content is not subject to our usage or sharing limitations, or other obligations under this Privacy Policy or otherwise, and may be used and shared by us and third parties to the fullest extent not prohibited by applicable law. We encourage you to exercise caution when making decisions about what you disclose in such public areas. For more information on how User Content is treated under our Sites Terms of Use click here. California minors should see our California Consumer Privacy Notice regarding potential removal of certain UGC they have posted on the Sites.

    Additionally, the Sites may offer you the option to send a communication to a friend or other contact. If so, we rely on you to only send to people that have given you permission to do so. The recipient’s personal information you provide (e.g., name, e-mail address) will be used to facilitate the communication, but not used by us for any other marketing purpose unless we obtain consent from that person. Your contact information and message may be included in the communication.

We may contract with third party advertising companies to tailor online advertising to be directed to you on other websites and online services (“Interest-based Advertising”). These third-party advertising companies place, use, or rely on tracking technology, such as cookies and pixel tags, to obtain information about your interactions with our Sites as well as with other websites. This information helps us select advertising to serve to you and where to serve it based on your experience on our Sites and other sites that you visit. You may opt to not accept cookies. You should be aware that our systems do not recognize “Do Not Track” signals from all browsers since there is not currently an accepted standard for how to respond to such signals.

You may choose whether to receive some Interest-based Advertising by submitting opt-outs. Some of the advertisers and service providers that perform advertising-related services for us and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, including use of Cross-device Data for serving ads, visit http://www.aboutads.info/choices/, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program specifically for mobile apps (including use of precise location for third party ads). Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective. We support the ad industry’s 2009 Self-regulatory Principles for Online Behavioral Advertising and expect that ad networks we directly engage to serve you Interest-based Advertising will do so as well, though we cannot guaranty their compliance. We are not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.

We may share your personal information as permitted by applicable law to the extent not inconsistent with this Privacy Policy or any representations made at the time of collection, including without limitation with the following third parties for the purposes outlined below:

• Authorized Image Skincare professional accounts or other resellers of Image Skincare products
• Our contractors, vendors, affiliates and third-party service providers in order to perform tasks on our behalf such as the following:

a. facilitating your purchase

b. assisting in servicing our products

c. providing and improving our communications with you

d. responding to requests to our investor relations

e. cloud based and hosting services

• When it is necessary for completing or servicing any transactions that you have authorized and, in some instances, to verify the existence or condition of your account with a financial institution, credit bureau or other third party
• to verify an application for employment
• as required to cooperate with a subpoena, search warrant or other legally valid inquiry, court order or other legal process, or as required or permitted by law
• to protect the rights, property or safety of our Sites, our users or others, including where necessary for the establishment, exercise or defense of legal claims
• as necessary and appropriate to protect Image Skincare from harm due to fraud or other illegal activities.

If Image Skincare were ever merged with or acquired by another company, or if we acquire another business entity or are involved in a corporate reorganization or other change of control, or if we sell substantially all the assets of a division, affiliate or subsidiary, some or all of the personal information collected about you could be shared with the acquiring or acquired company (“Corporate Transaction(s)”). We may also share aggregate and/or de-identified data with third parties, such as in connection with reporting information about our sales, customers, traffic patterns, and other related Site information with, but none of this data is connected to an individual’s personal information.

    The Sites may include hyperlinks to, or include on or in connection with the Sites (e.g., apps and plug-ins), websites, locations, platforms, applications or services operated by third parties (“Third-Party Service(s)”). These Third-Party Services may use their own cookies, web beacons, and other tracking technology to independently collect information about you and may solicit personal information from you.

    Certain functionalities on the Sites permit interactions that you initiate between the Sites and certain Third-Party Services, such as third party social networks (“Social Features”). Examples of Social Features include: enabling you to send content such as contacts and photos between the Sites and a Third-Party Service; “liking” or “sharing” Image Skincare’s content; logging in to the Sites using your Third-Party Service account (e.g., using Facebook Connect to sign-in to the Sites); and to otherwise connect the Sites to a Third-Party Service (e.g., to pull or push information to or from the Sites). If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Sites (See Section 2) or by the Third-Party Service that you use. Similarly, if you post information on a third-party service that references the Sites (e.g., by using a hashtag associated with Image Skincare in a tweet or status update), your post may be used on or in connection with the Sites or otherwise by us. Also, both Image Skincare and the third party may have access to certain information about you and your use of the Sites and any Third-Party Service.

    Image Skincare may engage and work with service providers and other third parties to serve advertisements on the Sites and/or on third-party services, including Interest-based Adverting. See Section 3 above for choice you may have regarding these activities.

    We may use Google Analytics, Adobe Analytics or other service providers for analytics services. These analytics services may use cookies and other tracking technologies to help us analyze Site users and how they use the Sites. Information generated by these services (e.g., your IP address and other usage information) may be transmitted to and stored by these service providers on servers in the U.S. (or elsewhere) and these service providers may use this information for purposes such as evaluating your use of the Sites, compiling statistic reports on the Sites’ activity, and providing other services relating to Site activity and other Internet usage.

    Except to the extent we combine information we receive from service providers, Third-Party Services, or other third parties with personal information we collect via our Sites and Social Media Pages, in which case we will treat the combined information as personal information governed by this Privacy Policy, data obtained by us from a third party is not subject to the limitations regarding personal information we collect via our Sites and Social Media Pages under this Privacy Policy, however such data remains subject to any restrictions imposed on us by the third party, if any. Otherwise, the information collected, stored, and shared by third parties remains subject to their privacy policies and practices, including whether they continue to share information with us, the types of information shared, and your choices on what is visible to others on Third-Party Services.

    Image Skincare is not responsible for, and makes no representations regarding, the policies or business practices of any third parties, including, without limitation, analytics service providers and Third-Party Services associated with our Sites or Social Media Pages, and encourages you to familiarize yourself with and consult their privacy policies and terms of use. See Section 3 (“How is technology used to serve our advertisements on other websites that you visit and what choices do you have?”) for more on certain choices offered by some third parties regarding their data collection and use, including regarding Interest-based Advertising and analytics.

We give you choices about the information we collect and how we communicate with you.

1. Email: You may opt-out of our marketing emails by following the instructions listed in the email that you received. However, even if you opt-out you may still receive non-marketing emails, such as customer service communications.

2. Location Information:

a. Mobile Device Location Information. Your mobile device settings may allow you to disable location-based services, which will prevent our Sites from accessing your precise mobile device location information. We recommend you review the help or user manual provided with your device for instructions.

b. Desktop Device Location Information. Your desktop web browser may allow you to remove permission you granted through your desktop device for our Sites to access location information and/or completely block requests for location information. We recommend you review the help or user manual provided with your browser for instructions.

c. Email Location Information. Your email program may allow you to prevent the pixel tags or images in the emails you receive from us from downloading, which will also prevent our service provider from accessing your location information. You can also unsubscribe from receiving our emails, as described in the "Email" section, above.

3. Postal Marketing: If you no longer want to receive marketing materials from us via regular postal mail, please call our Customer Service Department at 1-800-796-7546 or email us at PrivacyRequest@imageskincare.com and tell us that you want to be removed from the Image Skincare postal mailing list, including the postal address you wish to have removed.

4. Cookies: You may set your web browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Sites, you may not be able to take advantage of all the features on our Sites. For information on how to opt-out of the use of cookies for Interest-based Advertising, see Section 3 (“How is technology used to serve our advertisements on other websites that you visit and what choices do you have?”).

5. Text Messages: You may opt-out from receiving text messages from us by following the opt-out instructions in the text message or by contacting us as described below in Section 9 ("How Can I Contact Image Skincare?”).

Children’s Privacy: Our Sites are intended for adults, and not directed to children less than 13 years of age. We do not knowingly collect personal information as defined by the U.S. Children’s Online Privacy Protection Act (“COPPA”) from anyone under the age of 13 on our sites or marketing platforms in a manner that is not permitted by COPPA. If we become aware that anyone under the age of 13 has provided us with personal information in a manner not permitted by COPPA, we will delete the information from our records to the extent required by COPPA.

ADDITIONAL RIGHTS AND DISCLOSURES FOR CALIFORNIA RESIDENTS: California residents have certain additional rights as more fully detailed in our California Consumer Privacy Notice. In the event of a conflict between that notice and this policy, that notice will govern California resident’s privacy rights.

ADDITIONAL DISCLOSURE FOR NEVADA RESIDENTS: Although we do not “sell” “covered information” of Nevada “consumers” as those terms are defined by Chapter 603A of the Nevada Revised Statutes, you may contact us here and register an e-mail contact address for us to provide you notice in the event we should do so in the future, at which point you will have an opportunity to be verified and exercise your opt-out rights under that law. Contact us in the same manner to update your contact email for notices. Changing your email elsewhere (e.g., informational requests, account information, etc.) will not update your Nevada notice contact information. It is your responsibility to keep your notice contact information current.

We use firewalls and have implemented other reasonable technical, administrative and physical measures designed to protect the personal information in our custody or control from unauthorized access, use, modification and disclosure. Moreover, we regularly monitor our systems for possible vulnerabilities and attacks. While we implement these security measures on our Sites, you should be aware that 100% security is not always possible.

    We may make changes to this Privacy Policy prospectively at any time, and your use of our Sites indicates your consent to the privacy policy posted at the time of use, so please review it periodically. We will update the effective date of the Privacy Policy at the time a change is made. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

If you have questions or concerns with respect to our Privacy Policy, please contact us by:

• Phone: Customer Care: 1-800-796-7546
• Email: PrivacyRequest@imageskincare.com
• Postal mail: 7130 Seacrest Boulevard, Lantana, FL 33462, Attn: Privacy Policy

Be sure to include your question or request, name, email, phone number and address information.

Effective as of: 6-24-20