Our Privacy Policy has been updated and has an Effective Date of December 31, 2019.

This Privacy Policy governs the information Combe Incorporated, and our affiliated and subsidiary companies and brands, collects from you, online and offline, including through our websites, applications, email communications, social media pages, and other interactive features and online services (“Services”), unless a separate privacy policy is specifically referenced or posted.

Please take a moment to review this Privacy Policy.  Please also review the Terms of Use which governs your use of the Services. Please note that certain features or services discussed in this Privacy Policy may not be offered through the Services at any particular time. By using the Services, you agree to the collection, use, and disclosure of information as described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy and the applicable Terms of Use, do not access or use the Services or provide information to us.

INFORMATION WE MAY COLLECT AND HOW WE COLLECT IT  

We collect information from you directly, automatically when you visit the Services, and sometimes from third parties.  Some of this information may be considered “personal information” under various applicable laws.  We consider information that identifies you as a specific, identified individual to be personal information (such as your name, phone number, e-mail address), and we treat additional information, including IP addresses and cookie identifiers, as “personal information” where required by applicable law. And, if we combine information we consider to be non-personal with personal information, we will treat that combined information as personal information under this Privacy Policy and as required by law. Note that we may de-identify personal information so that it is non-personal, such as by aggregating it or converting it to a code, sometimes using function commonly known as a “hash.”  We will treat de-identified information as non-personal to the fullest extent allowed by applicable law.

Information You Provide To Us Directly

We may ask you to provide information when you interact with us, such as when you sign-up for our newsletter or make a purchase, including contact information (such as your name, postal address, telephone number, email address) and other information such as demographic information (for example, your gender, birth day and month, or similar information). Certain features may also collect information about your preferences and interests. We may also collect information about your account with Combe (such as your user account ID and password).

Certain Services may also allow you to purchase products directly from us, in which case we may ask you to provide payment information (such as credit and debit card number and other associated card information).

We may collect information from you offline, such as when you contact customer service.

If you submit any personal information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Information Collected Automatically

We and third party analytics and advertising companies and other business partners may use a variety of technologies that automatically or passively collect certain information whenever you access our Services or otherwise interact with us or our content (“Usage Information”). Usage Information may include the hardware model, browser, and operating system you are using, your MAC address, computer type, screen resolution, device, language settings, the URL or advertisement that referred you to our Services, all of the areas within our Services that you visit, your time zone, location information, and mobile network (if applicable), among other information. In addition, we automatically collect your IP address or other unique identifier (“Device Identifier”) for any computer, mobile phone, or other device you use to access our Services.  We may be able to infer your approximate location through information we collect, such as IP address. In some cases, we may directly collect location information through your device. You may be able to turn off the collection of location information through the settings on your device. However, please note that we may still be able to collect or infer your approximate location through other information we collect, such as IP address. In addition, some mobile service providers may also provide us or our third party business partners with information regarding the physical location of the device used to access our Services

Usage Information is generally non-identifying, but if Combe associates it with you as a specific and identifiable person, Combe treats it as personal information.

The methods that may be used to collect Usage Information include the following:

Cookies and Local Storage: Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences and other traffic data. We and our third party business partners use this information for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience while using the Services, and to recognize your computer in order to assist your use of the Services. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services. We may also use cookies or other technologies to track responses to our online advertisements.

If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html.

If you choose to disable cookies on your device, you may experience some inconvenience in your use of the Services or some features may not function properly. For example, we may not be able to recognize your computer, and you may need to log-in every time you visit. You also may not receive advertising or other offers from us that are relevant to your interests. 

Pixel Tags and other similar technologies: Pixel tags are small graphic images or other web programming code (also known as “web beacons”, “1x1 GIFs” or “clear GIFs”) may be included in our web pages and e-mail messages. Pixel tags or similar technologies may be used for a number of purposes, including to count visitors to the Services, monitor how users navigate the Services, compile statistics about usage of the Services and response rates to our e-mail messages, and measure the success of our marketing campaigns.

In addition, we may use these and a variety of other technologies that collect Usage Information and similar information for security and fraud detection purposes. 

User Content Submissions

The Services may provide you the opportunity to participate and post content publicly, such as product reviews or in connection with a sweepstakes. You may choose, through such features or otherwise, to submit or post comments, photographs, videos, or other content (collectively, “User Content”). Any user content you submit is subject to our Terms of Use, and may be used by Combe for its business and marketing purposes and may be published online or offline.

Note that anything you choose to submit or publicly post to the Services may be public—others will have access to your User Content and may share it with third parties. If you choose to voluntarily disclose personal information, that information may be considered public information and the protections of this Privacy Policy will not apply.

Information Third Parties Provide About You

Combe may receive information about you from third parties, including business partners and data providers. For example, if you are on another website and you agree to receive information from Combe, that site will forward your information to us so that we may contact you. And, we may supplement the information we collect with outside records from third parties, such as public databases, publicly available web pages, and third parties who enhance the information we have about you. We use this information to better provide you with information and products, to tailor our content and the offers we show you, and for other business purposes.

Social Media Interactions

The Services may link to our pages on an interactive third party website or and may facilitate interactions with third party social media, such giving you the opportunity to “like” or “share” content.  You may also be able to log-in through or otherwise connect your account on a social media service (e.g., Facebook or Twitter). When you interact with social media through our Services, we will receive information about you from that third-party service and they may set their own cookies and collect information about your use of the Services, including your IP address or other Device Identifier and which page you are visiting on the Services. Your interactions with social media and postings on social media are subject to the policies and terms of the third party social media company.

HOW WE USE INFORMATION

Combe (as well as service providers who act on our behalf and other business partners) may use information we collect for of the following purposes:

Providing the functionality of the Services and fulfilling your requests.

  • To provide the Services’ functionality to you.
  • To respond to your inquiries and fulfill your requests, such as to send you newsletters.
  • To complete and fulfill your purchase.
  • To send administrative information to you, such as changes to our terms, conditions, and policies.
  • To provide you with related customer service.
  • We engage in these activities at your request, to manage our contractual relationship with you, to conduct our business and/or to comply with a legal obligation.
  • If you do not provide us with certain information that we request, we may not be able to provide you with the requested Services.

Providing you with our newsletter and/or other marketing materials.

  • To send you marketing related emails or other communications, with information about our company and our products, services, and offers.
  • We will engage in this activity only with your consent.

Analytics and analysis for business reporting and providing targeted advertising and personalized services.

  • To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our Services are used, so we can improve our Services.
  • To better understand you, so that we can personalize our interactions with you and provide you with information, advertisements and/or offers tailored to your interests.
  • To better understand your preferences, so that we can deliver content via our Services that we believe will be relevant and interesting to you.
  • We provide personalized services in accordance with applicable law.  In the EU, we do so either with your consent or because we have a legitimate interest.

Allowing you to participate in polls, sweepstakes, contests, or promotions or activities.

  • We may offer you the opportunity to participate in polls, sweepstakes, contests, and similar promotions.
  • Some of these activities have additional rules containing information about how we will use and disclose your personal information.
  • We use your personal information in this context to manage our contractual relationship with you, to conduct our business and/or to comply with a legal obligation.

Accomplishing our business purposes.

  • For data analysis, for example, to improve the efficiency of our Services;
  • For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements;
  • For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
  • For developing new products and services;
  • For enhancing, improving, or modifying our current products and services;
  • For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
  • For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
  • For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.
  • We will engage in these activities to manage our contractual relationship with you, to conduct our business, to comply with a legal obligation, and/or because we have a legitimate interest.

We may also use information for any other purposes consistent with this Privacy Policy, as disclosed at the time you provide your information, or otherwise with your consent. 

WHEN WE MAY DISCLOSE INFORMATION

Combe shares non-personal information, which may include information that has been de-identified, with third parties. We do not share your personal information with third parties for those third parties’ own direct marketing purposes unless you consent (opt in or opt out) to such sharing. California residents, please see below for additional information in the “Notice to California Residents”.

We may share information we have collected about you as allowed by law and as disclosed at the time you provide your information, with your consent, and as described in this Privacy Policy, including in the following circumstances:

Combe Family of Companies. 

  • Combe includes several brands and companies, some of which operate as subsidiaries, affiliates or joint ventures. When Combe collects information through one of our Services, it will be accessible across the Combe family of brands and companies. The information will be used for business, operational, and marketing purposes.
  • The Combe Family of Companies may include, but is not limited to, the following entities: Combe Laboratories, Inc. (United States of America); Combe de Mexico, S. de R.L. de C.V. (Mexico); ClearVia Labs, LLC (United States of America); Combe Marketing Private Limited (India); Universal Revendedora de Produtos de Toucador Ltda. (Brazil); Ideal Commercial Ltda. (Brazil); Combe Asia-Pacific Pty Ltd (Australia); Combe de Brasil Proaganda e Mercadologia Ltda. (Brazil); Ward Laboratories (Thailand) Limited (Thailand); Combe International Limited (United Kingdom); Combe Europa S.L. (Spain); Advertising Operations, Assessoria, Planejamento e Propaganda Ltda. (Brazil); SP Pharma Distribuidora, Importadora e Exportadora Ltda, EPP (Brazil); Combe Italia S.r.l. (Italy); and Combe Products, Inc. (Puerto Rico).
  • Combe Incorporated is responsible for managing jointly-used personal information.
  • California residents, please see below for additional information in “Notice to California Residents”.

Third Parties Providing Services on our Behalf. 

  • These may include providers of services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.

Sweepstakes, Contests, Promotions. 

  • We may offer sweepstakes, contests, or other promotions (any, a “Promotion”), that may require registration.
  • By participating in a Promotion, you are agreeing to the provisions, conditions, or official rules that govern the Promotion, which may require specific requirements of you (including, without limitation, and except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness, or other indicia of persona in advertising or marketing materials).
  • If you choose to enter a Promotion, personal information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, as required by law or permitted by the Promotion’s terms or official rules (such as on a winners list).

When You Request That We Share Your Information. 

  • When using the Services, we may share information when you direct us to do so. For example, you may be presented an opportunity to receive marketing offers from a third party or you may engage with a social media service or other third party application or feature, through which information about you is shared.
  • We are not responsible for the privacy practices of third parties.

Administrative and Legal Reasons.  We may also use and disclose your personal information as we believe to be necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

  • To comply with applicable law. This can include laws outside your country of residence.
  • To respond to requests from public and government authorities. These can include authorities outside your country of residence.
  • To cooperate with law enforcement. For example, when we respond to law enforcement requests and orders.
  • For other legal reasons.
    • To enforce our Terms of Use; and
    • To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.

Business Transfers.

  • We have a legitimate interest in disclosing or transferring your personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings and in connection with due diligence inquiries in connection with a sale or similar corporate change).
  • Such third parties may include, for example, an acquiring entity and its advisors.

THIRD PARTY ADVERTISING AND ANALYTICS COMPANIES

Combe may work with network advertisers, ad agencies, analytics providers, and other advertising partners to serve Combe ads online, to serve third party ads on the Services, and to provide us with information regarding the use of the Services and the effectiveness of our advertisements. These third parties may set and access their own tracking technologies on your device (including cookies and pixel tags), and they may otherwise collect or have access to Usage Information and other information about you. Some of these parties may collect personal information over time when you visit the Services or other online websites and services. We may share information, typically information that has been de-identified, Usage Information, and location information with third party advertising companies, analytics providers and other third parties for the purpose of serving you more relevant ads on and off the Services.

We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/‌partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

We may use a variety of companies to serve our advertisements. Some of these companies are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising and you may want to visit the following webpages, which provide “opt-out” mechanisms for participating companies: http://networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/choices/. You may opt-out from interest based advertising on your mobile device through your mobile device settings. Please note opting out through these mechanisms does not opt you out of being served advertising and you will continue to receive generic ads while online. If you are a California resident, please see our “Notice to California Residents” regarding additional rights you have, including how to exercise your “Do Not Sell” right.

HOW WE RESPOND TO “DO NOT TRACK” SIGNALS

Some browsers have “Do Not Track” features that allow you to tell a website not to track you. There is no standard definition or application of “Do Not Track” at this time. Combe does not respond to browser do-not-track signals at this time except as specifically required by law. To find out more about “Do Not Track”, please visit www.allaboutdnt.com.

THIRD PARTY SERVICES

The Services may contain content that is served by someone else or links to third-party content or web sites that Combe does not control. This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties.

SECURITY

We use commercially reasonable organizational, technical and administrative measures designed to protect the information we collect. Unfortunately, no data transmission over the Internet, wireless transmission, or storage system can be guaranteed to be 100% secure. Combe cannot ensure or warrant the security of any information you provide to us or that we collect about you. You use the Services and provide us information at your own risk.

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section below.

CHOICES AND ACCESS

We give you choices regarding our use and disclosure of your personal information for marketing purposes. You may opt-out from:

  • Receiving marketing communications from us, including browser push notifications: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by clicking on the “Unsubscribe” link provided in each such email. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important communications relating to your account or use of the Services, such as administrative messages and services announcements. These transactional account messages may be unaffected if you choose to opt out from marketing e-mails. You may also be able to turn off browser push notifications through the settings on your browser.
  • Our sharing of your personal information with affiliates for their direct marketing purposes: If you prefer that we not share your personal information on a going-forward basis with our affiliates for their direct marketing purposes, you may opt-out of this sharing by e-mailing [email protected] We will try to comply with your request(s) as soon as reasonably practicable.

HOW YOU CAN ACCESS, CHANGE, OR SUPPRESS YOUR PERSONAL INFORMATION

If you would like to request to review, correct, update, suppress, restrict or delete personal information that you have previously provided to us, or if you would like to receive an electronic copy of your personal information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below. We will respond to your request consistent with applicable law.

In your request, please make clear what personal information you would like to have changed, whether you would like to have your personal information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your personal information. For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for legal and recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the personal information provided until after the completion of such purchase or promotion).

If you are a California resident, please see our “Notice to California Residents” for additional information about how to exercise your privacy rights. If you are a Nevada resident, please see our “Notice to Nevada Residents” for more information on additional rights you may have.

RETENTION PERIOD

We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

The criteria used to determine our retention periods include:

  • The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

GENERAL AUDIENCE SITES

The Services are intended for a general audience and We do not knowingly collect personal information from individuals younger than the age of 16. If we learn that we have inadvertently collected personal information from a user who is younger than age 16, we will delete the information from our active databases.

JURISDICTION AND CROSS-BORDER TRANSFER

Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers, and, by using the Services, you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.

If you are located in the EEA: Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission] to protect your personal information. You may obtain a copy of these measures by contacting us at [email protected].

SENSITIVE INFORMATION

We ask that you not send us, and you not disclose, any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.

UPDATES TO THIS PRIVACY POLICY

To the extent allowed by applicable law, we may change this Privacy Policy. The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services. We may also provide notice to you in other ways, such as through the contact information you have provided. Your continued use of the Services following these changes means that you accept the revised Privacy Policy to the fullest extent allowed by applicable law. However, we will provide notice and obtain your consent (opt-in or opt-out) if required. Note, that you may need to consent to our new policies in order to continue to use the Services.

CONTACTING US

Combe Incorporated, located at 1101 Westchester Avenue, White Plains, New York 10604, is the company responsible for collection, use and disclosure of your personal information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us at [email protected], or:
Combe Incorporated
Attn: Office of the General Counsel
1101 Westchester Avenue
White Plains, New York 10604

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.

NOTICE TO CALIFORNIA RESIDENTS

1. CALIFORNIA PRIVACY NOTICE

This California Privacy Notice is effective as of January 1, 2020.

This notice supplements Combe’s privacy policy and applies only to California residents. This California Privacy Notice sets forth the disclosures and rights for California consumers regarding their personal information, as required by the California Consumer Privacy Act (“CCPA”). Terms used in this California Privacy Notice have the same meanings given in the CCPA and the regulations of the Attorney General implementing the CCPA, unless otherwise defined.

This notice provides information about the categories of information that we collect from California residents generally, the sources of the information, the purposes for which we use the information, and the categories of third parties to whom we disclose the information for business purposes and to whom we sell Personal Information as defined by CCPA (and information on how to opt-out).

INFORMATION COMBE COLLECTS

Combe collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”Personal Information”).

The Personal Information we collect about you will depend upon how you use our Services or otherwise interact with us. Accordingly, we may not collect all of the below information about you. We may also collect and/or use additional types of information after providing notice to you before collection and obtaining your consent (to the extent such notice and consent is required by the CCPA). 

Category of Personal Information Collected

Categories of Sources from which the Information was Collected

 

Business or Commercial Purpose(s) for which Information is Collected

Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose

 

Categories of Third Parties to Whom this Type of Personal Information is Sold

Identifiers

This category includes information such as name, contact information, and online or device identifiers.

We may collect this type of information from:

· Consumer,

· Cookies and Tracking Technologies,

· Third Party Service Providers,

· Third party social media companies,

· Third party business partners,

· Third party data resellers.

We may use this type of information for:

· Providing the functionality of the Services and fulfilling your requests,

· Providing you with our newsletter and/or other marketing materials,

· Analytics for business reporting and providing personalized services,

· Allowing you to participate in polls, sweepstakes, contests, or promotions or activities,

· Accomplishing our business purposes as described in detail in our privacy policy.

We may disclose this type of information to:

· Combe Family of Companies,

· Service Providers,

· Third parties who deliver our communications,

· Third parties we partner with for contests, sweepstakes, or promotions,

· Third party advertising and analytics companies,

· Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition,

· Third parties or affiliated companies when you agree to or request that we share your information with them,

· Other third parties (including government agencies) as required by law (such as pursuant to subpoenas or court orders).

Third party advertising business partners may have access to this data, and this may be considered a sale under CCPA under certain circumstances.

 

Any categories of personal information described in subdivision (e) of Section 1798.80

 

This category includes name, address, and phone number, information about your employment or education, and other categories of information classified as “personal” under this California law.

We may collect this type of information from:

· Consumer,

· Cookies and Tracking Technologies,

· Third Party Service Providers,

· Third party social media companies,

· Third party business partners,

· Third party data resellers.

We may use this type of information for:

· Providing the functionality of the Services and fulfilling your requests,

· Providing you with our newsletter and/or other marketing materials,

· Analytics for business reporting and providing personalized services,

· Allowing you to participate in polls, sweepstakes, contests, or promotions or activities

· Accomplishing our business purposes as described in detail in our privacy policy.

We may disclose this type of information to:

· Combe Family of Companies,

· Service Providers,

· Third parties who deliver our communications,

· Third parties we partner with for contests, sweepstakes, or promotions,

· Third party advertising and analytics companies,

· Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition,

· Third parties or affiliated companies when you agree to or request that we share your information with them,

· Other third parties (including government agencies) as required by law (such as pursuant to subpoenas or court orders).

Third party advertising business partners may have access to this data, and this may be considered a sale under CCPA under certain circumstances.

Commercial information

 

This category includes, for example, payment information you provide for goods, services, customer service records, and information about the products you have purchased.

We may collect this type of information from:

· Consumer,

· Third Party Service Providers,

· Third party business partners.

We may use this type of information for:

· Providing the functionality of the Services and fulfilling your requests,

· Analytics for business reporting and providing personalized services,

· Allowing you to participate in polls, sweepstakes, contests, or promotions or activities,

· Accomplishing our business purposes as described in detail in our privacy policy.

We may disclose this type of information to:

· Combe Family of Companies,

· Service Providers, such as those who help us process transactions and deliver our communications,

· Third parties we partner with for contests, sweepstakes, or promotions,

· Third party advertising and analytics companies,

· Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition,

· Third parties or affiliated companies when you agree to or request that we share your information with them,

· Other third parties (including government agencies) as required by law (such as pursuant to subpoenas or court orders).

 

Internet or other electronic network activity information

 

This category includes information about the web browser and operating system you are using, the website or ad that referred you to our Services, areas of the Services that you visited, and terms entered into a search engine that led you to the Services.

We may collect this type of information from:

· Consumer,

· Cookies and Tracking Technologies,

· Third Party Service Providers,

· Third party social media companies,

· Third party business partners,

· Third party data resellers.

We may use this type of information for:

· Providing the functionality of the Services and fulfilling your requests,

· Analytics for business reporting and providing personalized services,

· Accomplishing our business purposes as described in detail in our privacy policy.

We may disclose this type of information to:

· Combe Family of Companies,

· Service Providers,

· Third party advertising and analytics companies,

· Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition,

· Third parties or affiliated companies when you agree to or request that we share your information with them,

· Other third parties (including government agencies) as required by law (such as pursuant to subpoenas or court orders).

Third party advertising business partners may have access to this data, and this may be considered a sale under CCPA under certain circumstances.

 

Inferences drawn from any of the information identified above to create a profile about a consumer

 

These inferences may relate to your perceived interests, preferences, characteristics, or behavior.

We may collect this type of information from:

· Consumer,

· Cookies and Tracking Technologies,

· Third Party Service Providers,

· Third party social media companies,

· Third party business partners,

· Third party data resellers.

We may use this type of information for:

· Providing the functionality of the Services and fulfilling your requests,

· Analytics for business reporting and providing personalized services,

· Accomplishing our business purposes as described in detail in our privacy policy.

We may disclose this type of information to:

· Combe Family of Companies,

· Service Providers,

· Third parties we partner with for contests, sweepstakes, or promotions,

· Third party advertising and analytics companies,

· Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition.

Third party advertising business partners may have access to this data, and this may be considered a sale under CCPA under certain circumstances.

 

EXERCISING YOUR CALIFORNIA ACCESS, DELETION, AND DO-NOT-SELL RIGHTS

You have the right to request that we disclose to you what Personal Information we collect, use, disclose, and sell, including the right to request that we provide to you the specific pieces of Personal Information we have collected about you in the prior 12 months (“Right to Know”) and you have the right to ask us to delete the Personal Information we collect about you (“Right to Delete”), subject to exceptions set forth in the CCPA.  California residents also have the right to opt-out from the sale of their Personal Information. These rights are subject to some limitations, such as when we are retaining data to comply with our own legal obligations. You will not be required to create an account with us in order to submit a request. More information on each of these rights is below.

If you would like to authorize an agent to act on your behalf in submitting a request to know, request to delete, or request to opt-out of the sale of your Personal Information, you may do so by following the instructions below for making a request and indicating that you would like to authorize an agent to act on your behalf. We will follow up to request additional information and documentation, including a signed Declaration of Authorized AgentPlease keep in mind that if we do not receive adequate proof that the agent is authorized to act on your behalf, we may deny the request.

Response Timing

When you request access to the Personal Information we have collected or deletion of your Personal Information, we will typically provide the requested information within 45 days, and we will notify you within that time period if we need additional time to process your request.

RIGHT TO KNOW

1.Making A Request

If you are a California resident and would like to request information about the Personal Information we have collected about you in the prior 12 months, please contact us at this email address [email protected] and provide your first and last name, state the nature of your request, indicate the Combe brand(s) with which you may have interacted,and include your phone number and email address (if you have used a different email address to interact with Combe), which we will use to verify your request as described below  or You may also call us toll-free at 1 888 733 6423.  

We will provide the requested information free of charge up to two (2) times in a 12-month period, but please note that where we receive unfounded, excessive, or repetitive requests, we may elect to decline the request. Note also that we will not be able to provide information we do not ordinarily retain in the course of our regular business practices.

2. Verifying Requests to Access

Please note that we will take steps to verify your identity in order to fulfill your request.

In order to verify your identity, we will request that you provide the following pieces of information when you contact us with your request: your first and last name, the Combe brand(s) with which you may have interacted, the phone number and email address that you have previously provided to Combe. In order to have us provide specific pieces of information, we will require a signed declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request. 

If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we will not be able to provide the requested information.

RIGHT TO DELETE

The CCPA also provides a right to request that we delete personal information we have collected about you and for us to direct service providers to do the same, with certain exceptions as set forth in the CCPA.  Note that you may also delete certain Personal Information you have provided to us through your online account. 

When processing a request to delete, we may erase some information and we may de-identify some information (when we de-identify information, we implement technical safeguards and business processes that prohibit re-identification, business processes to prevent inadvertent release of de-identified information, and will make no attempt to re-identify the information).

1. Making A Request

If you are a California resident and would like to request that we delete your information, please contact us at this email address [email protected] and provide your first and last name, state the nature of your request, indicate the Combe brand(s) with which you may have interacted, and include your phone number and email address (if you have used a different email address to interact with Combe).You may also call us toll-free at 1 888 733 6423.

2. Verifying Requests to Delete

To ensure that we do not delete your personal information in response to a fraudulent request, once you submit the request, we will follow up to confirm that you want your information to be deleted.

In order to verify your identity, we will request that you provide the following pieces of information when you contact us with your request: your first and last name, the Combe brand(s) with which you may have interacted, the phone number and email address that you have previously provided to Combe.  

RIGHT TO OPT-OUT OF THE SALE OF PERSONAL INFORMATION

The CCPA also provides a right to California residents to request to opt-out of the sale of Personal Information. As indicated above, we may allow third-party advertising companies to collect data from visitors to our Services, including to better serve you more relevant advertisements.  Combe does not sell your personal information for monetary compensation, but its online advertising practices (and certain analytics or similar activities), may potentially be considered “sales” under the CCPA under certain circumstances.

You can limit this type of tracking through industry opt-outs (http://networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/choices/) and by limiting ad tracking on your mobile device.

You may also be able to limit the access these third-party advertising companies have to information about you when you use our Site by installing a browser or browser extension that can enable you to block the functionality of some tracking technologies.

If you use different computers or browsers, you may need to indicate your opt-out choices across those computers and browsers.  

Users Younger than 16

Combe does not knowingly sell Personal Information of minors younger than 16 years of age without affirmative authorization.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

California consumers have the right to not receive discriminatory treatment for exercising CCPA rights.  We will not discriminate against you for exercising your CCPA rights.

Contact for More Information

You can contact us for more information by writing us at Combe Incorporated, Attn: Office of the General Counsel, 1101 Westchester Avenue, White Plains, New York 10604 or emailing [email protected].

NOTICE TO NEVADA RESIDENTS

Combe does not currently sell your covered information as those terms are defined under applicable Nevada law. However, you may still submit an opt-out request and we will honor that request as required by Nevada law if Combe were to ever engage in such a sale in the future. If you are a Nevada resident and would like to opt-out of future sales of your covered information, please submit your request to [email protected]. Your request must include your full name, street address, city, state, zip code, and an email address so that we can contact if needed regarding this request.   You may also be required to take reasonable steps as we determine from time to time in order to verify your identity and/or the authenticity of the request.  Combe will respond to your request within sixty (60) days either confirming that your request has been processed or indicating that we need an additional thirty (30) days to complete the request.

ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EEA

If you are located in the EEA, you may lodge a complaint with a data protection authority competent for your country or region or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.