Privacy Policy for Image Skincare UK Ltd.

This Privacy Policy applies to personal information collected online by Image Skincare UK Ltd., its affiliates and subsidiaries (collectively referred to as “Image Skincare”) in connection with its UK and EU-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, Twitter®, LinkedIn, YouTube, Pinterest, Google Plus ® or others (collectively referred to as our “Social Media Pages”).

This Privacy Policy answers the following questions:

1. What information does Image Skincare collect about you on our Sites and Social Media Pages?
2. How do we use the information we collect about you?
3. For how long do we keep the information we collect about you?
4. Does Image Skincare share your information with third parties?
5. What choices do you have over how Image Skincare uses your information?
6. How does Image Skincare secure your information on its Sites?
7. What rights do you have regarding the information Image Skincare collects about you?
8. Will this Privacy Policy change?
9. How can I contact Image Skincare?

1. What information does Image Skincare collect about you on our Sites and Social Media Pages?

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.

Information You Provide

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

• name
• address
• email address
• telephone number
• birthday
• username and password
• payment card information

• financial information
• user generated content
• customer satisfaction surveys
• personal preferences

We may allow you to use your personal social media account, on 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.

Information Observed or Collected Through Technology:

1. 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
   • 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
2. 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:
   • Salon Finder. 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 browser or 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.
3. Cookies and other similar technology. We use cookies to allow your web browser to communicate with our website, and to enable you to move around the website and use its features. We also use cookies to collect information about how you use our website. Cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personalized features. Sometimes our cookies are used to deliver advertisements that may be relevant to you. They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Some of the cookies we use may be deleted from your browser when you end your session, but others may persist indefinitely unless you delete them.

Information Obtained from Third parties

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 require that the information you provide on pages hosted by these third parties be maintained by them in confidence. Information you voluntarily supply will be stored in a database, which will be accessed by authorized personnel of Image Skincare to address your inquiry or consider you for employment purposes with any of our affiliates. We may also keep the information for future consideration.

Information Collected on Image Skincare’s Social Media Pages

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.

2. How do we use the information we collect about you?

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 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

When you provide this information and when we use it for advertising or marketing, we will rely on your consent as the basis for our processing activities. If at any time you wish to withdraw your consent to future processing of this information, you may do so by clicking here. When we use it for the other purposes described above we will do so:

• To enter or perform a contract with you or to allow us to provide you with goods or services.
• For the establishment, exercise of defense of legal claims or proceedings.
• To comply with legal and regulatory obligations.
• For our legitimate business purposes.

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 have a legitimate business interest in tracking navigation information for these purposes.

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
• determining return visitors
• measuring the effectiveness of our advertising.

When you provide this information, we will rely on your consent as the basis for our processing activities. If at any time you wish to withdraw your consent to future processing of this information, you may do so by clicking here.

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. For more information on how Google uses data when you use our Sites, click here.
Similar to 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.

3. For How Long Do We Keep the Information We Collect About You?

We will only keep information about your visit to our Website for as long as is necessary for the purposes we’ve mentioned. We may be required to retain your personal data for a number of years in order to satisfy legal or contractual obligations, or in order to establish, exercise or defend legal claims. When your personal data is no longer necessary for these purposes, the personal data will be deleted.

4. Does Image Skincare share your information with third parties?

We may provide your information to affiliates or third parties under the following circumstances:

• To our contractors, vendors, affiliates and third-party service providers to perform tasks on our behalf such as the following:
  1. facilitating your purchase
  2. assisting in servicing our products
  3. providing and improving our communications with you
  4. responding to requests to our investor relations
  5. 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.

We may also share aggregate data about our sales, customers, traffic patterns, and other related Site information with third parties, but none of this data is connected to an individual’s personal information.

5. What choices do you have over how Image Skincare uses your information?

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:
   1. 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.
   2. 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 your 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.
   3. 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 1-855-791-5800 or email us at info_uk@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.

6. How does Image Skincare secure your information on its Sites?

Our Sites utilize encryption technology. We also 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 enable you to navigate to third-party websites through links on our Sites. We do this for your convenience. If it is not one of our Sites, we don't endorse, may not have any affiliation with, do not control and aren't responsible for those third-party websites and/or their Internet and web practices. Whether the third-party content appears within our Sites environment (like a map frame), or you leave our Sites for another website to view it, the terms, conditions, and privacy policies of those other websites govern your online experience. Please review their terms of service and privacy policies if you have any question about their practices.

7. What rights do you have regarding the information Image Skincare collects about you?

If you are a resident of the European Union, you may have certain rights under the General Data Protection Regulation, (EU) 2016/679. Those rights include:

• The right to receive a copy of the personal data we have collected from you or have received about you.
• The right to ask us to correct any inaccuracies in the personal data we have about you.
• The right to lodge a complaint with the data protection authority in the EU member state in which you reside if you believe we have violated your rights.
• If the basis on which we rely for processing your personal data is your consent to the processing, the right to withdraw your consent for future processing of that personal data.

8. Will this Privacy Policy change?

We may make changes to this Privacy Policy at any time, so please review it periodically. We will update the effective date of the Privacy Policy at the time a change is made.

9. How can I contact Image Skincare?

If you have questions or concerns with respect to our Privacy Policy, please contact us by calling our UK Customer Service Department on 0345 504 0461, emailing us at info_uk@imageskincare.com, or writing to us at the following address: Venture House, Parklands, Railton Road, Guildford, Surrey. GU2 9JX. Attn: Privacy Policy, making sure to include your question, name and contact information.

If you have a concern about the way, we handle your personal data you have the right to complain to the Information Commissioner (ICO). You can find details of how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

Effective as of: May 1, 2019