Privacy Policy Oct 21

Privacy Policy

This Privacy Policy sets out how we, Imbue collect, store and use information about you when you use or interact with our website, imbuecurls.com (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from October 18, 2020.


IMBUE PRIVACY NOTICE


Introduction

Imbue US ("Company" or "We"), a member of the Mibelle Group, respect your privacy and are committed to protecting it through our compliance with this policy. We’ve written this Privacy Policy to let you know how we use your personal information.

Mibelle Group is made up of different legal entities, details of which can be found here www.mibellegroup.com. This privacy policy is issued on behalf of the Mibelle Group so when we mention "Mibelle", "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the Mibelle Group responsible for processing your data. Mibelle Limited is the controller and responsible for this website.

Our Group General Counsel is our Data Protection Officer and is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Group General Counsel using the details set out below.

This policy describes the types of information we may collect from you or that you may provide when you visit the website (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On this Website.

• In email, text, and other electronic messages between you and this Website.

• When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Company or any third party; or

• Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.


Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information.

If you believe we might have any information from or about a child under 13, please contact us at: letschat@imbuecurls.com.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

• By which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline ("personal information");

• That is about you but individually does not identify you; and/or

• About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

• Directly from you when you provide it to us.

• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies and web beacons.

• From third parties, for example, our business partners.

Information You Provide to Us.

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.

• Records and copies of your correspondence (including email addresses), if you contact us.

• Your responses to surveys that we might ask you to complete for research purposes.

• Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

• Your search queries on the Website.

You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies.

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.

• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.

• Store information about your preferences, allowing us to customize our Website according to your individual interests.

• Speed up your searches.

• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. Our Cookie Policy can be found at: https://imbuecurls.com/pages/cookie-policy.

Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.

Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-Party Use of Cookies

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.

• To provide you with information, products, or services that you request from us.

• To fulfill any other purpose for which you provide it.

• To provide you with notices about your account, including expiration and renewal notices.

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

• To notify you about changes to our Website or any products or services we offer or provide though it.

• In any other way we may describe when you provide the information.

• For any other purpose with your consent.

We may also use your information to contact you about goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.

• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our Website users is among the assets transferred.

• To third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information.

• To fulfill the purpose for which you provide it.

• For any other purpose disclosed by us when you provide the information.

• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

• To enforce or apply agreements to which we are a party, including for billing and collection purposes.

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

• Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt out by checking the relevant box located on the form on which we collect your data (the order/registration form). You can also always opt out by logging into the Website and adjusting your user preferences in your account profile, by checking or unchecking the relevant boxes or by sending us an email stating your request to letschat@imbuecurls.com.

• Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties' products or services, you can opt out by checking the relevant box located on the form on which we collect your data (the order/registration form) or at any other time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to letschat@imbuecurls.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.

• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt out by checking the relevant box located on the form on which we collect your data (the order/registration form) or at any other time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to letschat@imbuecurls.com.

We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address:
 letschat@imbuecurls.com.. However, please know we do not currently sell data triggering that statute's opt-out requirements.

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Website and visiting your account profile page.

You may also send us an email at letschat@imbuecurls.com. to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

To edit, correct, or exercise any of consumer rights under the California Consumer Privacy Act of 2018, please visit https://imbuecurls.com/pages/ccpa-compliance-1.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit California Privacy Policy. To edit, correct, or exercise any of consumer rights under the California Consumer Privacy Act of 2018, please visit our CCPA Compliance page.

California's "shine the Light" law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to letschat@imbuecurls.com or write us at: Mibelle Limited, City Link Industrial Park, Phoenix Way, Bradford, BD4 8JP.

International Transfers of Data

We share your personal data within the Mibelle Group. This will involve international transfers of data.

Some of our external third parties are based in the UK, EU, or elsewhere so their processing of your personal data will involve international transfers of data. Whenever we transfer your personal data internationally, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

• Where we use certain service providers, we may use specific contracts, approved for use in the appropriate jurisdiction, which give personal data the standards of protections required by then-effective data privacy regulations.


Please contact us if you want further information on the specific mechanism used by us when we make international transfers of data.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Changes to Our Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: letschat@imbuecurls.com.