Last updated: August 5, 2021
Personal Information We May Collect
“Personal Information” is information that identifies you as an individual or relates to an identifiable person, including:
- postal address;
- telephone number;
- email address;
- credit and debit card number and other associated card information; and
- user account ID and password.
We need to collect and process these types of Personal Information in order to provide the requested Services to you or because we are legally required to do so. If you do not provide the information that we request, we may not be able to provide you with the requested Services.
How We Collect Personal Information
We and our service providers collect Personal Information in a variety of ways, including:
- Through the Services: We may collect Personal Information through the Services, such as when you sign up for a newsletter or make a purchase.
- Offline: We may collect Personal Information from you offline, such as when you place an order over the phone or contact customer service.
- From Other Sources: We may receive your Personal Information from other sources, such as public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected) and other third parties.
Use of Personal Information
We and our service providers use Personal Information for our legitimate business purposes, including the following:
- Providing the functionality of the Services and fulfilling your requests.
We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
- 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.
- Providing you with our newsletter and/or other marketing materials.
We will engage in this activity with your consent.
- To send you marketing related emails, with information about our products and company.
- Analysis of Personal Information for business reporting and providing personalized services.
We provide personalized services either with your consent or because we have a legitimate interest.
- 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 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.
- Allowing you to participate in polls, sweepstakes, contests, or promotions or activities.
We use your Personal Information in this context to manage our contractual relationship with you.
- 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.
- Aggregating and/or anonymizing Personal Information.
- We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.
- Accomplishing our business purposes.
We will engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
- 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.
Disclosure of Personal Information
We disclose Personal Information:
- Combe Incorporated’s affiliates include 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 the party responsible for the management of the jointly-used Personal Information.
- To our third-party service providers, to facilitate services they provide to us.
- 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.
- To third-party sponsors of sweepstakes, contests, and similar promotions.
- By using the Services, you may elect to disclose Personal Information.
- On message boards, chat, profile pages, blogs, and other services to which you are able to post information and materials (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
Other Uses and Disclosures
We 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 and conditions; and
- To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
- In connection with a sale or business transaction.
- 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). Such third parties may include, for example, an acquiring entity and its advisors.
Other Information We May Collect
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual, such as:
- Browser and device information
- Information collected through cookies, pixel tags and other technologies
- Demographic information and other information disclosed by you that does not reveal your specific identity
- Information that has been aggregated in a manner such that it no longer reveals your specific identity
How We Collect Other Information
We and our service providers collect Other Information in a variety of ways, including:
- Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.
Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Services and response rates.
We do not respond to browser do-not-track signals at this time.
IP Address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.
From you: Information such as your preferred means of communication is collected when you voluntarily disclose it.
By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Services (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).
How We Use and Disclose Other Information
We use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information (such as combining your name with your location). If we do, we will treat the combined information as Personal Information as long as it is combined.
THIRD PARTY SERVICES
We seek to use reasonable organizational, technical and administrative measures designed to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. 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
Your choices regarding our use and disclosure of your Personal Information
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:
Receiving electronic communications from us: 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.
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 Privacy@combe.com. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
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 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).
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).
USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under 16.
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@example.com.
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.
- 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.
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.