Last updated and effective date: February, 2023
We may provide different or additional privacy notices in connection with certain activities, programs, and offerings. We may also provide additional “just-in-time” notices that may supplement or clarify our privacy practices or provide you with additional choices regarding your personal information.
Our websites may include links to websites and/or applications operated and maintained by third parties. Please note that we have no control over the privacy practices of websites or applications that we do not own. We encourage you to review the privacy practices of those third parties.
2. What Personal Information We Collect
The types of personal information we obtain about you depends on how you interact with us and our products and services. When we use the term “personal information,” we are referring to information that identifies, relates to, describes, or can be associated with you.
The following are the categories and specific types of personal information that we collect:
Basic Identifying Information
Including your full name, alias, postal address, e-mail address, phone number, date of birth, account name, username or social media handle, or other similar identifiers.
Device Information and Other Unique Identifiers
Including device identifier, internet protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifier, or similar unique identifiers.
Internet or Other Network Activity
Including browsing or search history, and information regarding your interactions with our websites, emails, or advertisements.
Including information that permits us to determine your location, such as if you manually provide location information or enable your mobile device to send us precise location information.
Including credit or debit card number.
Including products or services you have purchased, returned, exchanged, or considered, preferences, and rewards activity related to Bona Fide Beauty Friends membership.
Including age, gender, race, ethnicity, estimated income, and household information, some of which may include characteristics of protected classifications under state or federal law.
Including your communications with us and any other content you provide (such as social media profiles, photographs, images, videos, survey responses, comments, product reviews, testimonials, and other content).
Audio and Visual Information
Including photographs, images, videos, and recordings of your voice (such as when we record customer service calls for quality assurance).
Inferences drawn from or created based on any of the information identified above.
Job Applicant Information
Including professional or employment-related information (such as education and employment history) and any other information you provide in connection with applying and interviewing for employment at Bona Fide Beauty. If we retain you as an employee, this may include, among other things, your Social Security number or taxpayer ID.
3. How We Collect Your Personal Information
We collect personal information about you from various sources.
For example, we collect and obtain information:
Directly from you
We collect personal information you provide, such as when you make a purchase, register for an account or create a profile, sign up for the Bona Fide Friends Program, contact us, respond to a survey, RSVP for an event, participate in a sweepstakes, contests or other similar campaign or promotion, respond to a survey, apply for a job, or sign up to receive emails, text messages, and/or postal mailings.
Using cookies and other automatic data collection technologies
When you visit our websites, open or click on emails we send you, or interact with our advertisements, we or third parties we work with automatically collect certain information using technologies such as cookies, web beacons, clear GIF, pixels, internet tags, web server logs, and other data collection tools. For more information, please see “Cookies and Similar Tracking Technologies” section below.
From our Third-Party Partners
If you have given Bona Fide Beauty permission to store your Payment Information, your credit card issuer may provide us with updated Payment Information (including credit card number and expiration date) in connection with the credit card issuer’s account updater service.
From Social Media Platforms and Networks
If you interact with us on social media or use features, such as plugins, widgets, or other tools made available by social media platforms or networks (including Instagram, Facebook, Twitter, TikTok, Google, YouTube, and Pinterest) in connection with our websites, we collect information that you share with us, or that the social media platforms share with us. For more information about the privacy practices of those social media platforms, please review the privacy policies and settings of the social media platforms and networks that you use.
From Other Sources
For example, we may obtain information about you from other sources, such as data analytics providers, marketing or advertising service providers, fraud prevention service providers, vendors that provide services on our behalf, or publicly available sources. We also create information based on our analysis of the information we have collected from you.
4. Cookies and Similar Tracking Technologies
We permit third parties to use tracking technologies on our websites for analytics to understand how visitors interact with our websites. For example, we use Google Analytics to evaluate website traffic and usage data to help us improve our products and services.
For more information about how Google collects and processes data visit: https://policies.google.com/technologies/partner-sites.
For more information about how to opt out of having your information used by Google Analytics, visit: https://tools.google.com/dlpage/gaoptout/
We also permit third parties to use tracking technologies on our websites for advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders. The third parties use their technology to provide advertising about products and services tailored to your interests which may appear either on our websites or on other websites. This is sometimes referred to as third-party behavioural advertising.
6. How We Share Your Personal Information
We may share personal information with our corporate affiliates, including our parent company, sister companies and subsidiaries including Bona Fide Beauty Products Inc. Such corporate affiliates process personal information on our behalf as our service provider, where necessary to provide a product or service that you have requested, including to administer the Bona Fide Friends program, or in other circumstances with your consent or as permitted or required by law.
We share certain personal information with third parties that perform services to support our core business functions and internal operations including: fulfilling orders, delivering packages, complying with your request for the shipment of products to or the provision of services by a third party intermediary, sending postal mail, e-mails and text messages, analyzing customer data, providing marketing assistance, administering our Ratings & Reviews, supporting beacons, processing credit card and debit card payments, investigating fraudulent activity, conducting customer surveys, and providing customer service.
Third Party Partners
Social Media Platforms and Networks
Some of our websites provide the opportunity to post content in a public forum. For example, Bona Fide Beauty’s Reviews allows you to participate to provide Ratings & Reviews. If you decide to submit information in a public forums, that information will be publicly available.
We may disclose personal information in response to subpoenas, warrants, court orders, government inquiries or investigations, or to comply with relevant laws and regulations. We may also disclose information to establish, exercise, or protect the rights of our company, employees, agents, and affiliates; to defend against a legal claim; to protect the safety and security of our visitors; to detect and protect against fraud; and to take action regarding possible illegal activities or violations of our policies.
We may share personal information with another company that buys some, or all, of the assets or stock of Bona Fide Beauty, and that company may use and disclose personal information for purposes similar to what is described in this policy. Bona Fide Beauty may also share personal information with prospective purchasers to evaluate the proposed transaction.
7. How We Protect Your Personal Information
We realize that, that individuals trust us to protect their personal information. We maintain reasonable and appropriate physical, electronic and procedural safeguards designed to help protect your personal information. While we attempt to protect your personal information in our possession, no method of transmission over the internet, or security system is perfect, and we cannot promise that information about you will remain secure in all circumstances.
For your convenience, our websites include functionality that allows you to remain logged in so that you do not have to re-enter your password each time you want to access your account. If you choose to remain logged in, you should be aware that anyone with access to your device will be able to access and make changes to your account and may be able to make purchases through your account. For that reason, if you choose to remain logged in, we strongly recommend that you take appropriate steps (such as enabling the “Passcode Lock” security feature on your mobile device) to protect against unauthorized access to and use of your account. Please also notify us as soon as possible if you suspect any unauthorized use of your account or password.
8. Your Rights
Consistent with applicable law, you may exercise your rights described in this section. Please note that some of the rights may vary depending on your country, province, or state of residence.
Accessing, Updating, Correcting, and Deleting Personal Information
You may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, update and correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.
Access and Deletion
You can submit a request to access or delete your personal information, or withdraw consent, by contacting our support team firstname.lastname@example.org.
For us to process some requests, we will need to verify your identity to confirm that the request came from you. We may contact you by phone or e-mail to verify your request. Depending on your request, we will ask for information such as your name, and an e-mail address that you have used with Bona Fide Beauty, or a phone number you have used with Bona Fide Beauty. For certain requests, we may also ask you to provide details about the most recent purchase you made online and the mailing address used to place the order(s).
9. Managing Communication Preferences
You can stop receiving promotional e-mails at any time by:
Clicking on the “unsubscribe” link at the bottom of any promotional e-mail that you receive from us; or contacting us at email@example.com. Please note, whilst we will honor your request to stop receiving marketing communications, we will continue to send you service-related communications such as emails confirming purchases through the Bona Fide Beauty Sites and keep your information for record keeping purposes.
You can opt-out of receiving text messages from us by replying “STOP” to the text message you receive from us. Please note that this will only opt you out of the specific text messaging program associate with that number.
Removing Content from Bona Fide Beauty Reviews
You can request that we remove content or information that you have posted on a public page by e-mailing details to support at firstname.lastname@example.org. Please note that while we will endeavour to honour your request. Our removal of your content or information does not ensure complete or comprehensive removal of that information from our website. For example, historical copies, or “caches,” may remain.
10. Children's Privacy
Our website is not intended for or directed to children under the age of 13. We do not knowingly collect personal information directly from children under the age of 13 without parental consent. If we become aware that a child under the age of 13 has provided us with personal information, we will delete the information from our records.
11. Transmission of Information to Other Countries
As an international entity, in order to provide our services we may need to transfer and process your personal information internationally (including to destinations outside the European Economic Area (the “EEA") and the UK), notably throughout Bona Fide Beauty and to the jurisdictions in which those entities exist. This means that when we process your personal information we may process it in any of these countries.
As a result, your information may be transferred to and/or processed in countries which may not guarantee the same level of protection for personal information as the country in which you reside. However, we have taken appropriate safeguards to ensure that your personal information will remain protected in accordance with this Notice. This includes implementing the European Commission's Standard Contractual Clauses for transfers of your personal information between our group companies, which require all group companies to protect personal information that they process from the EEA in accordance with European Union data protection law.
Further information can be provided on request: please contact us at email@example.com.
12. Information for California Residents – California Privacy Rights
This section discloses the legal rights of residents of states including California, Virginia, Colorado, Utah, and Connecticut.
Customers who are residents of California may request information concerning the categories of personal information (if any) we share with third parties or affiliates for their direct marketing purposes. If you would like more information, please submit a written request to us at firstname.lastname@example.org.
Categories of Personal Information We Collect and Our Purposes for Collection and Use
You can find a list of the categories of personal information that we collect in the “What Personal Information We Collect” section above. For details regarding the sources from which we obtain personal information, please see the “How We Collect Your Personal Information” section above. We collect and use personal information for the business or commercial purposes described in the “How We Use Your Personal Information” section above.
Categories of Personal Information Disclosed and Categories of Recipients
We disclose the following categories of personal information for business or commercial purposes to the categories of recipients listed below:
- We share Basic Identifying Information with: Service Providers, Third Party Partners, advertising networks, and social media networks.
- Providers, Third Party Partners, advertising networks, and social media networks.
- We share Internet or Other Network Activity with: Service Providers, Third Party Partners, advertising networks, and social media networks.
- We share Geolocation Data with: Service Providers and Third Party Partners.
- We share Payment Information with: Service Providers who process payments.
- We share Commercial Information with: Service Providers, Third Party Partners, advertising networks, and social media networks.
- We share User Content with: Service Providers who help administer our programs, such as Bona Fide Friends or product reviews, and social media networks.
- We share Inferences with: Service Providers who help administer marketing and personalization.
For more information on how your information is shared, please see the “How We Share Your Personal Information" section, which provides more detail on our Service Providers and Third Party Partners. We may also need to share any of the above categories of information pursuant to Legal Process or as a result of a Business Transfer as described in the “How We Share Your Personal Information” section.
California Privacy Rights
Subject to certain limitations and in addition to the choices enumerated under the “Your Rights” section above, California residents have the right to request access to (also referred to as the “right to know”) the categories and specific pieces of personal information we collect, use, and disclose; the right to request deletion of their personal information; and the right to opt out of any sales of personal information that may be occurring. In addition, California law also gives you the right to request that we limit the use of your "sensitive" personal information. Bona Fide Beauty does not use any sensitive personal information to make inferences about you and uses sensitive personal information only for reasons permitted by the California Consumer Privacy Act.
The rights granted to you under California law may provide us with exceptions to fulfilling your request, including where we need to retain the information to fulfill a legal obligation, complete a transaction with you, prevent fraud or any other purpose permitted by law.
Access and Deletion Requests
You may submit a request for a copy of the information collected about you in the last 12-months, or request deletion of information, by contacting our support team email@example.com. Please include "Data Subject Rights Appeal" in the subject line of your email, and provide your name, the email address associated with your request and any relevant information for us to investigate your appeal. We will provide a response to your request for an appeal within a reasonable time and in accordance with applicable law.
Sale of Personal Information and the Right to Opt-Out
Though we do not receive any monetary compensation, our use of tracking technologies may be considered a “sale” under California law. You can opt-out of being tracked by these third parties by emailing our support team at firstname.lastname@example.org. Please note that your use of our website may still be tracked by Bona Fide Beauty and/or our service providers. We do not knowingly sell the personal information of consumers under 16 years of age. For more information, please visit our "Do Not Sell My Personal Information" page.
Categories of personal information disclosed that may be considered a “sale” under California law: Basic Identifying Information, Device Information and Other Unique Identifiers, Internet or Other Network Activity, Geolocation Data, and Commercial Data.
Categories of third parties to whom personal information was disclosed that may be considered a “sale” under California law: advertisers and marketing partners, data analytics providers, and social media networks.
Right to Non-Discrimination
Notice of Financial Incentive
We offer our customers a loyalty program (the Bona Fide Friends) that provides certain perks, such as rewards and exclusive offers. We may also provide other programs, such as sweepstakes, contests, or other similar promotional campaigns (collectively, the “Programs”). When you sign up for one of these Programs, we typically ask you to provide your name and contact information (such as email address and/or telephone number). Because our Programs involve the collection of personal information, they might be interpreted as a “financial incentive” program under California law. The value of your personal information to us is related to the value of the free or discounted products or services, or other benefits that you obtain or that are provided as part of the applicable Program, less the expense related to offering those products, services, and benefits to Program participants.
You may withdraw from participating in a Program at any time by contacting us using the designated method set forth in the applicable Program rules. Visit the terms and conditions page of each Program to view full details, including how to join.
13. Changes To This Policy
We may update or modify this Policy from time to time in response to changing legal, technical or business developments. We will obtain your consent to any material Policy changes if and where this is required by applicable data protection laws. The date of the most recent version of this Policy will appear at the top of the page.
When we update our Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. For example, we will notify you of any changes to this Policy by posting a new Policy and updating the “last modified” date at the top of this page or by sending the new Policy to you via email, where appropriate.
14. Communicating With Us
If you have any questions about our privacy or security practices, you can contact us at email@example.com.
Thank you for taking the time to read this Notice.