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Privacy Policy

Effective as of September 15, 2020

BeNome, Inc., d/b/a Pure Culture Beauty (“Pure Culture Beauty,” “we,” “our,” “us”) is committed to providing our customers with privacy protections related to the use of our website, pureculturebeauty.com (the “Site”), and the sale of our products and services. The following Privacy Policy (the “Policy”) describes how we may collect, use, share, and disclose your personal information when you interact with Pure Culture Beauty.

Review this Policy carefully. By using our Site or providing your personal information to Pure Culture Beauty through other means, you agree to this Policy and consent to the collection, use, sharing, and disclosure of your information as described in this Policy. If you do not agree with any provision in this Policy, please do not use our Site or provide your personal information to Pure Culture Beauty.

Our Site may contain links to independent third party websites. When you click on a link to another website or location, you will leave our Site, and the third party website may collect personal information from you. We are not responsible for the content or privacy practices of any third party website, application, or feature. You should review the privacy policies or notices of any websites you visit.

PERSONAL INFORMATION WE COLLECT

When you visit our Site, use our services, or buy our products, we may collect some or all of the following personal information:

  • Registration Information: Information you provide us when you create an account, including your name, email, username, and password.
  • Shipping/Billing Information: Shipping address, billing address, credit card number, phone number, and any other information used to process a transaction.
  • Self-Reported Information: In order to obtain personalized skincare results, you may choose to tell us certain information regarding your date of birth, gender, background, lifestyle, and skin characteristics (e.g., skin type, texture, sensitivity).
  • Testing Results: By using our services, you may provide information to us regarding the particularities of your skin by completing a test kit and answering related survey questions online. Additionally, you may choose to participate in lab testing whereby our third-party laboratory processes the sample you provide to generate a microbiome report.
  • Automatically-Collected Information: Information regarding how you use our Site, which we may collect through cookies, log-files and web beacons. Examples of information which we may collect include your web browser information, Internet Protocol (“IP”) address, and time zone.
  • We may use the following technologies to automatically collect personal information:

  • “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies as well as how to disable cookies, visit http://www.allaboutcookies.org.
  • “Log files” are electronic files that track actions occurring on the Site and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
  • “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

HOW WE USE YOUR PERSONAL INFORMATION

We use the personal information that we collect to fulfill any orders you place through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we may use your personal information to:

  • Communicate with you;
  • Personalize your user experience;
  • Screen our orders for potential risk of fraud;
  • Respond to customer service requests;
  • Send marketing and promotional communications;
  • Administer customer accounts;
  • Analyze, improve, and optimize Site functionality and the provision of products and services;
  • Generate analytics about how customers interact with the Site; and
  • In accordance with the preferences you share with us, provide you with information or advertisements relating to our products and services.

SHARING YOUR PERSONAL INFORMATION

We may share your personal information with third parties who perform services on our behalf in the U.S. and Canada. Such service providers may only use your personal information for the service we employ them for and may not share your information with other third parties. Examples of potential services for which we may engage providers include website hosting operations, payment processing and authorization, laboratory testing, and product fulfillment.

We may also share your personal information with third parties to help us understand how a customer uses our Site (e.g., analytics) or to provide you with targeted advertisements or marketing communications that we believe may interest you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You may opt out of targeted advertising from these third parties by visiting the websites below.

We may also share your personal information when required by applicable laws and regulations, for reasons such as in response to a subpoena, search warrant, or other lawful requests for information we receive, or to otherwise protect our rights.

Finally, we may share aggregated information to third parties for the purpose of benchmarking trends based on the microbiome data collected. Aggregated data is not considered personal information because we remove all personal identifiers, and the raw data is not personally identifiable on its own.

HOW WE PROTECT YOUR PERSONAL INFORMATION

We maintain reasonable administrative, technical, and/or physical safeguards and appropriate security measures to protect your personal information from loss, misuse or unauthorized access, disclosure, alteration, or destruction. We cannot guarantee, however, the security of your personal information, as no electronic data transmission or storage of information is completely secure. We encourage you to take steps to protect the privacy of your user account information and password to prevent unauthorized access or disclosure.

For users choosing to participate in microbiome testing, we have committed to advanced safeguards to protect your personal information, such as requiring that the personnel who come in contact with your sender information (e.g., name, address) differ from the personnel who conduct the testing and processing of your sample. Once the laboratory processes your sample, they will send us the results via a unique barcode, which does not include any sender information.

If we become aware, or reasonably believe, that your personal information has been disclosed or accessed by an unauthorized individual, we will notify you consistent with our legal obligations.

DO NOT TRACK

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

MINORS

We do not intentionally direct our services to or collect personal information from minors under 16. If a minor under 16 submits personal information to us, and we become aware that such personal information belongs to a minor under 16, we will take action to address the issue. If you believe that we may have collected the personal information of a minor under 16, please contact us at privacy@pureculturebeauty.com.

CALIFORNIA RESIDENTS

If you are a California resident, California privacy laws may afford you certain rights regarding your personal information, as described below.

Access and Shine the Light

You may request access to specific pieces of collected personal information, which we will provide in a readily useable format. You may also request general information regarding the categories of personal information collected, the categories of sources from which we collected personal information, the business purpose of such collection, and the categories of third parties with whom we may have shared personal information. In lieu of making a formal request, you can find some of this information in the “Personal Information We Collect,” “How We Use Your Personal Information,” and “Sharing Your Personal Information” sections of this Policy.

For your safety, we will not disclose sensitive information, such as your social security number, financial account number, or passwords.

Pursuant to California’s “Shine the Light” law, California residents with whom we have an established business relationship may request certain information regarding the personal information we have shared with third parties for direct marketing purposes during the preceding calendar year. Please be aware that you may only request this information once per year. To make such a request, please contact us by email at privacy@pureculturebeauty.com.

Deletion

You may request that we delete your personal information at any time, subject to certain exceptions.

Choice

As discussed in the “Sharing Your Information” section, we engage in behavioral analytics and targeted advertising to improve your user experience. California law may broadly construe such activities as “sales” of personal information because it involves sharing your personal information with companies that provide services to us. You may choose to opt out of such disclosures of your personal information by emailing us at privacy@pureculturebeauty.com.

You can submit a request to exercise your California privacy rights by emailing us at privacy@pureculturebeauty.com or contacting us at 1-856-517-8141. When we receive a valid request (one which is not unfounded or excessive), we will generally respond within 45 days. Once we receive a request, we may ask for additional personal information to verify your identity. If we are unable to fulfill your request, we will inform you of the basis for rejection.

We will not discriminate against you for exercising your California privacy rights.

DATA RETENTION

We will retain your personal information as long as reasonably necessary for the business purposes described in this Policy and in accordance with applicable legal requirements.

When you place an order through our Site, we will maintain your order information unless and until you request that we delete your information.

CHANGES TO OUR PRIVACY POLICY

We will review and update this Policy from time to time, so please review it regularly for any changes. We will notify you of material updates to the Policy either via our Site or through direct communication. By continuing to use our Site, products, or services, you affirm your continued consent to the terms of this Policy.

CONTACT US

If you have any questions about this Policy or would like to make a complaint, email us at privacy@pureculturebeauty.com or contact us at 1-856-517-8141.

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