Attn: Office of the General Counsel
1101 Westchester Ave.
White Plains, New York 10604
WHAT WE COLLECT
We collect information on or through our websites that can personally identify you but this will only occur when such information is voluntarily offered by you. In short, when you visit our websites or interactive advertisements, we will not collect any personal information about you (such as your name, home address, telephone number, e-mail address, or credit card information) unless you provide it to us voluntarily. If you decide not to provide us with personal information, you can still access our websites but you may be unable to participate in certain things, or receive product information offered through our websites or interactive advertisements.
Our websites sometimes include information about contests, sweepstakes, and other promotions that we are offering individually or jointly with one or more other parties, and we may allow you to enter electronically in some cases. If that occurs, we will use the information you provide for the purpose of conducting the event (for example, to notify you if you have won) and, when we have your consent, to offer you products and services of Combe and our joint event sponsors. In addition, we may also collect demographic and other data for advertising, promotion, and market research purposes.
At some of our websites you can request product samples, vote in polls, express an opinion, subscribe to one of our newsletters, or participate in one of our online forums. These programs require you to submit some information in order to participate. Combe may occasionally ask visitors to complete opinion polls or surveys to assess consumer interests, needs, and attitudes. Surveys help us provide better products and services that meet customer needs. Participation is completely voluntary and these surveys are optional.
If you provide our consumer service representatives with feedback on your experiences with our products or otherwise submit questions to our consumer service representatives, you will be asked to supply personal information for purposes of record-keeping and response.
In the situations described above, we may also enhance or merge your personal information with data obtained from third parties for the same purposes.
Combe works with various search entities to research certain usage and activities on our websites on our behalf. These entities use web beacons to conduct this research. The information collected through these web beacons is used to find out more about our users, including user demographics and usage patterns, for more accurate reporting and to improve the effectiveness of our marketing. Information recorded through the use of these web beacons is aggregated and then shared with us. No personally identifiable information about you is shared by these entities with Combe as a result of this research. If you prefer that these entities not record information by means of these web beacons on the Combe websites, please advise Combe Incorporated.
Aside from personal information, there will be occasions in which we may also collect information about you that you voluntarily submit and which is not personal, such as general statistical information like age, gender, zip/postal code, household size, interest, and preferences. Additionally, data which is not personal, including feedback, questions, comments, ideas and suggestions shall be deemed to be non-confidential, and Combe will be free to disclose and use such data for any purpose and through any means without any obligation whatsoever towards you. Please read our accompanying Terms of Service for further information in this regard.
Our web server collects the domain names (but not the e-mail addresses) of visitors to our websites. The information is sometimes aggregated to measure the number of visits, average time spent on visits, pages reviewed, and so forth. Combe utilizes this type of information to measure the use of our websites and periodically to improve their content.
WHY WE COLLECT PERSONAL INFORMATION
Our principal goal in collecting personal information from you is to give us an opportunity to interact with you during and after your visit to our websites and interactive banner advertisements, and to allow us to develop new products and services that are more responsive to your needs and desires. Combe collects personally identifiable information to respond to visitor questions and comments about Combe, its products and services, and other products of interest, to send e-mail newsletters, and to contact winners of sweepstakes, contests and promotions. Personal information also allows us to provide online services and features that are more likely to meet your expectations, and to customize our services to make your online experience smooth, efficient, and enjoyable. Combe occasionally sends e-mail messages (describing new products, promotions or events) to visitors who have agreed to receive such mailings. These mailings are optional and you may opt-out of these mailings completely at any time.
ABOUT SECURITY AND STORAGE
Combe has taken measures to keep all information from our online visitors as secure as possible against any unauthorized access or use. All information is protected by standard security measures that are periodically reviewed, however no website is entirely secure. You should protect the account information in your possession as well.
Combe and its affiliated companies are part of a multinational organization. Your personal information will generally be stored in our databases, which are located in various jurisdictions including the United States and the European Union. For easier processing of e-mail campaigns or other marketing purposes, your personal information may be sent, usually on a temporary basis, to countries outside the United States or the European Union. Combe data protection standards are the same, regardless of where your personal information is stored. Further, we will only store your personal information for a reasonable period of time.
SHARING YOUR INFORMATION
As stated above, your information may be transferred to one or more of our affiliated companies in other countries and regions of the world. Except for the situations described herein, we do not sell or transfer personal information to third parties outside of our global organization.
We do not share personal information with companies, outside organizations and individuals unless one of the following circumstances apply:
With your consent: We will share personal information with companies, outside organizations or individuals if we have your consent to do so.
For legal reasons: We will share personal information with companies, outside organizations or individuals if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable law, regulation, legal process or enforceable governmental request, detect, prevent, or otherwise address fraud, security or technical issues or protect against harm to the rights, property or safety of our users or the public as required or permitted by law.
In case of a sale or asset transfer: If we become involved in a merger, acquisition or other transaction involving the sale of some or all of our assets, user information, including personal information collected from you through your use of our services, could be included in the transferred assets. Should such an event occur, we will use reasonable means to notify you, either through email and/or a prominent notice on the services.
In aggregated form for business purposes: We may share aggregated, non-personally identifiable information publicly and with our partners we have a relationship with, advertisers or connected sites. For example, we may share information to show trends about the general use of our services.
Unless you consent, none of these other parties are allowed to re-sell any of your personal information or data or use such personal data for any other purpose.
SHARING OUR INFORMATION
Occasionally, visitors will have the opportunity to forward product sampling prospects or other information on a Combe website to friends or relatives or to send messages from our websites or interactive advertisements to friends or relatives. The personal referral information you provide to facilitate this communication is used on a one-time basis or stored only for analysis purposes, and it is not further used by Combe to re-contact referred individuals, except in circumstances where we obtain consent from the people you have referred to receive communications from us.
If you do not wish to continue receiving our notifications or any other emails from us, you may deactivate future mailing by clicking on the provided UNSUBSCRIBE link in each mailing.
If you supply us with your postal address online you may receive periodic mailings from us with information on new products and services, samples, marketing give-a-ways or information on upcoming events.
Persons who supply us with their telephone numbers online may receive telephone contact from us with information regarding new products and services, upcoming events or brand news/announcements.
THIRD PARTY SITES
ACCESSING, REVIEWING OR CHANGING YOUR INFORMATION
You have the right to access, update, or remove certain information that you have directly submitted to us by sending an email to us at [email protected] We may require additional information from you to allow us to confirm your identity. Please note that we reserve the right to keep any information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Combe is not responsible for updating information contained in third party lists or databases.
TRACKING TECHNOLOGIES GENERALLY
Most browsers are initially set up to accept cookies; however, you generally can reset your browser to refuse all cookies or indicate when a cookie is being sent or you can flush your browser of cookies from time to time. (Note: you may need to consult the help area of your browser application for instructions.) If you choose to disable cookies or refuse to accept a cookie, you may not be able to utilize all features of the websites. With respect to mobile apps, you can stop all collection of information via an app by uninstalling the app. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
ANALYTICS AND ADVERTISING TRACKING TECHNOLOGIES
Some of the third parties that collect information from or about you on the Service in order to provide more relevant advertising to you participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. This program offers a centralized location where users can make choices about the use of their information for online behavioral advertising. To learn more about the DAA and your opt-out options for their members, please visit (i) for website opt-out, http://www.aboutads.info/choices; and (ii) for mobile app opt-out, http://www.aboutads.info/appchoices. In addition, some of these third parties may be members of the Network Advertising Initiative ("NAI"). To learn more about the NAI and your opt-out options for their members, please visit http://www.networkadvertising.org/choices/. Please note that if you opt-out of online behavioral advertising using any of these methods, the opt-out will only apply to the specific browser or device from which you opt-out. Further, opting-out only means that the selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). We are not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
Our site is not directed toward children under 13 and we will not knowingly collect information for any child under the age of 13.
WHAT YOU CAN DO
You are in control of the personal information you provide to Combe online. You can:
1. Ask for a copy of your personal information.
2. Ask for your personal information to be corrected or updated.
3. Ask us to remove your personal information from our records.
If you have communicated with us electronically, and wish to do any of the preceding, please write to us at:
Attn: Office of the General Counsel
1101 Westchester Ave.
White Plains, New York 10604
Please give us your full name and telephone number in case we have questions. We will use diligent efforts to fulfill your request on a timely basis.
As evidenced by this Privacy Statement, we believe that the interactive media can coexist with the fundamentals of privacy, and we will continue our efforts to ensure that that coexistence is harmonious.
Thank you for your visit. We hope you enjoy your stay.
This Privacy Statement was most recently amended on ____________, 2018.