Privacy Policy

LAST UPDATED AND EFFECTIVE: November 7, 2024

1. Collecting Your Personal Data

This Privacy Policy explains how we process and use your Personal Data. Please take time to read this Privacy Policy carefully. Please also review our Terms of Use. We will notify you of any additional processing of your Personal Data that is not mentioned in this document.

BY ACCESSING OR USING THIS SITE OR BY CHECKING THE BOX PROMPT BEFORE SUBMITTING PERSONAL DATA TO US, YOU EXPRESSLY CONSENT TO THE COLLECTION, USE, DISCLOSURE, RETENTION, AND DESTRUCTION OF YOUR PERSONAL DATA SUBMITTED TO US IN ACCORDANCE WITH THIS PRIVACY POLICY.

If you live in a state, like California and others, that extends comprehensive privacy rights respecting Personal Data to its residents, the subsection below titled “Comprehensive States’ Privacy Rights,” within Section 5, includes a description of your rights and our handling of your Personal Data.

If you have any questions about this policy or would like to exercise any of the rights set out within, you can email us at support@goPureBeauty.com.

2. Personal Data We Collect

When you visit the Site, we collect the following Personal Data:

Provided directly by you:

Identifiers, including name, alias, or other similar identifiers
Contact information, including home address, email address, telephone number, and other contact details
Birthday and/or age
Log-in and password
Content of your interactions with or messages to us, including applications, emails, texts, chats, and communication through social platforms or other feedback
Audio, electronic, visual, or similar information, including a sound or video recordings of your messages to our employees and visits to our Site

Collected automatically with your use of the Site (“Log Data”) or provided by third parties or public sources, such as social media profile information

Device identifiers and information about or generated by your device, such as IP address, log files, log-information, browser type and browser version
Statistics on your activities on the Site (such as the date and time of visits, the pages viewed, time spent at the Site)
Information about how you came to the Site
Data collected through cookies or other similar technologies discussed in more detail below.
Internet or other electronic network activity information and behavioral information, such as your browsing history, search history, and interaction with advertisements

3. How We Use Your Personal Data

We use your Personal Data for various purposes, depending on our relationship with you.

Customer Service

If you are a customer, we use your Personal Data for the purposes for which you provided it, including to:

Fulfill your product or service needs;
Register your online account;
Maintain our own accounts for billing and delivery;
Advise you about products, services, offers, or events that may be of interest to you; and Provide customer service to you.

Internal Business Activities

We may also use your Personal Data or Log Data to administer our internal business activities, including to:

Design and arrange the Site content and functionality in the most user-friendly manner;
Better understand customer trends and requirements and visitors to the Site;
Create non-personally identifiable data to be used for marketing;
Detect unauthorized activity on the Site;
Manage your account;
Track, monitor, and comply with legal obligations regarding the safety of our products or services; and Provide a service that is reliable, responsive, and efficient.

Analytics

In addition, we may use third-party services and advertising networks, such as Google Display Network or Google Analytics, that collect, monitor, and analyze Log Data to deliver online behavioral advertising that serves ads to you on our behalf on other sites throughout the Internet.

Text Message Marketing

If you sign up to receive recurring, marketing text messages from us, we collect your name, the mobile telephone number you provide, and your opt-in consent information, including your written or electronic signature, and use or disclose it to:

Send recurring, marketing text messages to the phone number you provide a varying frequencies using an automatic telephone dialing system (you can opt-out at any time by texting STOP to the number from which you receive our messages);
Provide customer service to you via text message or telephone, including a welcome message about your subscription in our text messaging program and responses to your requests for help by texting HELP or calling us at 1-800-925-4232;
Cancel your subscription to our text messaging program when, at any time, you text STOP to the number from which you are receiving our messages or change your communications preferences on our Site;
Confirm when we cancel your subscription to our text messaging program with a single, autodialed text message;
Engage and use one or more third-party service providers to provide software we use to perform the above functions, but we never sell text messaging originator opt-in data or consent to third-parties.

You do not have to opt in or agree to receive text messages as a condition of purchasing any products or services. Message and data rates may apply for any messages you receive from or send to us. If you have any questions about your text plan or data plan, it is best to contact your wireless provider. goPure Beauty and the mobile carriers (for example, T-Mobile) are not liable for delayed or undelivered messages.

4. How We Disclose Your Personal Data

There are certain circumstances in which we may disclose, transfer, or share your Personal Data with certain third parties after obtaining your consent. We may also use anonymized versions of your Personal Data for any purpose. By checking the box prompt before submitting your Personal Data to us, you expressly consent to our sharing your Personal Data, as set forth below.

For purposes consistent with this Privacy Policy, we may disclose your Personal Data with:

goPure Beauty affiliated entities

our parent companies, subsidiaries, and/or affiliates

Third-parties we engage to perform business-related functions for

third parties who provide services to our customers or with whom we partner to do business;
third parties who assist with our marketing, including chatbot applications, marketing agencies, and analytics companies,

goPure Beauty or provide services to customers, such as

Google Analytics, that collect, monitor, and analyze Log Data;

third party providers of database, software, email, security, backup and disaster recovery services;
payment processors;
our insurance carriers;
professional service providers, such as consultants, attorneys, and accountants;

Third parties to whom we disclose your Personal Data maintain and use it according to their own privacy policies.

Social media platforms

including Facebook, Instagram, YouTube, Google, Pinterest, TikTok, and Twitter, and application developers who specialize in social commerce

so you can connect to us, share your interests, express opinions about products and services, purchase our products, and generate interest in our products and services among members of your social networks or
to automatically record technical information about your interactions when you visit the Site to help deliver cookies; count users who visit the Site; track your online actions, movements, and related information available to social media platforms; and deliver optimized external ads that appear on third-party sites.

If you use third party social media features available on our Site, we or the third party may collect or share your data, including your Personal Data. If you do not want us to be able to access information about you, including Personal Data, from Third Party Sites, you must limit data collection and disclosure in the privacy settings on the Third Party Sites. We reserve the right to remove the Personal Data or other data of any person for any reason we, in our sole discretion, deem appropriate.

Successors who acquire your Personal Data

if we sell, merge, reorganize, dissolve, or similarly change our ownership or corporate structure

Government or third-party lawyers

if required to do so by law or in our good faith belief that such action is necessary to:

comply with a legal obligation, such as to report a serious adverse event to FDA;
protect or defend our rights, interests, or property, or that of third parties;
prevent or investigate possible wrongdoing in connection with the Site;
act in urgent circumstances to protect the personal safety of users of the Site or the public; or
protect against legal liability.

(a) Summary of Disclosures of Your Personal Data

The table below describes the categories of personal information that we may disclose to third parties, and the purpose of such disclosure:

Category of Personal Data

Identifiers

Examples:

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, or other similar identifiers

Purposes (Sample)

Fulfill product or service needs; conduct marketing, including analytics functions; process payments; secure digital and physical properties; and other business purposes set forth in Section 3 above

Disclosed to (Sample)

goPure Beauty affiliates; service providers; social media platforms; government authorities if reporting is required

Consumer records information

Examples:

Name, address, telephone number, financial information, medical information. Some personal information included in this category may overlap with other categories

Medical information is only collected if you report an adverse event and only shared if it is required to be reported to FDA.

Purposes (Sample)

Fulfill product or service needs; conduct marketing, including analytics functions; process payments; secure digital and physical properties; and other business purposes set forth in Section 3 above

Disclosed to (Sample)

goPure Beauty entities; service providers; government authorities if reporting is required

Internet or other similar network activity

Examples:

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement

Purposes (Sample)

Fulfill product or service needs; conduct marketing, including analytics functions; process payments; secure digital and physical properties; and other business purposes set forth in Section 3 above

Disclosed to (Sample)

goPure Beauty entities; service providers; government authorities if reporting is required

Professional or employment-related information

Examples:

Employer other employment-related information. Applicable to stylist and salon customers only

Purposes (Sample)

Fulfill product or service needs; conduct marketing, including analytics functions; process payments; secure digital and physical properties; and other business purposes set forth in Section 3 above

Disclosed to (Sample)

goPure Beauty entities; service providers; social media platforms

5. Your Rights About The Processing Of Your Personal Data

You have the right to consent or withdraw your consent to the collection, use, or disclosure of your Personal Data at any time, subject to exceptions defined by law. If you change your privacy preferences in the future, that will not limit the lawfulness of any processing performed based on your prior consent. To withdraw consent, please follow this link to our Privacy Center or email us at support@goPureBeauty.com and specify what you would like us to do. You may have additional rights, under the laws of your jurisdiction, with which we comply.

To stop email communications from us, you can also follow the unsubscribe instructions set forth at the bottom of our promotional e-mail messages. You may also access and correct some of your Personal Data by logging into your online account, if you have one. If you choose to limit our use of your Personal Data, you may not have access to certain functionality of the Site, such as promotions, product information, or opportunities.

Comprehensive States’ Privacy Rights

If you reside in a state that offers comprehensive privacy rights respecting your Personal Data, you have the following rights, which you may exercise at our Privacy Center:

Access: You have the right to access a copy of your Personal Data that we hold about you, upon receipt of a verified request.
Accuracy: You have the right to correct any inaccurate or out of date Personal Data, upon receipt of a verified request.
Deletion: You have the right to delete your Personal Data, upon receipt of a

verified request, with some exceptions that allow us to deny your request.

Equal Treatment: You have the right to equal treatment and not to be retaliated

against, regardless of your exercise of your privacy rights.

Sensitive Personal Data: You have the right to limit, with some exceptions, our use of your sensitive Personal Data, including identification numbers (like Social Security number), financial account and access information, precise geolocation data, personal demographic information (like your race, religion, philosophical

beliefs), genetic or biometric information, and information about your health or sexual activity. However, we do not collect/use Sensitive Personal Data, except for business purposes expressly permitted by law.

Opt Out: You have the right at any time to opt out of the sale of your Personal Data, the use of your Personal Data for profiling, or the sharing of your Personal Data for targeted or cross-context behavioral advertising.

We may deny your request to delete Personal Data when your Personal Data is needed for any of the following reasons:

Fulfill our obligations

To complete the transaction for which the Personal Data was collected, provide a good or service that you requested, or to take actions that we reasonably anticipate in connection with our ongoing relationship with you, or otherwise perform our contract with you

Security

To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity

Maintain Functionality

To debug, to identify, and repair errors that impair existing intended functionality

Free Speech

To exercise free speech, ensure the right of another California consumer to exercise their right of free speech, or exercise another right provided for by law.

Comply With Law

To comply with a legal obligation or the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code

Engage In Research

To engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent

Internal Uses

To enable solely our internal uses that are reasonably aligned with your expectations based on your relationship with us or other internal use of your Personal Data in a lawful manner that is compatible with the context in which you provided the information

(a) How To Exercise Your Rights About The Processing Of Your Personal Data

To exercise any of your rights, you or your authorized agent may contact us at support@goPureBeauty.com, 1-800-925-4232, or use our Privacy Center, which can be accessed here.

(b) How We Verify Your Requests

Before we may fulfill a request to access, correct, or delete your information, we are required to verify your identity. We will ask you to verify, at a minimum, your name and email address. When providing us this information, you represent and affirm that all information provided is true and accurate. If we are unable to verify that the consumer submitting the request is the same individual about whom we have collected Personal Data, we may contact you for more information, or we may not be able to meet your request. Only you, or an agent legally authorized to act on your behalf, may make a verifiable request related to your Personal Data.

If you use an authorized agent, however, we will require that you (1) provide the authorized agent signed permission to submit the request, (2) verify your identity directly with us, and (3) directly confirm to us that you provided the authorized agent permission to submit the request. These tasks will not apply if you have provided the authorized agent with power of attorney pursuant to California Probate Code sections 4000 to 4465. For your protection, we may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.

(a) How We Process Your Requests

Upon receiving your request through our Privacy Center, we will confirm receipt within ten (10) days and provide information about how we will process your request. We will make every effort to respond to your request within forty-five (45) days from when you contacted us. If you have a complex request, we may require up to ninety (90) days to respond. We may contact you within forty-five (45) days from the date you contacted us to inform you if we need more time to respond.

Applicable law may allow or require us to refuse to provide you with access to some or all of your Personal Data, or delete some or all of your Personal Data, or we may have destroyed, erased, or made your Personal Data anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to or delete your Personal Data, we will inform you of the reasons why, subject to any legal or regulatory restrictions. If you delete your User Content from the Site, copies of your User Content may remain viewable in cached and archived pages or might have been copied or stored by other Users. Proper access and use of information provided on the Site, including User Content, is governed by our Terms of Use.

6. Notice of Financial Incentive

goPure Beauty offers customers the opportunity to participate in its Loyalty Program (the “Program”), which may provide benefits, including the opportunity to earn points that can be redeemed for discounted products on the Site, to those who choose to join.

Those benefits are described along with other material terms and conditions in our Terms of Use. Our collection of customers’ Personal Data (including name, email address, and other Personal Data as described in Section 2 above) allows goPure to operate the Program and provide membership benefits. We use the Personal Data of the Program to both award and redeem points. Otherwise, the types of Personal Data we collect from Program members are generally similar to the types of Personal Data that we collect from non-members. The amount of Personal Data that we collect from a member or non-member may vary and is dependent on the level of interactions and engagement that the member or non-member has with us. We estimate the value of a member’s Personal Data to goPure to be equal to the value of the benefit we offer to you. We have calculated the value by using the expense related to the benefit. This estimate is not specific to any individual consumer and varies per consumer. We have based this good-faith estimate on the value that arises from our commercial relationships and the collection and retention of the Personal Data of consumers who have voluntarily signed up and chosen to remain in the Program. The value of benefits to Program members varies significantly as individual members take advantage of benefits to varying degrees.

7. How We Secure Your Personal Data

We use reasonable means to secure your Personal Data. However, no network, server, database, or Internet or e-mail transmission, is ever fully secure or error free. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Site. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site. Therefore, you should take special care in deciding what Personal Data you send to us electronically. For more information on the security of your Personal Data, please reference our Terms of Use.

8. How Long We Keep Your Personal Data

Except as otherwise permitted or required by law, we will only retain your Personal Data as long as necessary to carry out the purpose for which we collected it, including maintenance of your account, or to satisfy any accounting or legal requirements.

We may anonymize your Personal Data so that it can no longer be associated with you for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

You may close your account, unsubscribe to emails, and otherwise limit our use of your Personal Data by contacting us at support@gopurebeauty.com. However, we may retain your Personal Data for an additional period as is permitted or required under applicable laws. Even if we delete your Personal Data, it may persist on backup or archival media for an additional period of time.

9. How We Use Cookies

We use cookies on our Site. If you do not want cookies to be placed on your device, you can manage your cookie preferences in our cookie banner.

(a) What Are Cookies?

A cookie is a piece of information that is placed on your web browser or device when you access or use the Site. Cookies store text and can later be read back by the Site or third parties. Cookies can remember the information you access on one webpage to simplify your subsequent interactions with the Site or to use the information to streamline your transactions on related webpages.

(b) Why We Use Cookies

We use cookies to recognize your browser and you as a unique visitor to the Site through an anonymous unique identifier. We use cookies to:

recognize when you are logged in to your account on the Site;
monitor and analyze how you use the Site or interact with us;
remember your preferences to make your online experience easier and more personalized;
route Site traffic to effectively distribute the Site workload across servers; ● use analytics, such as Google Analytics, to help understand how visitors come to and use the Site, including through combination with third-party cookies of our service providers;
provide information to us about which advertisements you see and click or to show you ads on or off the Site; and
test new features.

You can opt out of and manage the use of cookies in a number of ways, either through your browser or via the third party placing the cookie. The following pages provide browser specific information:

Google Chrome
Internet Explorer
Safari
Mozilla Firefox

Many of the third party technologies that enable targeted banner advertising also allow you to opt out. Such third party service providers include Adroll, Rubicon, Google, Media Math, Perfect Audience, Quantcast, Retargeter, and Yahoo! among others. You can control your preferences directly with each such third party service provider.

To see how to opt-out of Google Analytics Advertising Features, visit Google Ads Settings, Ad Settings for mobile apps, or any other available means (for example, the NAI's consumer opt-out listed below). Google also provides a Google Analytics opt-outplug-in for the web.

You can find more information on how Google Analytics works in this Google guide and on Facebook App Events here.

You can learn more about cookies at the following third-party websites:

All About Cookies: http://www.allaboutcookies.org/; and
Network Advertising Initiative: http://www.networkadvertising.org/.

Note that if you disable, delete, or refuse to accept cookies, you may not be able to use some features of the Site and/or some of our pages might not display properly. Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not currently respond to DNT signals. Therefore, please be advised that third party web analytics companies may collect information about your online activities over time and across our website and other online properties.

10. Use of Automated Assistant Chatbot/Chat

We offer an Automated Assistant on the Site, which is operated through a third-party service provider, that you may engage with to answer your questions about our products or services. Our Automated Assistant is a chatbot. When you engage with our Automated Assistant, you are not conversing with a human. A chatbot is a computer program that uses artificial intelligence (AI) and natural language processing to understand customer questions and automate responses to you, simulating human conversation.

Our Automated Assistant operates like an interactive FAQ, responding to a set of anticipated questions with answers authored by humans and produced when prompted by a recognized question. It can transfer you to our human support staff if it is unable to answer your questions or if you ask to speak to a representative. Our Automated Assistant also uses AI to recognize your questions and formulate answers about common issues.

We offer the Automated Assistant/Chat function to make information about our products, services, and events immediately available to Site visitors. When you engage with our Automated Assistant/Chat, we and our third-party service provider record your communications with us and use them to provide further customer service to you, market to you, and improve the experience of our Automated Assistant for other Site visitors. You are not required to engage with our Automated Assistant/Chat and may reach our human support staff at support@gopurebeauty.com.

11. What Data Is Not Covered By The Privacy Policy?

The limitations in and requirements of this Privacy Policy do not apply to:

Third Party Sites: Any data you disclosed on websites not operated or controlled by us (“Third Party Sites”), even though we may provide links to them on the Site or in our emails. We are not responsible for the policies and practices employed by, or the content of, Third Party Sites. We suggest contacting those sites directly for information about their privacy policies and practices.
Non-Personally Identifiable Data: Any non-personally identifiable data we collect, including, without limitation, Log Data, domain names of your Internet Service Provider, your approximate geographic location, a record of your usage of the Site, the time of your usage, and aggregated personally identifiable information, but only to the extent the foregoing cannot be used to specifically identify you.
Aggregated Personal Data: Any aggregated Personal Data that can no longer be used to identify you will be treated as non-personally identifiable data under this Privacy Policy.
Publicly Available Data: Any information that is lawfully made available to the general public by you, from widely distributed media, or by a person to whom you disclosed the information without restricting it to a specific audience, including information you make disclose on social media.
Data Excluded From California Consumer Privacy Act (CCPA): Any information that is excluded from the scope of the CCPA because it is governed by another law, such as health or medical information covered by the Health Information Portability and Accountability Act (HIPAA) or personal information

covered by certain sector-specific privacy laws, such as the Fair Credit Reporting Act (FCRA).

12. We Do Not Collect The Personal Data of Children

We do not intentionally or knowingly collect any Personal Data from children under the age of eighteen (18), nor do we target our emails to them. Children under the age of eighteen (18) should not submit any Personal Data through the Site. We encourage parents and legal guardians to monitor their children's use of the Internet and instruct them to never provide Personal Data through the Site. If you believe a child under the age of eighteen (18) may have provided Personal Data to us through the Site, please contact us at support@gopurebeauty.com, and we will use reasonable efforts to delete it from the Site and our files.

13. International Privacy Laws

If you are visiting the Site from outside the United States, please be aware that you are sending information (including Personal Data) to the United States where our servers are located. That information may then be transferred within the United States or out of the United States depending on the type of information and how it is stored by us. We will hold and process your Personal Data in accordance with privacy laws in the United States and this Privacy Policy. Please note that privacy laws in the United States may not be the same as, and in some cases may be less protective than, the privacy laws in your country, and while in the United States, Personal Data may be subject to lawful access requests by government agencies.

14. Changes To This Privacy Policy

We may occasionally make changes to this Privacy Policy. If we wish to use your Personal Data for a new purpose not covered by this Privacy Policy, we will provide you with a new Privacy Policy and notice explaining this new use prior to commencing the processing of your Personal Data pursuant to the new Privacy Policy and setting out the relevant purposes and processing conditions. If we change this Privacy Policy, your checking the box prompt before submitting Personal Data to us, or continued use of the Site after receiving the notice outlined above, will signify your consent to such changes.

15. How You Can Resolve A Privacy Dispute With Us

If you have a complaint about this Privacy Policy or our privacy practices, we will work with you in an attempt to resolve your complaint. Please contact us at support@gopurebeauty.com. Please also refer to the arbitration procedures described in the Dispute Resolution section of the Site’s Terms of Use.BY CHECKING THE BOX PROMPT BEFORE SUBMITTING YOUR PERSONAL DATA TO US, WE EACH AGREE TO SETTLE DISPUTES ONLY BY NON-CLASS, INDIVIDUAL ARBITRATION, INSTEAD OF SUING IN COURT (EXCEPT CERTAIN SMALL CLAIMS). THE RULES IN ARBITRATION ARE DIFFERENT. THERE IS NO JUDGE OR JURY, BUT AN ARBITRATOR CAN AWARD THE SAME DAMAGES AND RELIEF, AND MUST HONOR THE SAME LIMITATIONS STATED IN THE AGREEMENT, AS A COURT WOULD.

To initiate an arbitration proceeding, you must send us a notice of your complaint that includes a written statement of your name, address, and contact information, the facts giving rise to your complaint, and the relief you are requesting (the “Dispute Notice”). The Dispute Notice must be addressed to: NATURAL LIFESTYLE BRANDS, INC. d/b/a GOPURE BEAUTY, 543 Country Club Drive, Suite B123, Simi Valley, CA 93065 and sent to us as described in the Dispute Resolution section of the Site’s Terms of Use. If we do not reach an agreement to resolve your privacy complaint within sixty (60) days after we receive your Dispute Notice, you may commence an arbitration proceeding under the Dispute Resolution section of the Site’s Terms of Use.

16. Contact Us

If you have any questions about this Privacy Policy, our practices, or your dealings with us, or to exercise any and all of your rights, please contact us at support@gopurebeauty.com.