DEFINITION OF PERSONAL INFORMATION“Personal information” is any information about an identifiable individual. This may include, for example, your name, home address, contact information, and email address. It may also include more technical information, but only when this information can identify you as an individual. Information that is aggregated and/or de-identified and cannot be associated with an identifiable individual is not considered to be personal information.
PRIVACY PHILOSOPHIESAlthough our business and social network community have unique services and offerings, they share a similar privacy philosophy. ZO follows these privacy principles in our conduct in the collection, use, release, and security of personal information both online and offline:
• Providing you with notice of our information practices.
• Giving you choices about how your data will be used and the ability to opt-out at any time.
• Providing you with the opportunity to update or correct your personal information.
• Using information security safeguards.
• Committing to complying with applicable privacy requirements.
• Limiting the sharing of your information and requiring all partners to abide by applicable privacy and data protection laws.
• Providing you with means to contact us about privacy-related issues.
CROSS BORDER TRANSFERSThis site is owned and operated by ZO, which is based in the United States. Please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located, and our central database is operated, and may be shared with ZO’s affiliates, subsidiaries or agents based or otherwise located outside of Canada. By continuing to use the Sites, or providing us with any information, you consent to the collection, storage, and processing of your data in the United States and in any other country which ZO may transfer your data in the course of its business, and acknowledge that when your personal information is used or stored in a jurisdiction other than where you are residing, it may be subject to the law of such foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in such jurisdiction.
INFORMATION WE COLLECT ABOUT YOUZO collects information that is provided to us directly by you, information from your engagement with our Sites, advertising and media campaigns, and information from third parties who have gained your consent to share your data. We may also combine information collected via different methods in order to build a more complete profile of your preferences regarding our products and services, allowing us to provide a more tailored consumer experience.
Personal information we collect may include:
• Identifiers and contact information, such as your name, email and postal address, delivery address and telephone numbers, or social media account handles;
• Demographic data, such as your age;
• Health-related information, such as your skin type and conditions;
• Opinions and preferences, such as aesthetic concerns relating to your skin and skincare goals;
• Financial information, such as your payment information, billing address and purchase history;
• Browsing activity on our sites, such as pages and events viewed and your IP address, if it can identify you as an individual;
• Any other information you provide to us (as further detailed in the HOW WE COLLECT PERSONAL INFORMATION section).
HOW WE COLLECT PERSONAL INFORMATIONWe collect personal information in a variety of ways, including directly from you or through online technologies.
Directly From You
You may provide personal information to us by mail, by email, over the telephone, through our Sites or in any other direct manner, for instance when you engage in certain activities on our Sites, such as registering for an account on our website, making purchases from ZO (whether online or through the ZO Skin Centres), signing up for the ZO Skin Health email list, submitting content and/or posting comments on the ZO Blog or ZO social media accounts, leaving a product review, entering a sweepstakes or contest, or sending us feedback through the Contact Us form.
Through Automatic Collection of Data, Online Technologies and Other Sources
Information concerning your computer hardware and software is automatically collected and may be shared with other affiliated websites. This information may include: your IP address, browser type and language, domain names, access times, referring website addresses and the content of any undeleted cookies that your browser previously accepted from us (see "Cookies" below). ZO uses this information to maintain the quality and security of its service and to provide general statistics about website visitors.
We may use the latest standard Internet technology, such as web beacons and other similar technologies, to track your use of the Sites. In some of our emails to our customers, we may use click through URLs that will bring you directly to that specific content on our sites. We also may include web beacons in our emails, newsletters, or notifications to determine whether messages have been opened and/or acted upon. This enables us to customize the services we offer our Site visitors, to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming or other activities. We analyze and utilize this information to improve our marketing programs, change the frequency of our emails, and assess consumer interests. You can find more information on how to prevent or limit the use of web beacons by clicking here.
Information from Other Sources
Social Media Platforms
You may withdraw your consent to our collection, use, or disclosure of your personal information at any time, subject to any legal or contractual restrictions. Your withdrawal of consent will not operate retroactively and may impact your ability to access our services, offers, and content.
HOW WE USE THE INFORMATION WE COLLECTWe will primarily use your personal information to provide better products, service offerings, and support to you. Specifically, ZO collects and uses your personal information in order to:
• operate the Sites and to deliver the services that you have requested;
• manage your account and provide you with customer support;
• provide tailored content and marketing based on your preferences;
• post content and consumer reviews on our Sites and associated social media accounts;
• perform research and analysis (both in the form of personal information and as aggregated or de-identified information) about your use of, or interest in, our products, services, or content, or products, services or content offered by others;
• conduct research and analytics;
• verify your identity and prevent fraud;
• verify your eligibility and deliver online and/or offline communication in connection with contests and sweepstakes;
• contact you regarding updates to our policies as well as enforcing our terms and conditions and complying with all applicable laws; and
• manage our business and perform functions as otherwise described to you at the time of collection.
The collection of your e-mail address and name during account registration enables ZO to communicate with you regarding the status of your account and any orders placed as well as sending you any requested newsletter(s) or to send you any requested mailings or offers. If you indicated upon registration that you are interested in receiving offers or information from our partners and us, we may occasionally send you emails regarding product and event information, cosmetic tips or promotions. Only ZO will send you these solicitations, and only if you have previously indicated that you wish to receive them. If you prefer not to receive such emails, please do not opt-in to receive these emails. You may opt-out of receiving marketing emails from ZO when you register on the Site or otherwise provide contact information to ZO. ZO provides links to send email messages to the Sites for your convenience and your email address is used so that we may reply to your inquiry.
ZO tracks the pages on our Sites that our customers visit in order to determine which areas of the Sites are the most popular. This data is used to deliver customized content and advertising within the Sites to customers whose behavior indicates that they are interested in a particular subject area. The vast majority of data collection from Site visitors is used to assess the type of people visiting that Site and to determine what content is most frequently accessed by those visitors. This information helps ZO improve its Sites by offering content that more specifically meets the interests of its Site visitors. You can always choose to limit the data you provide to ZO, but if you choose not to provide certain information, you may have altered experiences with our Sites, or be unable to access some of the services, offers, and content on our Sites.
WITH WHOM WE SHARE YOUR INFORMATIONWe want you to understand when and with whom we may share personal or other information we have collected about you or your activities on our Sites or while using our services. We do not sell your personal information to any third parties.
Authorized Service Providers: We may share your personal information with our authorized service providers that perform certain services on our behalf. These services may include processing orders, processing credit card payments, delivering products and services, providing customer service and marketing assistance, performing business and sales analysis, supporting our website functionality, and supporting other features and promotions offered through our Sites. When you enter into transactions with others or make payments on our Site, we will share transaction information with only those third parties necessary to complete the transaction. We will only provide these service providers with the limited information that they need to provide us with such services, including limited access to personal information needed to perform their functions. However, they are not permitted to share or use such information for any other purposes. You can obtain access to information about our policies and practices with respect to service providers outside Canada by contacting us using the coordinates provided in the section entitled “CONTACT US”.
ZO Authorized Physicians: In order to purchase ZO products through our Site, you will be asked to choose a ZO Authorized Physician before completing your purchase. ZO Physicians can offer product guidance and help you experience safe and effective results. When registering an account with ZO, you will be given the option of agreeing to allow ZO to share your personal information with your selected Physician. We will only share your personal information with your selected Physician if you choose to “opt-in” at registration. If you do not wish for your information to be shared with your selected Physician, please do not opt-in.
Legal Obligations: ZO may transfer and disclose information, including your personal information, usage data, and device identifiers to third parties in response to a subpoena, court order, or other requests for cooperation from a law enforcement or other government agency (including civil and criminal matters); to establish or exercise our legal rights; to defend against legal claims; or as otherwise permitted or required by law. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion. This may include respecting requests from jurisdictions outside of the United States if we have a good faith belief that response is required by law under the local laws in that jurisdiction, apply to users from that jurisdiction, and are consistent with generally accepted international standards. We may also share information when we have a good faith belief it is necessary to prevent illegal activity; to respond to an emergency; to protect and defend the rights or property of ZO or any of ZO’s Sites; and, act under exigent circumstances to protect the personal safety of users of ZO, its Sites, or the public; or to enforce our Terms of Service or other policies. This may include sharing information with other companies, lawyers, courts or other government entities where applicable.
Otherwise With Your Consent: Other than the purposes listed above, we may, with your implied or express consent, share or disclose your personal information outside of our group of companies, in accordance with applicable laws.
You can opt-out of receiving targeted or interest-based advertisements by changing your browser settings on your device, and/or using third party unsubscribe functionality (e.g., via Google or Facebook) to change your preferences within their platforms. Please note that disabling, blocking or deleting some of these technologies, such as cookies, may cause you to lose the functionality of certain features on our websites and apps. You can also opt out of receiving targeted advertising through use of the Network Advertising Initiative or Digital Advertising Alliance opt-out pages, for participating advertisers. You can also opt out of certain targeted advertising programs, however even if you decide to opt-out of targeted advertising, you may still see ads on ZO Sites, but they may not be targeted to you based on your collected information.
We may also link to other websites not owned or operated by ZO through postings on our Sites, which may include links from our partners or third-party advertisers. We do not control, recommend or endorse and are not responsible for these sites or their content, products, services or privacy policies or practices. These other sites may utilize their own cookie or other tracking technologies in order to collect your data or solicit personal information and may or may not have their own published privacy policies. In some instances, these other sites may provide us with information about your activities on those websites. In consequence we may recognize your data across different platforms and/or devices that you use which may result in you seeing “targeted” ads for our products on another website, social media platform, or device. We encourage you to review the privacy statements of the third-party websites you choose to visit so that you can understand how those websites collect, use and share your information. ZO is not responsible for the privacy policies or other content on third-party websites accessed through its websites.
Aggregated InformationInformation that has been aggregated or de-identified and cannot be associated with an identifiable individual is not considered to be personal information. When we gather certain information about you when you visit our Sites as described in the section above entitled “HOW WE COLLECT PERSONAL INFORMATION”, we may aggregate or otherwise de-identify this information and analyze it on that basis. We may use such information and analysis for internal business purposes, such as generating statistics and developing marketing plans. The technologies we use enable us to determine (i) the IP Address of your computer and its geographic location; (ii) your search terms or interactive behavior on the Sites; (iii) your purchasing behavior; (iv) source of the information sought by you during your search; and (v) the age of your results data.
We may share aggregated and de-identified information we collect. We may also share it with third parties to develop and deliver targeted advertising on our Sites and on websites of third parties. We may combine such non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. This information does not contain any personal information and may be used to develop services that we hope you and other users will enjoy using.
GENERALUser Generated Content
We do not screen, filter or monitor user submissions to the ZO Blog or ZO product reviews. We do not aggregate any additional personal information from any such submissions except for those provided by the submitter (i.e., name, likeness, email address, whether such information pertains to the submitter or someone else, etc.) and such personal information may be viewed by other users of the Sites subject to our Terms of Service.
Accessing and Updating Your Information
ZO takes reasonable measures to maintain updated and accurate information and we respect your right to access and update any of your personal information. If you have an online account with us, you have the ability to review and update your personal information at any time by logging into your account. You may also request access to or update your personal information by emailing us at email@example.com. You can also write us at the address in the “Contact Us” section below. If you send us a letter, please provide your name, address, email address, and detailed information about the change(s) you would like to make. We will retain your personal information for as long as your account is active or as needed to provide you with our services and/or as necessary to comply with certain legal obligations.
When you register on our Sites you may be given a choice as to whether you want to receive email notifications and/or newsletters. At any time, you can choose to stop receiving notification emails by accessing your account settings or through the link at the bottom of the emails. updating your preferences on the Sites; sending us an email to firstname.lastname@example.org, or following the unsubscribe instructions in the communication(s) that you receive from us. It may take up to 10 days for us to process an opt-out request. We may send you other types of transactional and relationship e-mail communications, such as service announcements, administrative notices, and surveys, without offering you the opportunity to opt out of receiving them as long as your account is active. Please note that, changing information in your account, or otherwise opting out of receipt of promotional email communications will only affect future activities or communications from us. If we have already provided your information to a third-party (such as a credit card processing partner or an event provider) before you have changed your preferences or updated your information, you may have to change your preferences directly with that third-party.
In accordance with routine record keeping practices, we may delete records that contain personal information that has been previously collected. We are under no obligation to store such personal information indefinitely and disclaim any liability arising out of, or related to, the destruction of such personal information. In addition, you should be aware that it is not always possible to completely remove or delete all of your information without some residual data due to encrypted backups of our databases and other record retention requirements.
Protecting Your Personal Information
ZO maintains reasonable security measures (including physical, technological and organizational measures) to help safeguard your personal information from unauthorized access, disclosure, and/or destruction. In addition, we use encryption in the transmission of your sensitive personal information between your system and ours, and when transferring information for processing we require third parties providing services on our behalf to do the same. If you choose to create a profile on our Sites or if you choose to register for an account, you will be required to select a password which should be kept confidential. If you share a computer with anyone, you should always log out of the website before leaving it to prevent access to your information from subsequent users of that computer. There are, however, risks inherent in sharing information, and though we provide privacy settings, please be aware that no security measures are perfect or impenetrable. Therefore, although we take steps to secure your information, please note that we cannot ensure or warrant the security of any information you transmit to us. Users should also take care with how they handle and disclose their personal information and should avoid sending personal information through insecure email. We are not responsible for third-party circumvention of any of our privacy settings or security measures, where those privacy settings or security measures satisfy all the requirements of applicable laws.
User Submissions, Communities and Forums
We may provide areas on our Sites where you can post information about yourself, including your name and email address, communicate with others; upload content; and post comments/reviews. Any personally identifiable information or personally sensitive data that you voluntarily disclose through posting content on the ZO Blog, product reviews, or other public online forums hosted on the Site, may be collected and used by others. We encourage you to exercise discretion and caution with respect to your personal information. Once you have posted information, you may not be able to edit or delete such information.
Our Site is a general audience website, are not directed to children under the age of 13, and we do not knowingly collect personal information from children under the age of 13. The Sites and the Services are not intended for use by children. You may access the Sites and use the Services only if you are of legal age to lawfully form a binding contract. If you are under the age of 18 and do not have a parent’s or legal guardian’s permission to visit the Sites, you may not access the Sites or use any Services. If you are 13 years of age or older, then you can only use the Sites and Services with the consent of your parent or legal guardian.
No Rights of Third Parties
CONTACT USIf you have any further questions regarding the data ZO collects, or how we use it, then please feel free to contact us by email at: email@example.com, via phone at (888) 893-1375, or in writing at: ZO Skin Health, Inc.
9685 Research Drive
Irvine, CA 92618
Last Updated: October 11, 2021