Privacy Policy

2021-05-06

This Privacy Policy describes how Figure 1 Beauty, Inc. and its subsidiaries and affiliates (“Figure 1”, “we,” “us,” and/or “our”) handle personal data we collect online through our website at www.fig-1.co (and any other affiliated website on which this Privacy Policy is posted) and any mobile applications we might offer, including any consultation and other services we may offer through our websites and mobile applications. We call all of these the “Services”. This Privacy Policy explains the types of personal data we collect and process, how we may use and share the data, and the choices that are available to you with respect to our handling of your personal data.

Click on the links below to jump to the different sections of our Privacy Policy:

• Information We Collect

• Advertising and Analytics Services Provided by Others

• How We Use Your Information

• Who May Have Access to Your Information

• Your Rights And Choices

• Children

• Data Transfers 

• Nevada Residents

• California Privacy Rights

• Links to Other Websites and Third Party Content

• Data Retention

• Security

• Changes To Our Privacy Policy

• Contacting Figure 1

Information We Collect

Information we collect directly from you

We collect the information you provide directly to us, such as when you open an account, place an order, consult with an esthetician, ask to receive emails, contact customer service, or interact with us on social media. The types of personal data we may collect directly from you include:

• Contact information, such as your name, email address, mailing address, and phone number;

• Account information, such as your username and password;

• Billing information, such as credit card details and billing address;

• Optional information you may choose to provide, such as your social handles, skin issues, product preferences, age range, gender, such as when you consult with an aesthetician; 

• Employment-related information if we allow job applications to be submitted through our websites; and

• Any other information you choose to provide, such as product reviews, responses to surveys or consultations or to receive customer support.

Information about your use of our Services

We collect information about your use of the Services, such as the products you buy or express interest in.

Information we collect from other sources

We may collect information about you from other sources, including:

• Other users, such as through our refer-a-friend program or e-gift card offerings. If you choose to participate in our refer-a-friend program or purchase an e-gift card for someone else, we will collect information about your friend (such as a name and email address) in order to invite your friend to shop with us or send them their e-gift card.

• Third-party social media services. When you access the Services through a social network, we collect information about you from the social network in accordance with your settings on the social network. If you interact with us on social media, we will collect information about those interactions. The information we may collect includes your name and email address.

• Other unaffiliated third parties, such as advertising networks, media monitoring companies, and publicly available sources.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address or infer that you are looking to purchase certain products based on your browsing behavior and past purchases.

Information we collect by automated means

When you visit our websites, interact with our communications, or visit our online stores, or otherwise use our Services, we collect certain information automatically. To collect this information, we may use cookies, web beacons, and similar technologies. A “cookie” is a text file that websites send to a visitor‘s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as a pixel tag or clear GIF, is used to transmit information back to a web server. We may also collect information about your online activities over time and across third-party websites. The information we collect automatically may include:

• URLs that refer visitors to our websites;

• Search terms used to reach our websites;

• Details about the emails we send, such as opens, clicks, and unsubscribes;

• Details about the devices that are used to access our websites (such as IP address, browser information, device information, and operating system information);

• Details about your interaction with our websites (such as the date, time, length of stay, and specific pages accessed during your visits to our websites, referral activity, and which emails you may have opened);

• Usage information (such as the number and frequency of visitors to our websites).

We may associate this information with your Figure 1 account if you have one, the device you use to connect to our Services, or email or social media accounts that you use to engage with Figure 1 For more information about how we use cookies click here.

Advertising and Analytics Services Provided by Others

We may allow others to provide analytics services and serve advertisements on our behalf across the internet and in mobile applications. They may use cookies, web beacons, and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, device ID, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by Figure 1 and others to, among other things, analyze and track data, determine the popularity of content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for interest-based advertising purposes, please visit www.aboutads.info/choices.

We may also work with third parties to serve ads to you as part of a customized campaign on third-party platforms (such as Facebook or Google). As part of these ad campaigns, we or third-party platforms may convert information about you, such as your email address, into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and to serve you advertising that is customized to your interests. Note that the third-party platforms may offer you choices about whether you see these types of customized ads.

How We Use Your Information

We may use the information we collect to deliver the products and Services you request, to maintain and customize your account and our interactions with you (such as on our digital properties), to market and advertise our products and Services, and to provide, maintain, and improve our Services. We also use the information we collect to:

• Create and manage your online accounts and profiles;

• Communicate with you about our Services, including to tell you about products and services that may be of interest to you;

• Complete the transactions you request, perform our contractual obligations, and use as otherwise anticipated within the context of our ongoing business relationship;

• Respond to your requests, inquiries, comments, and suggestions;

• Facilitate your engagement with the Services, including to enable you to post comments and reviews, to engage with other customers, and to post on social media;

• Facilitate consultation with estheticians;

• Process job applications and other employment-related purposes; 

• Offer contests, sweepstakes, loyalty programs or other promotions;

• Personalize your online experience and the advertisements you see when you use the Services or third-party platforms based on your preferences, interests, purchasing history and browsing behavior;

• Monitor, audit and analyze trends, usage, and activities in connection with our Services;

• Carry out short-term activities and other internal uses related to the products or services you purchase from us or your ongoing relationship with us;

• Conduct internal research and development;

• Detect, investigate, and respond to security incidents and protect against illegal or objectionable activities, including the unauthorized use of the Services, and protect the rights and property of Figure 1 and others;

• Debug, identify and repair errors that impair existing intended functionality of our Services;

• Comply with our legal obligations, including those required for you to benefit from rights recognized by law, or any regulatory requirements or provisions; 

• Enforce our contracts and exercise and defend legal claims; and

• Conduct or administer surveys and other market research.

Who May Have Access to Your Information

Within Figure 1: We may disclose certain of your personal data to Figure 1 affiliates and personnel who need to know the information for the purposes described above, including personnel in the customer service and information technology departments.

Estheticians: Our Services may include the ability to consult an esthetician through our chat function, video or other communication means. During such consultation, any information you provide may be shared with the Esthetician for purposes of providing consultation regarding products.

Other Users: Our Services may include features that allow you to post comments, reviews and other information. When you provide a product review or post other user content, that content may be publicly posted. Other users may be able to see your name or other information about you that you post. We have no responsibility for how such other users use the information or content that you may post.

Third-Party Service Providers: We may use third party service providers acting on Figure 1’s behalf to perform some of the services described above. For example, and without limitation, we share certain information with service providers who assist with the processing of credit cards and payments, hosting, managing and servicing our data, distributing emails, conducting research and analysis, advertising, analytics, or administering certain services and features. We also may share information about you with our professional advisors, including accountants, auditors, lawyers, insurers and bankers, if needed. We require those service providers to comply with this Privacy Policy and applicable law with respect to any personal data they may process on our behalf.

Other Third Parties: In certain limited circumstances, we share and/or are obligated to share your personal data with other third parties, including (a) to comply with our obligations, to protect the rights and property of Figure 1, our customers and the public, to cooperate with law enforcement investigations, to respond to legal process (such as subpoenas, court orders and civil discovery) and to detect and respond to suspected illegal activity and threats to the health or safety or any person or of our systems or services; (b) in connection with, or during negotiations of, any merger, joint venture, sale of company assets, financing, or acquisition of all or a portion of our business, assets or stock by another company (including in connection with any bankruptcy or similar proceedings); and/or (c) with your consent and at your direction.

In certain instances, we may also share aggregated or de-identified information that cannot reasonably be used by those third parties to identify you.

Your Rights and Choices

Managing or deactivating your Figure 1 account

You may request to review, update, or modify your account information, including profile, contact, payment and shipping information, at any time by logging into your Figure 1 account. You may also deactivate your Figure 1 account or make requests about your personal data by emailing info@fig-1.co. We will endeavor to accommodate these requests within a reasonable period of time and as required by applicable law, provided that we may refuse requests if we need to retain information for business or legal purposes, if the request is excessive or unreasonably burdensome or if we have a legal basis for refusing the request. In addition, we may request information from you to verify your identity before responding to a request.

Opting out of email marketing

You may unsubscribe from our promotional emails at any time by following the instructions included in those emails. If you opt out of receiving such communications, note that we may continue to send you non-promotional emails (such as order confirmation emails or emails about changes to our legal terms).

Restricting cookies

Most web browsers are set to accept cookies by default. You can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our websites and Services.

Mobile Push Notifications/Alerts

With your consent, we may send you promotional and non-promotional mobile push notifications or alerts. You can deactivate these messages at any time by changing the notification settings on your browser.

Children

Our Services are not designed for children under the age of 13. If you have reason to believe that a child has provided personal data to us, please contact us.

Data Transfers

Figure 1 is headquartered in the United States and its Services are intended for use in the United States. If you access the Services from outside the United States, you agree to the transfer of your personal information to the United States, which may have less protections than your jurisdiction of residence. 

Nevada Residents

We do not sell your personal data as that term is defined under Nevada law.  However, if you are a Nevada resident and wish to opt-out of the sale of your personal data by email us at info@fig-1.co.

California Privacy Rights

Shine the Light

California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes or to opt out of such sharing. We do not share your personal data with third parties for their own direct marketing purposes.

Links to Other Websites and Third-Party Content

We may provide links to third-party websites, services, plug-ins and applications, such as Facebook and Google, that are not operated or controlled by Figure 1. This Privacy Policy does not apply to such third-party services, and we cannot take responsibility for the content, privacy policies, or practices of third-party services. We encourage you to review the privacy policies of any third-party services before providing any information to or through them.

The Services may offer social sharing features and other integrated tools (such as the Facebook "Like" or "Share" button or the Twitter “Tweet” button) which let you share actions you take on our Services with other media. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Data Retention

Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which the data was collected, and any other permissible, related purpose. We may retain some personal data to comply with our legal or regulatory obligations, as well as to allow us to manage our rights or for statistical or historical purposes. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired. When we no longer need to use your personal data, it is removed from our systems and records or anonymized so that you can no longer be identified from it.

Security

We are committed to keeping your personal data secure and taking all reasonable precautions to do so.  We contractually require that trusted third parties who handle your personal data for us do the same.  However, as the transmission of information via the internet is not completely secure, we cannot guarantee the security of your data transmitted to our websites. As such, any transmission is at your own risk.

Changes to Our Privacy Policy

We may change this Privacy Policy from time to time. If we do so, we will post the updated policy on our sites and will indicate when the Privacy Policy was last revised. If we make any material changes, we will provide you with additional notice. You should periodically review our current Privacy Policy to stay informed of our personal data practices.

Contacting Figure 1

If you have questions or concerns regarding this Privacy Policy, please contact us using the information provided below.

Figure 1 Beauty, Inc.

156 Fifth Avenue, Suite 612

New York, NY 10010

info@fig-1.co