Privacy policy

BRG Aesthetics USA, Inc. ("BRG Skin", “we,” “us,” or “our”) is committed to keeping your personally identifiable information secure.  We will only use your personally identifiable information in accordance with this Privacy Policy and as you otherwise consent or direct us.  This Privacy Policy applies to our websites and platforms (collectively, the “Sites”) and our collection of information by telephone, email, text message, third parties, and your interactions with us (on our Sites, digital tools, and advertising).  It also explains how your personally identifiable information is collected, used, and disclosed by us and your rights as a consumer.

We reserve the right to update or modify this Privacy Policy at any time.  Please check back from time to time so you are aware of any changes or updates to the Privacy Policy.  This Privacy Policy is in effect as of April 1, 2020

This Privacy Policy does not cover information that you submit on third party websites, apps, and other social platforms (collectively, “Platforms”) even if we communicate with you on those sites. For example, if you post something on Facebook, Twitter or YouTube, that information is governed by the privacy policies on those Platforms.

Your use of any of our Sites signifies that you agree to the terms of this Privacy Policy. 

PERSONALLY IDENTIFIABLE INFORMATION COLLECTED

We collect personally identifiable information from the following sources: Information you provide to us (e.g., from your engagement with our Sites, advertising, and media); Information we collect automatically from you (e.g., from the use of cookies); and Information from third parties (e.g., from our service providers who help operate our Sites). Personally identifiable information relates to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual consumer or their respective household – including, but not limited to, your name, gender address, telephone number, e-mail address, IP addresses, order history, etc. We may combine information that we collect via one method (e.g., from our Site) with another method (e.g., an offline event). We do this to get a more complete view of our consumers’ preferences for our beauty products and services, which, in turn, allows us to serve you better with more customization and better beauty products.

The categories of personally identifiable information we may collect and have collected within the past 12 months from you include:  

  • Identifiers - Including without limitation your real name, account name, unique identifiers, email address, postal address, billing address, phone number, birthdate, credit card information, social media handle or moniker, or other similar identifiers.

  • Legally Protected Characteristics – Including without limitation, your age and gender.

  • Commercial Information - Including without limitation our products you purchased, obtained, considered, or returned and promotions, sweepstakes, contests, and other loyalty programs you participated in.

  • Internet or Other Electronic Network Activity Information – Including without limitation, browsing history, search history, click numbers, referring/exit pages, date/time stamps, information regarding your interaction with our Sites and advertisements, and your device information. See the Section below titled “USE OF COOKIES AND OTHER TECHNOLOGY” for more information.

  • Geolocation Information - Including without limitation information that can help identify your physical location like your GPS coordinates or the approximate location of your electronic devices. See the Section below titled “USE OF COOKIES AND OTHER TECHNOLOGY” for more information.

  • Audio and Visual Information – Including without limitation images or recordings of you if you attend one of our promotional and marketing offline events and any voice recordings that you voluntarily leave on voice mailboxes or that we may collect when you call customer services.

  • Inferences Drawn About Your Preferences – Including without limitation your beauty and related preferences and interests, characteristics, behaviors on and offline, purchase patterns, and other inferences drawn from other types of information we collect from you.  

  • Other Categories of Personal Data that Relates to or is Reasonably Capable of Being Associated with You - Including without limitation the messages and other content you send us (e.g., feedback and reviews of our products and services or questions and information you provide to our staff and customer services) and information we collect from you if you interact with us on other Platforms, such as Facebook, Instagram, Twitter, and other social media or interactive pages.

HOW INFORMATION IS USED 

We use personally identifiable information and non-personally identifiable information in a variety of ways, including without limitation to:

  • Operate and improve our Sites, customer service, or product and service offerings;

  • Send you messages (e.g., information about promotions and products offered by BRG Skin and our selected partners (only if you request the same), security alerts, and updates to our Privacy Policy);

  • Personalize and improve your experience on our Sites (e.g., your information helps us to better respond to your individual needs);

  • Respond to comments and questions and provide customer service (e.g., your information helps us to effectively respond to your customer service requests and support needs);

  • Send you newsletters (if you signed up for it) about products, promotions, and other information that we believe may interest you;

  • Operate and maintain our promotions, contests, sweepstakes, and games;

  • Provide tailored content, services, advertisements, and offers;

  • Administer and manage your account or loyalty program membership;

  • Verify your identity and prevent fraud;

  • Fulfill product purchases and BRG Skin Auto Replenishments;

  • Conduct research and analytics and create aggregated, pseudonymized, or anonymized information for statistical purposes;

  • Post your content and consumer reviews on the Sites, our social media pages, Platforms, and related third party sites that retail or feature our brand and products;

  • Enforce our Terms & Conditions, this Privacy Policy, and our other written policies and to comply with applicable laws;

  • Enable you to interact with third-party content service providers, whether by linking to their sites, viewing their content within our online environment, or by viewing our content within their online environment; and

  • Fulfilling any other business or commercial purposes at your direction or with your consent.

USE OF COOKIES AND OTHER TECHNOLOGIES

We collect certain aggregate and non-personally identifiable information when you visit our Sites. Aggregate and non-personally identifiable information does not relate to a single, identifiable visitor. It tells us how many users visited our Sites or the pages accessed. By collecting this information, we learn how to best tailor our Sites to our visitors. We collect this information through a “cookie” and other technologies, as explained below.

Cookies are very small text files, located on your computer’s hard drive.  We employ the use of cookies and use them in several ways which help track information about the users of our Sites.  Such information helps us better understand how you go through our Sites so that we may tailor your experience at our Sites.  Cookies are also used to tell us whether you have visited our Sites previously and to help us determine whether you came to our Sites from a particular Internet link or banner advertisement.  Cookies cannot and will not be used by us to retrieve any personally identifiable information about you from your electronic device that has not previously been voluntarily provided to us. If you have opted to allow BRG Skin to collect cookies, and later wish to opt out of that consent, you may make changes regarding cookie collection via changes to your web browser. For instructions on how to control cookies on your browser, visit www.aboutcookies.org. Opting out of the use of cookies by BRG Skin may affect the functionality of our Sites.

Our Sites may use Google Analytics, a web analytics service provided by Google, Inc. (“Google”).  Google Analytics uses cookies to help us to analyze how users use the Sites. If we use Google Analytics, the information provided and generated by the cookie about your use of our Sites (including your IP address) will be transmitted to and stored by Google Analytics.  Google Analytics will use this information for the purpose of evaluating your use of our Sites, gathering reports on our Sites’ activity for us, and providing other services relating to our Sites’ activity. Google Analytics may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google Analytics’ behalf.  Google Analytics will not associate your IP address with any other data kept by Google. You may reject cookies by selecting the appropriate settings on your browser. If you choose to do so, however, you may not be able to use certain areas and features/functions of our Sites. You can learn more about how Google Analytics processes information here: Google Analytics Terms of Use and Google Privacy Policy.

The use of cookies by our service providers, including without limitation Google Analytics, is not covered by this Privacy Policy. We do not have access or control over our service providers’ cookies; you can contact our service providers directly with questions or to opt out of collection. Our service providers may use session ID cookies to collect data in order to enable us to provide a better user experience on our Sites.

SHARING OF PERSONALLY IDENTIFIABLE INFORMATION

The categories of entities to whom we disclose and have shared information within the last 12 months, include:

  • Service Providers - BRG Skin shares information with entities that help us with maintaining and operating our Sites, payment processing, data analytics, marketing and advertising, and other business purposes. These companies may only use such information to perform those functions and may not use it for any other purpose, although we may permit them to use aggregate information which does not identify you or de-identified data for any purpose except as prohibited by applicable law.

  • Vendors - We may share information with vendors and other entities in connection with tailoring advertisements, measuring, and improving our Sites and advertising effectiveness, processing your specific requests, and enabling other enhancements to our products, services, and offline events. These companies may act as our service providers, or in certain contexts, independently decide how to process your information.

  • Promotional Partners - If you voluntarily enroll in our newsletters, we share information to help us provide and operate our e-newsletter offerings. This includes without limitation sharing your information with our service providers that maintain our e-newsletters, our third party partners (or their service providers) participating in our promotions, or other third parties for administrative purposes.

  • Third Parties in Connection with a Merger, Acquisition or Other Business Transaction - We may share information if BRG Skin is involved in a merger, acquisition, sale of all or a portion of its assets, financings, joint ventures, reorganization, dissolution, liquidation, or other event where we sell or transfer all or a portion of our business assets or equity. We will not provide you with notice before disclosure in such cases. 

  • Third Parties for Security and Compelled Disclosure Purposes - BRG Skin must disclose information about you in response to lawful requests by public authorities, including but not limited to meet national security or law enforcement requirements. We may share information about you in connection with legal requirements, such as in response to an authorized subpoena or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, or investigate fraud. Such disclosures may be carried out without notice to you.

  • Third Parties that You Direct Us to Share With - We share information at your request or direction, such as when you purchase a gift card and direct us to send it to a certain recipient. We may also share your information with notice and as required by applicable law, with your consent.

We do not sell, trade, or otherwise share your personally identifiable information to outside parties, except with those parties identified in this Privacy Policy, so long as those parties agree to keep such information confidential.  

THIRD PARTY LINKS

Our Sites contain links to several third party websites not owned or controlled by BRG Skin and this Privacy Policy does not apply to such websites or the use of any data by such websites. Should you decide to navigate to any websites or webpages external to our Sites, you do so entirely at your own risk.  We are not responsible for the actions, privacy, security, or content of such third party websites. If you are asked to provide information on one of these websites, we encourage you to carefully review their privacy policy before sharing your information. Nevertheless, we value and seek to protect the integrity of our Sites and welcome any feedback about third party links.

We may use third party companies to serve advertisements, measure the performance and engagement with our ads, provide analytic, preference, and interest information. In some instances, these ad network providers, social platforms, sponsors, and/or analytics service providers may use their own tracking technology to capture information about your device, use and engagement online.

We may recognize your information across different devices that you use or log in from (e.g., computers or mobile devices).  We may recognize that one cookie ID (e.g., from a computer) may be connected to another device (e.g., smart phone) by the device ID or log in. This may result in you searching for one of our products on one device but seeing an advertisement later for that product on another device. By knowing what devices are being used by a person or household helps us limit the number of times you may see the same advertisement across different devices.

You can specify your preferences over the use of some of these technologies by changing your preferences regarding cookie collection via changes to your web browser.  Additionally, you can manage third party advertising preferences for some of the third parties we work with that serve advertising across the internet by using the choices available at www.networkadvertising.org/managing/opt_out.asp and www.aboutads.info/choices. We do not guarantee that all of the third parties we work with will honor the elections you make using those options, but we strive to work with third parties that do.  Some Platforms (i.e., Facebook) allow you to exercise ad choices, limit data collection and clear your history on that Platform as well.

CHILDREN’S GUIDELINES

Our Sites are intended for general audiences and is not directed to children under 13. We do not knowingly collect personally identifiable information from children under 13. If you become aware that a child has provided us with personally identifiable information without parental consent, please contact us at customerservice@brgskin.com.  If we become aware that a child under 13 has provided us with personally identifiable information without parental consent, we will take reasonable steps to remove such information and terminate the child’s account.  

HOW WE PROTECT YOUR PERSONALLY IDENTIFIABLE INFORMATION

BRG Skin implements reasonable practices to protect your personally identifiable information from unauthorized access, use, disclosure, or destruction. No data transmission or electronic storage is infallible. Therefore, BRG Skin cannot guarantee or warrant the security of the personally identifiable information that you transmit to BRG Skin.

WHAT CHOICES DO YOU HAVE OVER HOW YOUR INFORMATION IS USED? 

In this section, we describe the rights and choices available to all users.

  • Access or Update Your Account Information - If you registered for an account with us, you may review and update certain personally identifiable information in your account profile by logging into your account and editing your Account and Billing information.

  • Opt Out of Marketing Communications - You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions located at the bottom of the email.  You may continue to receive service-related and other non-marketing emails (e.g., emails confirming your online orders). If you receive marketing text messages from us, you may opt out of receiving further marketing text messages from us by replying STOP to our marketing message.

  • Cookies - Most browsers let you remove and/or stop accepting cookies from the websites you visit.  To do this, follow the instructions in your browser’s settings. 

  • Do-Not-Track - Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

  • Privacy Settings and Location Data - Users of our Sites can disable our access to their device’s precise geolocation in their electronic device settings.

  • Choosing Not to Share Your Personally Identifiable Information - We do not require you to register or provide personally identifying information to view our Sites or access much of its content. However, there are certain instances where we need your information to provide you with certain services or provide you access to certain features of our Sites (e.g., to process your online orders). In addition, if you terminate your account or membership to our newsletters, Program (defined below), or other incentive programs, or if you choose not to join, you may not be able to benefit from the discounts, free sample, gifts, or free shipping offered to customers who sign up for such programs.

YOUR CALIFORNIA PRIVACY RIGHTS

Under the California “Shine The Light” law, California residents may opt-out of our disclosure of personally identifiable information to third parties for their direct marketing purposes. As detailed above, you may choose to opt-out of the sharing of your personally identifiable information with third parties for marketing purposes at any time by changing your cookie settings on your web browsers.  It is important to note that this opt-out does not prohibit disclosures made for non-marketing purposes.

Under the California Consumer Protection Act of 2018 (“CCPA”), California consumers have certain rights regarding the collection and use of their personally identifiable information by BRG Skin.  Since the implementing regulations of the CCPA are not yet final and there remain differing interpretations of the law, we may from time-to-time update information in this and other notices regarding our data practices and California consumers’ rights, modify our methods for responding to California consumers’ requests, and/or supplement our response to California consumers’ requests, as we continue to develop our compliance program to reflect the evolution of the CCPA and our understanding of how it relates to our data practices.

For more information regarding the information described below, please see the following Sections:

  • The categories of personally identifiable information BRG Skin collects from consumers in the preceding 12 months (each a “Category of PI”) - See “PERSONALLY IDENTIFIABLE INFORMATION COLLECTED”

  • The categories of sources from which each Category of PI may be collected from. - See “PERSONALLY IDENTIFIABLE INFORMATION COLLECTED”

  • The business or commercial purposes for which each Category of PI may be collected for. - See “HOW INFORMATION IS USED”

  • The categories of third parties with whom BRG Skin may share each Category of PI. - See “SHARING OF PERSONALLY IDENTIFIABLE INFORMATION”

California consumers have the right to request to know what personally identifiable information has been collected, used and disclosed about them within the past 12 months of the date of their verified request, and to access that information. California consumers may also request deletion of their personal information, though exceptions under the CCPA may allow BRG Skin to retain and use certain personally identifiable information notwithstanding their deletion request.  

We will not discriminate against you for exercising your rights under the CCPA.  However, if you choose not to provide us with certain information, you may not be eligible to receive certain promotions and offers for our products and services (e.g., if you do not sign up for our newsletters or Program, you may not benefit from receiving notifications of discounts, free samples, gifts, or free shipping to customers that may be exclusively offered to our subscribers).   

BRG Skin does not “sell” your personally identifiable information as defined under the CCPA.  It will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law.

If you are a California consumer, you may exercise any of your rights described in this section by contacting us via the methods listed under “HOW TO CONTACT US” below.

We will take reasonable steps to verify your identity before responding to a request, which may  require you to provide (a) three specific pieces of data we have on file for you (e.g., your name, email address and billing address) and (b) a statement that you “declare under penalty of perjury that you are the person about whom the Right to Know/Delete request has been made.”

You are also permitted to designate an authorized agent to submit certain requests on your behalf. For an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity according to the above method before processing the authorized agent’s request.

If we cannot successfully verify you according to the above methods, then we will not be able to comply with your request.

Mobile Terms of Service

The BRG Aesthetics , Inc. mobile message service (the "Service") is operated by BRG Aesthetics USA, Inc. (“BRG Skin”, “we”, or “us”). Your use of the Service constitutes your agreement to these terms and conditions (“Mobile Terms”). We may modify or cancel the Service or any of its features without notice. To the extent permitted by applicable law, we may also modify these Mobile Terms at any time and your continued use of the Service following the effective date of any such changes shall constitute your acceptance of such changes.

By consenting to BRG Skin SMS/text messaging service, you agree to receive recurring SMS/text messages from and on behalf of BRG Skin through your wireless provider to the mobile number you provided, even if your mobile number is registered on any state or federal Do Not Call list. Text messages may be sent using an automatic telephone dialing system or other technology. Service-related messages may include updates, alerts, and information (e.g., order updates, account alerts, etc.). Promotional messages may include promotions, specials, and other marketing offers (e.g., cart reminders).

You understand that you do not have to sign up for this program in order to make any purchases, and your consent is not a condition of any purchase with BRG Skin. Your participation in this program is completely voluntary.

We do not charge for the Service, but you are responsible for all charges and fees associated with text messaging imposed by your wireless provider. Message frequency varies. Message and data rates may apply. Check your mobile plan and contact your wireless provider for details. You are solely responsible for all charges related to SMS/text messages, including charges from your wireless provider.

You may opt-out of the Service at any time. Text the single keyword command STOP to +18337432367 or click the unsubscribe link (where available) in any text message to cancel. You'll receive a one-time opt-out confirmation text message. No further messages will be sent to your mobile device, unless initiated by you. If you have subscribed to other BRG Skin mobile message programs and wish to cancel, except where applicable law requires otherwise, you will need to opt out separately from those programs by following the instructions provided in their respective mobile terms.

We may change any short code or telephone number we use to operate the Service at any time and will notify you of these changes. You acknowledge that any messages, including any STOP or HELP requests, you send to a short code or telephone number we have changed may not be received and we will not be responsible for honoring requests made in such messages.

The wireless carriers supported by the Service are not liable for delayed or undelivered messages. You agree to provide us with a valid mobile number. If you get a new mobile number, you will need to sign up for the program with your new number.

To the extent permitted by applicable law, you agree that we will not be liable for failed, delayed, or misdirected delivery of any information sent through the Service, any errors in such information, and/or any action you may or may not take in reliance on the information or Service.