1. How do we use your personal information?

Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No.

Self Esteem respects your right to privacy, and maintaining your privacy is very important to us. We do not store credit card details. All transactions are processed via our portal and are fully secure. When you visit Self Esteem or any pages or sub-pages related to our site, we collect information sent to us by your computer, tablet or mobile phone. The information sent to us includes your computer’s IP address, device identifiers, the operating system you’re using, your location, standard web logs or any other information available through web data. We also collect information related to our service, like contact information you submitted on our website such as your name, email, home address, phone number and other similar information.

We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:

• Communicate with you;

• Screen our orders for potential risk or fraud;

• When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

2. Personal information we collect

Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We may use your personal information to:

• Process your order on Self Esteem;

• Send you notifications about your transaction or shipment;

• Improve our customer support;

• Customize, measure, and improve our services;

• Design our website in consequence of the way visitors use it;

• Deliver target marketing, service update notices, and promotional offers based on your communication;

• Complete security checks related to the use of our services;

• Contact you by email or by the method selected in your preferences;

When you visit the Site, we collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.

We collect Device Information using the following technologies:

• “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

•“Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

• “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.

Additionally, when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers and debit card numbers), email address, and phone number. We refer to this information as “Order Information”.

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.

3. Do not track

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

4. Sharing your data with others

We may disclose your personal data to any member of our group of companies (including our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this notice. Such may include internal administration purposes as well as provision/sharing of IT, payment or marketing services or data centres in the group.

We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

We may disclose your personal data to our anti-fraud, risks and compliance providers insofar as reasonably necessary for the purposes of protecting your personal data and fulfilling our legal obligations.

We may disclose your personal data to our payment service providers. We will share service data with our payment services providers only to the extent necessary for the purposes of processing your payments, transferring funds and dealing with complaints and queries relating to such payments and transfers.

We may disclose your personal data to other service providers insofar as it is reasonably necessary to provide specific services (including, providers of servers and maintenance thereof, email service providers, service providers used for data analysis or marketing, call centres, customer satisfaction surveys or market research). We take all the necessary measures to ensure that such subcontractors would implement proper organisational and technical measures to ensure security and privacy of your personal data.

In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Persons, indicated in this Section may be established outside the European Union and European Economic Area. In case we will transfer your personal data to such persons, we will take all the necessary and in the legal acts indicated measures to ensure that your privacy will remain properly secured, including where appropriate, signing standard contractual clauses for transfer of data. To find out more information regarding appropriate safeguards you may contact us via email: [email protected]

5. How long do we store you data?

Your personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. In any case it shall be kept for no longer than:

• account data will be retained for no longer than 5 (five) years following your last update on the account;

• service data will be retained for no longer than 5 (five) years following the end of provision of services;

• messaging data will be retained for no longer than 2 (two) years following the provision of consent or, in case, the messaging data is being sent to the present clients in order to maintain and improve customer relations, for no longer than 2 (two) years following the end of provision of the respective services, unless you respectively withdraw your consent earlier or object to such processing;

• correspondence data will be retained for no longer than 6 (six) months following the end of such communication.

In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. I. e. device data will be retained for as much as will be necessary for the relevant processing purposes.

Not withstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Behavioural advertising

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by using the links below:

• Facebook: https://www.facebook.com/settings/?tab=ads

• Google: https://www.google.com/settings/ads/anonymous

• Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

7. Your rights

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

8. Changes

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

9. Minors

The Site is not intended for individuals under the age of 18.

10. Contact us

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at [email protected] or by mail using the details provided below:

Self Esteem, Privacy Compliance Officer, 1700 Van Ness Ave San Francisco, CA 94109