PRIVACY POLICY

Privacy Policy

LAST UPDATED December 13, 2017

 

BESHIRVEHALEL, INC. (“We,” “Juvinesse,” “Company”) welcomes its users and respects their privacy. This Privacy Policy informs you of our policies and practices regarding the collection, use, access, storage and disclosure of any personal information you submit to us via our website at www.juvinesse.com (the “Site”) and the related Juvinesse mobile applications (the “Applications”).

 

1 – USER CONSENT

 

By submitting personal information to us, you agree to the terms of this Privacy Policy. In addition, for certain products or services, we may further confirm your consent by asking you to expressly consent to the collection, processing, storage and use of your personal information according to this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please refrain from using our products or accessing our services.

 

2 – JUVINESSE PRODUCTS AND SERVICES

 

Juvinesse sells the Juvinesse beauty device (the “Device”), syringe, facial peel, face lift and cleanser and other beauty products and supplies (the “Product(s)”) to end-user customers who purchase monthly memberships to receive the Products (“Membership(s)”) through retail stores (“Stores”), the Site and the Applications (collectively, the “Services”).

 

3 – A NOTE ABOUT CHILDREN

 

We do not intentionally gather Personal Data from visitors who are under the age of 13. If a child under 13 submits Personal Data to Juvinesse and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 13, please contact us at [email protected]

 

4 – A NOTE TO USERS OUTSIDE OF THE UNITED STATES

 

If you are a non-U.S. user of the Site, by visiting the Site or using our Services and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. By providing your data, you consent to such transfer.

 

5 – TYPES OF DATA WE COLLECT

“Personal Data” means (a) data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that cannot publicly be linked or associated with your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data as described below:

 

5.1 - Information You Provide to Us

 

  1. We may collect Personal Data from you, such as your first name, last name, e-mail, city, state, password when you create a membership account (“Membership”).

 

  1. If you tell us where you are (e.g., by allowing your mobile device to send us your location), we may provide you with location-based information and advertising. If you want to deactivate this feature, you can deactivate GPS on your mobile device or remove permissions for the Application(s) to have access to your location.

 

  1. Our Application(s) let you store your Application preferences. We may associate these choices with your Account or your mobile device(s), and you can edit these preferences at any time in our Application(s).

 

  1. When you order our Products or Services from our Site, we, or our payment processors, will collect all information necessary to complete the transaction, including your name, phone number, credit card information, billing information and shipping information. This information may be shared with third parties who help process and fulfill your purchases.

 

  1. If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, to send you a reply.

 

  1. When you post content (i.e., text, images, photographs, messages, reviews, ratings, tips, comments or any other kind of content), the information contained in your posting will be stored in our servers. If the information is posted in a public area of the Services, other users will be able to see it. The information that you provide in the content you post in public areas of our Site and Application(s), will be visible to others, including anonymous visitors to the Site and Application(s).

 

  1. When you post tips and comments within the Application(s) or on our Site the information contained in your posting will be stored on our servers, and other users will be able to see it.

 

  1. When you participate in one of our surveys, we may collect additional profile information.

 

  1. If you participate in a sweepstakes, contest or giveaway on our Site or in our Application(s), we may ask you for your e-mail address and/or phone number (to notify you if you win or not). We may also ask for first and last names, and sometimes mailing addresses to verify your identity. In some situations, we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules for each sweepstakes and contest that you enter.

 

  1. We may also collect Personal Data at other points in our Site or Application(s) that state that Personal Data is being collected.

 

5.2 - Information Collected via Technology

 

  1. Information Collected by Our Servers. To make our Site and Services more useful to you, our servers (which may be hosted by a third-party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.

 

  1. Information About Your Device. If you use our Services on your mobile device, including through our Application(s), we may collect your Device’s battery level, the version of iOS used by your mobile device, the serial number and firmware version of your Device, the signal strength of your mobile device, notifications regarding errors related to your mobile device and other relevant diagnostics.

 

  1. Log Files. As is true of most websites and applications, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to provide, modify, or enhance the Services; analyze trends; administer the Site; track users’ movements around the Site; gather demographic information about our user base as a whole; and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Site or the Services again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests. We may also link this automatically collected data to your Personal Data to identify and fix errors that you experience.

 

  1. Cookies. Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs.

 

  1. Pixel Tags. In addition, we may use “Pixel Tags” (also referred to as clear Gifs, web beacons, or web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in web pages. Pixel Tags also allow us to send e-mail messages in a format that users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ Personal Data.

 

  1. Collection of Data by Advertisers. Juvinesse does not sell any Personal Data to advertising platforms, data brokers, or information resellers. Certain third parties may automatically collect information about your visits to this and other websites, your IP address, your ISP, the browser you use to visit our Site (but not your name, address, e-mail address or telephone number). They do this by using Cookies, Pixel Tags or other technologies. Information collected may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of our Site and the other sites tracked by these third parties. This policy does not apply to, and we are not responsible for, Cookies or Pixel Tags in third party ads, and we encourage you to check the privacy policies of advertisers and/or ad services to learn about their use of Cookies and other technologies. If you would like more information about this practice and to know your choices about not having this information used by these companies, click here: http://www.aboutads.info/choices or http://www.networkadvertising.org.

 

  1. How We Respond to Do Not Track Signals. We do not currently respond to “do not track” signals or other mechanisms that might enable consumers to opt out of tracking on our Site.

 

  1. Mobile Services. We may also collect non-Personal Data from your mobile device if you have downloaded our Application(s). This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include how you use the Application(s) and information about the type of device you use. In addition, in the event our Application(s) crashes on your mobile device, we may receive information about your mobile device model software version and device carrier and associate such information with your Personal Data so that we can identify and fix bugs and otherwise improve the performance of our Application(s).

 

  1. Push Notifications. If you consent to receiving push notifications on your mobile device, we will send push notifications to your mobile device through services such as Apple’s Push Notification Service for iOS devices and Google’s CD2M and Cloud Messaging for Android devices. Both services are standard features of these mobile device operating systems. The privacy policy of the applicable service provider governs the access, use and disclosure of your Personal Data obtained from your use of these services.

 

  1. Analytics Services. We may use third party analytics services, including but not limited to Google Analytics (“Analytics Services”), to help analyze how users use our Site and Services. We use the information we get from Analytics Services only to improve our Site and Services. The information generated by the Cookies or other technologies about your use of our Site and Services (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity. The Analytics Services may also transfer the Analytics Information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Service’s ability to use and share Analytics Information is restricted by such Analytics Service’s Terms of Use and Privacy Policy. By using our Site and Services, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above.

 

  1. Information Collected from You About Others . If you decide to provide a third party with a Personal Link under the Program to sign up for a Membership (see Section 6 of Terms of Service), we will collect your and the third party’s names and e-mail addresses in order to send an e-mail and follow up with the third party. We rely upon you to obtain whatever consents form the third party that may be required by law to allow us to access and upload the third party’s name and e-mail address as required above. You or the third party may contact us at [email protected] to request the removal of this information from our database.

 

  1. Information You Provide to Social Networking Sites . In the future, the Services may allow users to access social networking services such as Facebook (each an “SNS”) to interact and share content with friends. If you are already logged into the Services and an SNS, when you click on “Connect with Facebook,” or a similar connection on another SNS, you will be prompted to merge your profiles. If you are already logged into the Services but not logged into Facebook or another SNS that we support, when you click on “Connect with Facebook,” or a similar connection on another SNS, you will be prompted to enter your SNS credentials or to “Sign Up” for the SNS. By proceeding, you are allowing the Services to access your information and you are agreeing to the SNS’s Terms of Use in your use of the Services. Conversely, if you are not currently registered as a user of the Services, and you click on “Sign in” using an SNS that we support, you will first be asked to enter your SNS credentials and then be given the option to register for the Services. In this case, we may receive information from the SNS to make it easier for you to sign up for a Membership on the Site and show relevant content from your SNS friends. Any information that we collect from your SNS account may depend on the privacy settings you have with that SNS, so please consult the SNS’s privacy and data practices. Any misuse of SNS services or use of excessive and unnecessary language on SNS services, may result in banning a Member, which means his or her Membership will be suspended.

 

6 – USE OF YOUR PERSONAL DATA

 

6.1 - General Use

 

In general, Personal Data you submit to us is used to respond to requests that you make, to aid us in serving you better, and to provide the Services to you. We use your Personal Data in the following ways:

 

  1. facilitate the creation of and secure your Membership on our network;

 

  1. identify you as a user in our system;

 

  1. provide improved administration of our Site, Application(s) and Services;

 

  1. provide the Services you request;

 

  1. improve the quality of experience when you interact with our Site, Application(s), and Services;

 

  1. track your purchases of our Products and the status of your Membership;

 

  1. send alerts, reminders, and other notifications to you;

 

  1. tailor our Products and Services to your interests;

 

  1. send you a welcome e-mail to verify ownership of the e-mail address provided when your Membership was created;

 

  1. send you administrative e-mail notifications, such as security, or support and maintenance advisories;

 

  1. respond to your inquiries related to employment opportunities or other requests;

 

  1. send newsletters, surveys, offers, and other promotional materials related to our Services and services made available by third parties and for other marketing purposes of Juvinesse.

 

6.2 - User Testimonials and Feedback

 

We often receive testimonials and comments from users who have had positive experiences with our Services. We occasionally publish such content. When we publish this content, we may identify our users by their first and last name and may also indicate their home city. We obtain the user’s consent prior to posting his or her name along with the testimonial. We may post user feedback on the Site from time to time. We will share your feedback with your first name and last initial only. If we choose to post your first and last name along with your feedback, we will obtain your consent prior to posting you name with your feedback. If you make any comments on a blog or forum associated with our Site, you should be aware that any Personal Data you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these blogs and forums.

 

6.3 - Creation of Anonymous Data

 

We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.

 

7 – DISCLOSURE OF YOUR PERSONAL DATA

 

We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy:

 

7.2 - Third Party Service Providers

 

We may share your Personal Data with third party service providers to: provide you with the Services that we offer you through our Site, including fulfilling orders, processing credit card payments, or other functions necessary for our business; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to Juvinesse. These third-party service providers are required not to use your Personal Data other than to provide the services requested by Juvinesse, and have appropriate contractual controls to bind such third parties.

 

7.3 - Affiliates

 

We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.

 

7.4 - Corporate Restructuring

 

We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us subject to these same commitments and will assume the rights and obligations regarding your previously collected Personal Data as described in this Privacy Policy.

 

7.5 - Social Networking Sites

 

Some of our Applications and Services may enable you to post content to SNSs. If you choose to do this, we will provide information to such SNSs in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review the terms of use and privacy policy of the third-party provider of such SNSs. We will not be responsible or liable for: (i) the availability or accuracy of such SNSs; (ii) the content, products or services on or availability of such SNSs; or (iii) your use of any such SNSs.

 

7.6 - Information You Make Public

 

Certain portions of the Services are open to any user, such as our community forums. Any information you post in these locations will be available and accessible to other users of the Services. In addition, the Services may contain features that permit you to upload, post, transmit, display, perform or distribute content, information or other data, including your Personal Data. Any information that you choose to disclose by means of such features becomes public information. You should exercise caution when deciding to disclose your Personal Data by means of such features, and you agree to assume all responsibility for doing so.

 

7.7 - Other Disclosures

 

Regardless of any choices you make regarding your Personal Data (as described below), Juvinesse may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation with a lawful government request, regulatory requirement, legal order, or similar obligation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Juvinesse; (c) to protect or defend the rights or property of Juvinesse or its users of the Site or Services; and/or (d) to investigate or assist in preventing any violation or potential violation the law, this Privacy Policy, or our Terms of Use.

 

7.8 - Information We Don’t Collect or Use.

 

Juvinesse does not collect any employment eligibility, promotion, or retention; credit eligibility; healthcare treatment eligibility; and insurance eligibility, underwriting, and pricing information via our Site.

 

8 – THIRD PARTY WEBSITES AND INFORMATION WE RECEIVE FROM PARTNER COMPANIES .

We may receive Personal Information about you from other sources like mobile device, tablet, internet services, public posts, third party websites or otherwise from companies that provide our services by way of a co-branded or private-labeled website (“Partner Companies”), and for some of our Services, this includes location based services applicable for certain features in the Services. If you choose to disable location based services some features of the Services may not work properly. We may add this information to the information we have already collected from you via our Website or Services in order to improve the products and services we provide.

 

When you access the Services via any other Partner Companies, another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.

 

9 – YOUR CHOICES REGARDING YOUR INFORMATION

 

You have several choices regarding use of information on our Services:

 

9.1 - Email Communications

 

We will periodically send you free newsletters and e-mails that directly promote the use of our Site or Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information above). Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms of Use or Privacy Policy.

 

9.2 - Cookies

 

If you decide at any time that you no longer wish to accept cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Consult your browser’s technical information. If you do not accept cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify cookies, please let us know at the contact information provided above.

 

9.3 - Location Information

 

If you do not want location information collected by us, you can disable location services on your mobile device.

 

9.4 - SNS Information

 

You may also manage the sharing of certain Personal Data with us when you connect with our Services through an SNS or de-link your SNS account from our Services. Please refer to the privacy settings of the SNS to determine how you may adjust your permission settings and manage the interactivity between the Services and your SNS account.

 

9.5 - Changing or Deleting Your Personal Data

 

You may change any of your Personal Data in your Account by sending an e-mail to [email protected] You may request deletion of your Personal Data by us, and we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud or similar purposes.

 

9.6 - Push Notifications

 

If you wish to stop receiving push notifications for any Application(s), you can use your mobile device’s standard process to turn off push notifications by changing the application settings on your mobile device.

 

9.7 - Applications

 

You can stop all collection of information by the Application(s) by uninstalling the Application(s). You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. Uninstalling the Application(s) will stop collection of any new information by the Application(s) but will not delete any prior Personal Data already collected by us (“Prior Personal Data“). If you wish to delete any Prior Personal Data, please contact us at [email protected] and we will delete such Personal Data in accordance with Section 9.5. If you reinstall any Application(s) at a later date, your Prior Personal Data will not be associated with any new information collected by such Application(s) until you login to your Account through such Application(s). If you login to your Account through such Application(s), to the extent your Prior Personal Data remains in our active database, your Prior Personal Data will be associated with any new Personal Data collected by such Application(s).

 

10 – CHANGES TO THIS PRIVACY POLICY

 

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy at www.juvinesse.com/privacy-policy and we will change the “Last Updated” date above. In addition, when a material change is made to the Privacy Policy, we will notify you via an Enhanced Notice as set forth below. You should consult this Privacy Policy regularly for any changes.

 

11 – ENHANCED NOTICE AND EXPRESS CONSENT

 

For new users, Juvinesse provides notice of this Privacy Policy before installing the Juvinesse mobile application, as part of the process of downloading the Juvinesse application to a device; at the time that the Juvinesse Site or Services are opened for the first time; at the time Personal Data is collected; or in the device or application settings that are presented to the user upon using the Site or Services for the first time; or in other ways to obtain express consent (in each case, an “Enhanced Notice”). For existing users, Enhanced Notice of any material change to these Privacy Policy terms will include thirty (30) days after Juvinesse provides notice on the Site; or if the modifications are material, thirty (30) days after Juvinesse provides an email update notice summarizing the changes we are making, and how the changes would affect you and your accounts on our Site or Applications, and the continued use of the Services thereafter, which shall constitute the acceptance of the changes.

 

Juvinesse provides Express Consent via a user’s statement or clear affirmative action in response to a clear, meaningful, and prominent notice regarding the collection, use, and sharing of Personal Data as set forth in this Privacy Policy. In addition to the above, express consent will be provided:

 

  1. Before Personal Data is used in any materially different manner than claimed in this Privacy Policy when the data was collected.

 

  1. To share Personal Data with third parties or to make Personal Data public.

 

  1. For secondary uses of Personal Data that are incompatible with the primary purpose of the app or service.

 

Express consent may be obtained through our device, app, Site or Services directly; or by a platform like Apple iTunes or other third party requesting on behalf of the device, app, Site or Services.

 

If Juvinesse were to share Personal Data with a third party, Express Consent would be obtained:

 

  1. At the point of sharing;

 

  1. As part of the download or installation flow, but before data is collected; or

 

  1. Via a separate process where the individual user provides the third party with express consent to access the data.

 

Express consent may be withdrawn by the user at any time, without affecting the previously collected and processed covered data.

 

12 – SECURITY

 

Juvinesse is committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized or unlawful access, use, or disclosure and against accidental loss or destruction of, or damage to, such Personal Data. Juvinesse has implemented industry-standard electronic means of protecting your Personal Data. We store Personal Data behind a computer firewall, a barrier designed to prevent outsiders from accessing our servers, and we have implemented technology to detect intrusions. We also require you to enter a password to access your account information. In addition, Juvinesse protects your Personal Data from unauthorized physical access by storing your Personal Data in a controlled facility.

 

Except as provided elsewhere in this Privacy Policy, Juvinesse limits access to Personal Data in electronic databases to those persons (including employees and contractors) in Juvinesse’s organization who have a business need for such access. Lastly, we conduct periodic internal audits and vulnerability scans to ensure compliance with these security measures and generate security incident logs that track Information useful in screening for attempted abuse of or unauthorized access to your Personal Data.

 

Even though Juvinesse has taken significant steps to ensure that your Personal Data is not intercepted, accessed, used, or disclosed by unauthorized persons, you should know that Juvinesse cannot fully eliminate security risks associated with Personal Data.

 

13 – ENFORCEMENT

 

Juvinesse remains committed to implementing internal processes and procedures reasonably designed to (1) address privacy risks related to the development and management of new and existing products and services for users, and (2) protect the privacy and confidentiality of Personal Data. If you have any questions or suggestions about the security or enforcement of your Personal Data, you can contact us at [email protected]

 

14 – QUESTIONS; CONTACTING JUVINESSE; REPORTING VIOLATIONS

 

If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at the following address or email:

 

Attention: Privacy Policy

BESHIRVEHALEL, INC.

24011 Ventura Boulevard, Suite 200

Calabasas, CA 91302
[email protected]

+1 (612) 281-7177