PRIVACY POLICY

This Privacy Policy is effective as of June 17, 2024.   

You linked to this Privacy Policy (“Privacy Policy”) via a product website owned by G2G Newco, Inc. (“Company”, “us”, “our” or “we”). By using this Website, you signify that you have read, understand and agree to be bound by this Privacy Policy.

This Privacy Policy applies to all online communication with the Website but does not apply to our data collection activities offline unless we otherwise indicate at the time of collection or in Section 12 of this Privacy Policy. It is important for you to understand what information we collect about you during your visit to our Website and what we do with that information. Please note that your visit to our Website is subject to this Privacy Policy. By using our Website, you consent and agree to our Privacy Policy and Terms and Conditions ofUse and our collection, use and sharing of your information and data, and other activities, as described below. If you do not
agree to the terms of this Privacy Policy, please do not provide us with any personal information and do not use our Website.

1. Information Collection

We collect personally identifiable information about you via our Website when you provide it through various forms and places on the Website such as in connection with a request or purchase of a product, service, or information or if you register for a Website account. If, for example, you decide to place an order, we will ask you for your name, delivery and billing address, phone number(s), email address, and payment information such as credit/debit card number, expiration dates, or third party payment information. If you choose to
complete a user registration form or survey, we may ask you for personal information, such as your contact information (e.g., name, e-mail address and mailing address). Occasionally, we may also ask you for other demographic information,
such as gender, income level, and information about your prior experiences with the Company’s products. If we combine demographic information with the personal information, we collect directly from you on our Website, we will treat the combined data as personal information under this Privacy Policy. When you submit your personally identifiable or demographic information on our Website, you are giving your consent to the collection, use and disclosure of your information as set forth in this Privacy Policy.

We may receive information about you from your friends and others that use the Website, such as when they submit your information to us about you. Additionally, we may, from time to time, supplement the information we collect directly from you on our Website with outside records from third parties for
various purposes, including to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you. For example, if you choose to have your purchase delivered to another person’s
address, we may ask for the other person’s name and delivery address. We will use this information to deliver your purchase to the address you choose to have
it delivered. You may delete the other person’s information from your account or the other person may contact us at privacy@beautycounter.com to
request that we remove their information from our database. Note: Although you can remove the information from your account for future orders, the other person’s information may be retained with the original transaction for auditing
and legal purposes. In no other circumstances do our statements under this Privacy Policy apply to information we receive about you from third parties.

We may also use the tracking technologies described in Section 5 below in order to automatically (or passively) collect, store or accumulate certain non-personally identifiable information concerning your use of this Website, such as information regarding which of our pages are most popular and remembering you and your preferences, your IP address, UDID or other unique identifier, device functionality (including browser, operator system, hardware, mobile network information), device location, device characteristics, city, time zone, and referring URL. Information gathered may be used in aggregate form for internal business purposes, such as generating statistics, developing
marketing plans, customizing content, and improving the Website. This usage information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device whenever you visit or interact with our Site. We may share or transfer such aggregate, non-personally identifiable information with or to our affiliates, licensees, partners and other third parties.

We may combine automatically collected Website usage information with your Personal Information. In those cases, we will apply this Privacy Policy to the
combined information.

Our Website is intended for a general audience. We do not knowingly collect personal information from children under the age of 18. We will delete any
personal information collected that we later determine to be from a user
younger than the age of 18.

2. Use/Disclosure of Personal Information

The Company and its affiliates may use your information as follows:

to place an order made through the Website and fulfill your order request;

to notify you of product recalls or providing other information concerning products you have purchased;

to improve merchandise selections and the overall shopping experience at the Website;

to improve the Website, marketing endeavors or our Website offerings;

to provide customer support;

to contact you with regard to your use of the Website and, in our discretion, changes to the Website and/or Website’s policies;

to improve the overall experience at the Website;

for internal business purposes; and

for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

If for any reason you would no longer like to receive email marketing messages from the Company, you may follow the instructions contained within our
promotional emails or at checkout on the Website.  Please allow up to ten (10) days for us to process your request. If your opt-out is limited to certain types or categories
of emails the opt-out will be so limited. Please note, if you opt not to receive marketing emails from the Company, you may still receive
“transactional” email messages regarding your account, use of the Websites or your order (e.g., order confirmation, shipping information, recall notices, customer service notifications, etc.).

The Company may share non-personal information, such as aggregated user statistics, with third parties. The Company may also share and sell your information, such as your name, email address, mailing address and/or telephone number to business partners, vendors and other third party organizations to provide you
with information about products, services and special offers we think may interest you or to improve our products, services and advertising. If you are a California resident, you have the right to request additional information about this sharing, so please see Section 12 below. In addition, we may share the information we have collected about you, including personal information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy.

We may contract with companies or individuals to provide certain services including email and hosting services, credit card processing, shipping, data management, surveys and marketing, promotional services, to assist in preventing or deterring fraud, etc. We call them our “Service Providers”. We may share personally identifiable information with Service Providers solely as appropriate for them to perform their functions, but they may not use such information for any other purpose.

We do not share your credit card information with unaffiliated third parties unless you authorize us to do so, or if it is necessary to fulfill our responsibilities, including, but not limited to, delivering a product or service that you order.

Some of our pages utilize framing techniques to serve content to/from our partners while preserving the look and feel of our Website. Please be aware that you are providing your personal information to these third parties and not to Company.

The Company may, in its sole discretion, disclose personal information in special cases: (1) when we have reason to believe that disclosing this information is
necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) the rights of the Company or to anyone that could be harmed by such activities; (2) when we believe in good faith that the law requires it;
(3) to a subsequent owner, co-owner or operator of a Website or applicable database or in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process; and (4) in situations involving threats to the physical safety of any person.

3. Information Security

We use Secure Sockets Layer (SSL), an advanced security protocol that protects your credit card information and ensures secure online ordering. SSL Internet
connections are encrypted, and thus protect all credit card ordering
information, including your name, address and credit card number, so it cannot be read in transit. We use secure technology, privacy protection controls, and
restrictions on employee access, to safeguard your personal information. Please note, however, that although we employ industry-standard security measures to
safeguard the security of your personal information, no transmissions made on
or through the Internet are guaranteed to be secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our
Website and provide us with your information at your own risk.

4. Access and Choice

If your personal information changes, or if you no longer desire our service, you may correct, update, amend, delete/remove, or deactivate it by making the change on our member information page or by emailing our Customer Support privacy@beautycounter.com or
postal mail at the contact information listed below. We will respond to your request within a reasonable timeframe.

5. Technology Utilized / Tracking Technologies

We and our marketing partners, affiliates, or analytics or service providers, use technologies such as cookies, beacons, tags, browser fingerprinting, recognition technologies and scripts, to analyze trends, administer the Website, tracking users’ movements around the Websites, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and
aggregated basis. This information may be combined with information collected from other third-party sources of information not collected during your visit to our website, which may include your name and mailing address, for purpose of
determining whether you may be interested in receiving direct mail.

Our Website utilizes tracking technologies to collect and record your activities and movements across our websites throughout your browsing session, including
to track clicks/touches, mouse movements, scrolling, keystrokes, data entered, device information and orientation, and screen size (“session data”), for purposes of our own internal analytics and improving our products, services,
and user experience. We may share session data with our third party analytics or service providers for these purposes, who will use the session data solely on our behalf and for our benefit. Please review how you consent to the collection, use, and sharing of session data in Terms and Conditions of Use.

There may be other tracking technologies now and later devised and used by us in connection with the Website. Further, third parties may use tracking technologies in connection with our Website, which may include the collection and storing of information about your online activities over time and across third-party websites or online services.

We and third-party vendors, including Google and Facebook, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as a DoubleClick cookie), device fingerprinting, web beacons, and other storage technologies together to collect or receive information to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our Website and elsewhere on the Internet. Google’s use of the DoubleClick cookie enables it and its partners to serve ads based on your visit to our Website and/or other sites and
online services.

6. Do Not Track Signals

Some web browsers are developing or offering signals or other mechanisms for the expression of consumer choice regarding the collection of information about an
individual consumer’s online activities over time and across third-party web sites or online services (e.g., a “Do Not Track” (“DNT”) signal). A DNT signal
is a HTTP header field indicating your preference regarding tracking or cross-site user tracking. We do not monitor or take any action with respect to DNT signals.

8. External Links

Our Website may offer links to and from other third party sites. Other sites have their own policies regarding privacy. If you visit one of these sites, you may want to review the privacy policy on that site. For example, you may have linked to the Company’s brand site through a banner advertisement on another
site. In such cases the site you have linked from may collect information from people who click on the banner or link. You may want to refer to the privacy policies on those sites to see how they collect and use this information.

 

11. International Users

Our Website is operated in the United States and intended for users located in the United States. Like almost every website, our Website can be accessed by an
international audience. If you are located outside of the United States, please be aware that information we collect, including personal information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your personal information may be subject to access requests from governments, courts, or law enforcement in the United States
according to laws of the United States. In addition, such data may be stored on servers located outside your resident jurisdiction and in jurisdictions which may have less stringent privacy practices than your own. By using the Website
or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including personal
information, in the United States as set forth in this Privacy Policy.

12. Your California Privacy Rights

This Section 12 applies to any California residents about whom we collect personal information from any source, including through the use of the Websites, by buying our products or services, or by communicating with us electronically, in paper correspondence, or in person (collectively, “you”).

For purposes of this section, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer/resident or household. Personal information does not include publicly available information; lawfully obtained, truthful information that is a matter of public concern; information that has been de-identified, or aggregate consumer information.

For purposes of this section, “publicly available information” includes: information that is made available from federal, state, or local government records; information that a business has a reasonable basis to believe is lawfully available to the general public either through widely distributed media or by the consumer; and information that is made available by a person to
whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience.

A. What Information We Collect

We may collect the following personal information from or about you:

Identifiers, which includes real name; alias; postal address; online identifiers as detailed below; Internet Protocol (“IP”) address; email address; account name; telephone number; account number, and/or other similar identifiers; Characteristics of protected classifications under California or federal law, including but not limited to racial or ethnic origin; gender; race and ethnicity; nationality; marital status; military service/veteran status; and/or date of birth; Personal information as described in California Civil Code Section 1798.80(e); Commercial information; order and confirmation numbers; account balances, payment history, or account activity; shipping information; bank account information and other information relating to your financial institution; and/or other purchasing or consumer histories or tendencies; Information relating to Internet activity or other electronic network activity, which includes cookie identifiers, pixel tags, clear gifs (a.k.a. web beacons/web bugs), browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, device platform, device version, browsing history, search history, and/or other device characteristics including preferred language and your choice of settings such as Wi-Fi, Bluetooth, and Global Positioning System (“GPS”), as well as your session data as defined in Section 5 above; Geolocation data, which includes Global Positioning System (“GPS”) data; locational information based upon your IP address; cell network data; and/or other similar locational data; and which may be collected from various devices; Audio or electronic information, which includes records of calls to or from our customer service center; Certain of the information described above constitutes “sensitive personal information” as defined under California law, including: Financial account, and debit or credit card information; Precise geolocation; Certain information concerning a consumer’s health.

 

B. What We Do With Your Information

We may collect or use personal information from you for the following purposes:

• Internal analytics
• Assessing third party
  vendors / service providers
• Audit, compliance,
  policy, procedures, or regulation
• Billing, payment, and
  fulfillment
• Customer claims and
  fraud investigation and prevention
• Customer
  communications
• Customer relationship
  management
• General business
  administration
• Marketing our
  products and services
• Marketing the
  products and services of others
• Financial reporting
  and accounting
• Website optimization
  and maintenance
• Systems and data
  security
• Protecting the safety
  of our employees and others

To the extent we collect sensitive personal information as identified in Section 1.A above, it may be used for all of the above-listed purposes.

C. Sources of Collected Information

We may collect personal information from the following categories of sources:

• Our customers, prospective customers, users, members, and applicants, including, as applicable, via our websites, mobile applications, telephone, text message, postal mail, social media, forums, message boards, chatbot, or other means;
• Our service providers, which includes customer relationship management providers, analytics providers, website hosting providers, systems administrators, and communications delivery services;
• Nonaffiliated companies with which we have a business relationship and promotional and joint marketing partners;
• Other third parties, and other websites and mobile applications, online advertising partners, and other data suppliers;
• Things that other third parties may post publicly about you or otherwise provide to us; and
• Employees and job applicants.

 

D. Who We Disclose Information To

We provide personal information to third party service providers receiving information to perform services for us on our behalf.

We may “sell” or “share” certain personal information with third party partners as part of targeted advertising initiatives. These disclosures constitute “selling” and/or “sharing” under California law, even though we do not receive
monetary payment for sharing or disclosing personal information to these third parties.

Pursuant to California requirements regarding data sharing, we have provided you with opt-out rights as to that activity as described in Sections G and H below.

The only category of third parties with whom we may share your personal information is advertising and marketing companies for the limited purpose of providing you
with tailored digital advertising. The only categories of personal information that we may share with these third parties are identifiers, commercial information, and information relating to Internet activity or other electronic network activity, as further detailed in Section A above.

We will not collect additional personal information from you or use your personal information for additional purposes that are incompatible with our original
purpose for collection without providing you with notice.

E. How Long We Keep Your Information For

We retain your personal information, including sensitive personal information, for as long as reasonably necessary to provide you with the products or services
you have requested from us, as may be required by law, as may be required to achieve any of the other purposes listed in Section B above, or until such time that you exercise your privacy rights, as further detailed in Section F below.

F. Your Privacy Rights

If you are a California resident, subject to applicable law, you have the following rights under California law with respect to your personal
information:

• Right to Know. You have the right to request what personal information we collect, use, share, disclose and/or sell and to whom as applicable.
• Right to Delete. You have the right to request the deletion of your personal information that is collected and maintained by us.
• Right to Opt-Out of Sale. You have the right to opt-out of the sale of your personal information by us. Please see our Notice of Right to Opt-Out below for more information.
• Right to Opt-Out of Sharing. You have the right to opt-out of the sharing of your personal information by us with a third party for cross-context behavioral advertising purposes. Please see our Notice of Right to Opt-Out below for more information.
• Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above.
• Right to Limit Use and Disclosure. You have the right to limit the use or disclosure of your sensitive personal information to only the uses necessary for us to provide goods or services to you or that
  you otherwise reasonably expect. However, to the extent we collect sensitive personal information, we do not use it for such secondary purposes.
• Right to Correct. You have the right to request the correction of any of your personal information that you believe to be inaccurate.

You may also authorize a third party to exercise the above rights on your behalf by: (1) Providing written permission for the authorized third party to submit a request; or (2) providing a validly executed Power of Attorney to the authorized agent when such authorized agent submits a request. If we have collected information on your minor child, you may exercise the above rights on behalf of your minor child.

The above rights are subject to our being able to reasonably verify your identityand authority to make these requests. These rights are also subject to various exclusions and exceptions under applicable laws.

We will verify your identity by using data you provide. We require that you provide your full name, email address, and confirmation that you are a resident of the state in question. You may also be asked to provide your phone number
and address to further verify your request. These data elements will be compared against our records for verification.

If you are a California resident and wish to seek to exercise these rights, please reach us by email: privacy@beautycounter.com

Formore information regarding this Privacy Policy, or if you have any questions or concerns, you may contact us in the following ways:

• By email: privacy@beautycounter.com
• By mail: G2G Newco, Inc. General Counsel, 1745 Berkeley Street, Suite 2, Santa Monica, CA 90404, Attn: California Privacy Rights

 

G. Notice of Right to Opt-Out

We may “sell” or “share” share certain personal information with third party partners as part of targeted advertising initiatives. That sharing may constitute “selling” and/or “sharing” under California law, even though we do not receive monetary payment for sharing or disclosing personal information to
these third parties. We do not otherwise “sell” personal information as defined under California law.

If you wish to opt-out of our sharing of the limited data that is gathered when you visit our Websites and other web-based services for purposes of cross-context behavioral advertising, you may do so by emailing privacy@beautycounter.com

14. Notification of Changes

We may revise this Privacy Policy from time to time. If we decide to change our Privacy Policy, we will post the revised policy here. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Website prior to the change
becoming effective. As we may make changes at any time without notifying you, we suggest that you periodically consult this Privacy Policy. Your continued use of the Website after the changes are posted constitutes your agreement to the changes, both with regard to information we have previously collected from you and with regard to information we collect from you in the future. If you do not agree to the changes, please discontinue your use of our Website.

15. Contact Information

If you have any questions about the Privacy Policy or practices described in it, you should contact us in the following ways:

G2G
Newco, Inc.

General Counsel

1745 Berkely Street, Suite 2Santa Monica, CA 90404

Attn: California Privacy Rights

Email: privacy@beautycounter.com