Information We Collect
We at New Frontier Bio, Inc. collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). We do this to see a more complete picture of preferences for our products and services. Information from your engagement with our Sites, advertising, media, and third parties who share with us is collected. These are examples of categories of personal information from consumers we collect:
Legally Protected Characteristics
Internet or other similar network activity.
Professional or employment-related information.
Audio Visual Information
Inferences drawn from other personal information.
Other Information Considered Personal Information
(Some items addressed in other categories as well)
Information Automatically Collected
Some data is automatically collected when you use our Sites. Information may be obtained through cookies, pixels, web server logs, web beacons, and other technologies.
Types of cookies:
- Essential Cookies: These cookies (or similar technologies) are essential for the website to function, manage the security of the website (including to detect and prevent fraudulent activity), or provide access to features and functionality on the website. They are usually set in response to actions requesting services, such as setting your privacy preferences, logging in, or filling in forms. They also enable enhanced website functionality and personalization. These cookies (or similar technologies) are essential for the website to function, provide access to features and functionality on the website, and cannot be switched off. They are usually set in response to actions requesting services, such as setting your privacy preferences, logging in or filling in forms. These are also used in connection with website functionality, like web chat services, product recommendations, predictive sort, product search, and commenting and rating systems. These may be set by us or third-party providers whose services we use. Providers of these services may use their own analytics cookies (or similar technologies) to measure performance of these services. You may be able to use your browser's settings to block or alert you about these cookies, but some parts of the site may not work properly.
- Marketing Cookies: These cookies (or similar technologies) may be set through our site by our advertising partners. These may be used by these companies to build a profile of your interests to show you relevant adverts (for us or other advertisers) on other sites or to other devices connected to you (cross-device advertising).
- Device Identifiers: We and our third party service providers automatically may collect an IP address, mobile advertising identifier, or other unique identifier information ("Device Identifier") for the computer, mobile device, technology or other device (collectively, "Device") you use to access the Sites or on third party websites that publish our advertising. A Device Identifier is a number that is automatically assigned to your Device when you access a web site or its servers, and our computers identify your Device by its Device Identifier. For mobile devices, a Device Identifier is a unique string of numbers and letters stored on your mobile device that identifies it. We may use a Device Identifier to, among other things, administer the Sites, help diagnose problems with our servers, analyze trends, track users’ web page movements, help identify you and your shopping cart, deliver advertising and gather broad demographic information. Most mobile devices will allow you to turn off sharing or reset a Device Identifier.
- Mobile Services/Apps: Certain of our mobile apps and tools offer opt–in, geo–location services and push notifications. Geo-location services provide location–based content and services, such as store locators, local weather, promotional offers, and other personalized content. Push notifications can include discounts, reminders or details about local events or promotions. Most mobile devices allow you to turn off location services or push notifications. If you turn on location services, we will collect information about the Wi–fi routers closest to you and the cell IDs of the towers closest to you to provide location–based content and services.
Information from Third Parties: We receive information from third party partners, such as publishers that run our advertising, and retailers who feature our products. This information includes marketing and demographic data (including identifiers, commercial and purchasing information), analytics information (including online information), geolocation, and offline records, as well as inferences. We may also receive information from other companies that collect or aggregate information from publicly available databases or if you consented to allow them to use and share your information. This might be de-identified information about purchasing patterns, location of shoppers and sites that are of interest to our consumers. We also collect information about users who share common interests or attributes (e.g., color treated hair) to create user “segments,” which help us to better understand and market to our customers. We may use your data as part of health-related segments about non-sensitive conditions such as dry skin.
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA's scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
- Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
- Directly and indirectly from activity on our website (www.aramoreskincare.com). For example, from submissions through our website portal or website usage details collected automatically.
- From third-parties that interact with us in connection with the services we perform. For example, from contracted agencies used to sell our products.
Purpose of Information Collected:
We may use or disclose the personal information to provide better products, services, customizations and offerings from New Frontier Bio, Inc. to/for:
- provide tailored and personalized content, services, advertisements and offers based on your characteristics and preferences.
- respond to questions and otherwise interact with you
- provide news, emails, and other requested communications from us
- administer and manage your account, subscription program, or loyalty program membership
- manage any competitions, promotions, surveys, sweepstakes, giveaways, or contents you choose to enter
- verify your identity and detect and prevent fraud
- manage your orders, fulfill product purchases and processing payments
- contact you, send notice of changes to a New Frontier Bio, Inc. policy
- send you marketing communications, which may be tailored to your ‘profile’ which is based on personal information we know about you and your preferences
- provide you with products and services requested (e.g., virtually test our products, notification of when a product is back in stock)
- analyzing use of our products and services to improve effectiveness of our Sites, stores, customer service, and product offerings
- vigilance – collect, evaluate, and monitor reports of undesirable events during or after use of products
- conduct research and analytics including through consumer surveys and other market research activities
- develop new products and services
- allow log in, sharing and use of our content with a social media account
- provide shipping and other benefits from your selected third party providers (such as Shopify)
- post your content and consumer reviews on the Sites, our social media pages and related third party sites that retail or feature our brands and products
- maintain the security of our products, services, and systems
- protect our rights, property, and safety or the rights, property, and safety of others
- provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
- carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- improve our website and present its contents to you.
- testing, research, analysis and product development.
- respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- as described to you when collecting your personal information or as otherwise set forth in the CCPA.
- corporate governance including evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
When we send or display personalized communications or content, we use personal information collected to generate inferences about you. This means we collect personal information about you as described above, and we centralize this data and analyze it to evaluate and attempt to determine your personal preferences or interests. We then send or display communications or content tailored to these preferences, interests or needs.
For purposes of securing transactions, such as purchases and other submissions, placed through our websites/apps/devices against fraud and misappropriation, we use a third party provider’s solution(s). This fraud detection process may be completely automated or may involve human intervention where a person makes the final decision. You may (i) experience delay in the processing of your order/request while your transaction is being reviewed; and (ii) be limited or excluded from benefit of a service if a risk of fraud is identified.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share information with third party service providers fulfilling the above purposes on our behalf, including service providers that host or assist with technical operation of our Sites; information technology vendors that provide information technology services; analytics, and research vendors; vendors that assist and help us in providing digital and e-commerce services such as social listening, store locator services, loyalty programs and program administration, identity management, ratings and reviews, sampling and redemption services, CRM, web analytics, and user generated content curation tools; fraud prevention, legal, compliance, and risk management vendors; order processing fulfilment vendors who process orders, transactions and payments, and provide customer service; marketing, advertising, digital, and social media agencies and vendors that help us deliver advertising, marketing and campaigns, to analyze their effectiveness, and manage your contact and questions;, social media, or other third parties that participate in or administer our promotions, contests, sweepstakes, surveys or provide marketing or promotional assistance. We may also share information with third parties to help us identify your online preferences, including the ads with which you interact. This data may be matched with information that we process about you to provide a better experience using our websites and products. These third parties may use this information for their internal business purposes, such as process or product improvement, but are not permitted to use personal information for their own independent marketing or other purposes. We may also share non-identifying information, such as aggregate statistics or usage information, with third parties.
Categories of Information shared (depending on the specifics of the business transaction) include identifiers, internet or network activity, geolocation data, purchasing information, protected classifications, professional or employment-related information, audio-visual information, other categories of personal information, geolocation information, payment information, other information, and inferences generated from the foregoing categories of information.
We do not sell your Personal Information to third parties.
Your Agreement to Have Your Personal Information Shared
Personal Information may also be shared to complete a transaction you requested. For example, payments made via purchases through some of our Sites are completed using a third-party’s online payment system. Additionally, some of our Sites may provide the opportunity to post content in a public forum. For example, providing ratings & reviews. If you decide to submit information in these public forums, the information will be publicly available.
Some of our Sites have features such as plugins, widgets, or other tools provided by third parties. These tools collect identifiers along with internet or similar network activity. If you engage with such plugins, widgets, or other tools, additional information may be shared. For example, if you use Facebook’s “like” feature, Facebook may register the fact that you ‘liked’ a product and may post that information on Facebook. The use of information is not governed by this privacy notice.
Business Transfers: We share information with other entities and affiliates of the New Frontier Bio, Inc. As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or our assets, or assets related to the Sites, Personal Information, and any other information that we have collected may be disclosed to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.
Your Privacy Rights and Choices
You may change your preferences and unsubscribe from email services from our brands by: (i) modifying your registered user information on the Sites; (ii) sending us an e–mail to the email address listed in Contact Us located at the end of this notice; or (iii) following the unsubscribe instructions in the communication that you receive.
Retaining Personal Information
In accordance with our routine record keeping, we may delete certain records that contain Personal Information you have submitted through the Sites. We are under no obligation to store such Personal Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Information. In addition, you should be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data because of backups and other reasons.
We will retain your Personal Information for as long as your account is active or as needed to provide you services and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you wish to cancel your account or request that we no longer use your Personal Information to provide you services, contact us via one of the methods listed in Contact Us located at the end of this Privacy Notice. We do not control certain privacy settings and preferences maintained by our social media partners like Facebook and Twitter. If you wish to make changes to those settings and preferences, you may do so by visiting the settings page of the appropriate social media site.
You may at any time opt out from push notifications and allowing New Frontier Bio to access location data by adjusting the permissions in your mobile device. You can stop all further collection of information by our mobile applications by uninstalling the mobile application. Please note that if you uninstall the mobile application from your mobile device, the unique identifier associated with your mobile device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.
If you choose, you can provide your mobile phone number to receive text message alerts from our stores or sites to receive product and/or event information, tips or promotions. You agree that by providing your mobile phone number you expressly consent to receive automated marketing text messages from us to the mobile phone number provided. Consent is not required to purchase goods or services. Message and data rates will apply, and you should check the rates of your mobile carrier. You can opt out from further text marketing communications by texting STOP to the SMS number used by New Frontier Bio to contact you.
We may share your mobile phone number with service providers with whom we contract to assist us with the above activities, but we will not share your mobile phone number with third parties for their own marketing purposes without your consent. Text Messages are distributed via third party mobile network providers and, therefore, we cannot control certain factors relating to message delivery. Depending on the recipient's mobile carrier, it may not be possible to transmit the text message to the recipient successfully; nor is content available on all carriers. We do not claim or guarantee availability or performance of this service, including liability for transmission delays or message failures.
Interest-Based Advertising and AdChoices
If you would prefer not to accept cookies, you can manage your cookie preferences by clicking on the “Cookie Settings” button located on the bottom of the website homepage. You cannot disable essential cookies. We use certain analytics services, such as Google Analytics, to gather information about our site visits or mobile app usage.
You can also change your browser settings to notify you when you receive a cookie, which lets you choose whether to accept it; or set your browser to automatically reject any cookies. However, please be aware that some features and services on our Sites may not work properly because we may not be able to recognize and associate you with your account. In addition, the offers we provide when you visit us may not be as relevant to you or tailored to your interests. To learn more about cookies, please visit https://www.allaboutcookies.org.
We use third party companies to serve advertisements, measure the performance and engagement with our ads, provide analytics, preference, and interest information. In some instances, these ad network providers, social platforms, sponsors, and/or analytics 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 (i.e. computers or mobile devices.). We may recognize that one cookie ID (i.e. from a computer) may be connected to another device (i.e. 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 ad 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 ad across different devices. We may also combine information we collect from your devices with other information we have about you, such as your account information, services, transaction history, and interaction with our sites.
Some social networks (such as Facebook, Instagram, Twitter, Google, etc.), allow you to exercise ad choices, limit data collection and clear your history on that platform as well.
CALIFORNIA Rights and Choices
This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Statement of New Frontier Bio, Inc. and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Visiting www.aramorskincare.com for Customer Service contact information including phone number and email.
- Send request via one of the methods listed under Contact Information below.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
CALIFORNIA CONSUMERS:If you are a California resident and wish to exercise your rights under the California Consumer Privacy Act of 2018, Below are two or more designated methods for submitting requests to opt-out of sale/sharing:
If you are a minor under 18 and have a profile on a New Frontier Bio, Inc. Site, you may ask us to remove reviews or other content that you posted on the site by writing to us at the address listed at the end of this notice and providing as much detail as possible (i.e., date and caption) as to the post(s) you want removed. Please note that processing your request does not ensure complete or comprehensive removal of content that you posted.
CHILDREN: New Frontier Bio, Inc. sites are not directed to children under 13. We do not knowingly collect, use or disclose personally identifiable information from anyone under 13 years of age. If we determine upon collection that a user is under this age, we will not use or maintain his/her Personal Information without the parent/guardian's consent. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 13, we will make reasonable efforts to delete such information from our records. If you believe that we might have any information from or about a child under age 13, please contact us through one of the methods listed in the Contact Us section at the end of this notice.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us.
Aramore Customer Service
Or send us an e–mail with your request to firstname.lastname@example.org
UPDATED: OCTOBER, 2022