This is the privacy policy (“ Policy”) of Fig Facial Inc. (“ Fig Facial”). Fig Facial is committed to protecting your right to privacy when you provide us with personal information. This Policy sets out how we collect and manage personal information, whether that information is collected via our websites (“ Websites”), including www.figfacial.com, or otherwise, including through our services (“the “ Services”), what is collected and the steps we take to protect it. In this Policy, the terms "you", "user" and "your" refer to a visitor of our Websites or user of the Services and the terms “we”, “us” and “our” refer to Fig Facial.

Please read this Policy carefully before using our Websites. We may also update or modify this policy at any time by posting our revised policy to our Websites. We include an “effective date” in the Policy displayed on our Websites. We strongly encourage you to refer back to the Policy periodically to ensure that you stay up to date with our practices and procedures.

By using our Websites, you warrant that you have read, understood and agree to be bound by this Policy, including any updates to the Policy, and approve of the collection and use by us of your personal information according to its terms.

In the course of providing services through our Websites and off-line, we may collect your personal information.

“Personal information” means information that can identify an individual, and includes, for example, a person’s name, home address, home phone number, gender, date of birth, language preference, email address, credit card information, bank account information, account information with us, IP address or social media user name or identification. Personal information does not include information to enable an individual at a place of business to be contacted, such as their name, position name or title, business telephone number, business address, business mail or business fax number.

We will only collect personal information as permitted under the applicable federal and provincial privacy legislation. We may collect information in a variety of ways, including where you:

• submit an application to use our Websites and, where the option is available, create an account;
• place an order for any of our products or schedule to receive our Services;
• request us to provide you information about our company and promotional offers;
• submit an employment application to us;
• contact us; and
• provide feedback in an online survey.

By submitting information to us, you consent to us collecting your information.

We collect Personal Information for purposes related to managing and developing our business and operations, including:

• establishing, managing and terminating business relations with you;
• processing orders that you submit to purchase our products and Services;
• performing any contract that we have with you;
• providing us with information in order to improve our Websites and develop new products and Services;
• internal record keeping, including details regarding products and/or Services provided by us to you;
• requesting feedback through an online survey;
• providing you with information regarding our products and Services and to notify you of changes to these products and Services; and
• for other purposes related to the management of our relationship.

We may also collect aggregate information which tells us about visitors to our Websites, but not the identity of those visitors. For example, we may collect information about the date, time and duration of visits and which pages of our Websites are most commonly accessed. The purpose of collecting this aggregate information is to help us administer and improve our Websites. Data collected through our Websites on an anonymous and aggregated basis helps us measure interest in and use of our Websites. We reserve the right to provide our analyses based on such anonymous and aggregated data to third parties.

Personal information collected by us is used only for the purposes described in this Policy, or for other purposes which are disclosed to you and to which you consent.

We generally use your personal information to:

• create and secure your registered user account;
• identify you as a registered user in our system;
• provide, personalize and improve our Websites, products and Services;
• communicate with you about our Websites, products and Services;
• develop new products, Services and content for our Websites;
• investigate security breaches, for fraud prevention measures or to investigate potential fraud, or cooperate with government authorities pursuant to a legal matter;
• fulfill your requests;
• send newsletters, surveys, offers and promotional materials related to our Websites, products and Services and for our other marketing purposes;
• monitor traffic on our Websites;
• determine the future direction of our Websites, including technical upgrades;
• protect, investigate and prevent potentially fraudulent, unauthorized or illegal activities;
• protect our rights and the rights of other registered users; and
• other uses described in this Policy or in notices we provide to you.

We may also use your information to verify your geographic location. We may use your geographic location data to personalize our Services, recommend content or determine whether the information you have requested is available in your location.

We may disclose or share your personal information in the following circumstances:

• our regular reporting activities to our other affiliates and/or subsidiaries in and outside of Canada;
• protecting our rights and property, including for security breach, loss or fraud prevention, investigation or mitigation purposes;
• protecting the safety of a person or a group of persons;
• with third party service providers and partners that help us to provide our Websites, products and Services, including website hosting, data warehousing, data analysis, event logging, information technology, customer service, payment processing, user analytics and email delivery and messaging;
• with a third party, in the event of a change in ownership of all or a part of us through some form of merger, purchase, sale, lease or amalgamation or other form of business combination, provided that the parties are bound by appropriate agreements or obligations which require them to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Policy, unless you indicate otherwise;
• other purposes identified when the personal information is collected, or as permitted or required by law;
• with any third party, where you have provided your consent for such disclosure or where disclosure is required or permitted by law; and
• other purposes, some of which have been identified in other sections.

Our Websites may contain links to the websites of other organizations which may be of interest to you. Similarly, you may be directed to the websites of other organizations to perform certain functions provided on our Websites. Linked websites are responsible for their own privacy practices and you should check those websites for their respective privacy policies. Please refer to our Terms of Use for further information in relation to links to third party websites.

It is important to us that we collect, use or disclose your personal information only where we have your consent to do so or as provided in this Policy. Depending on the sensitivity of the personal information, your consent may be express, implied or deemed. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you accept, market or sell our products or Services, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to your acceptance and use of those products or Services, or for other purposes identified to you at the relevant time. Deemed consent is consent we assume in the event that you do not exercise an opt-out mechanism offered to you.

By submitting your personal information to us or obtaining our products or Services, you consent to the collection, use and disclosure of your personal information in the manner described in this Policy. To the extent that we are required by applicable laws to obtain your explicit consent for the collection, use or disclosure of your personal information in accordance with this Policy, such consent will be requested at the appropriate time. Further, if we plan to use or disclose your personal information for a purpose not previously identified (either in this Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure. However, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

You may change or withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting the office of our Privacy Officer using the contact information set out below. In some circumstances, a change or withdrawal of consent may limit our ability to provide products or Services to you or your ability to access certain areas of our Websites.

We assume, unless you advise us otherwise, that by receiving a copy of this Policy or by continuing to deal with us, you have consented to the collection, use and disclosure of your personal information as explained in this Policy.

When personal information comes into our possession, we will use commercially reasonable efforts to maintain a secure system of storage to protect the security and integrity of your personal information. Technological and operational policies and procedures are in place to protect personal information from misuse, loss and unauthorized modification or disclosure. We will dispose of personal information where it is no longer necessary to fulfil the purposes for which the information was collected or as required by law.

Unfortunately, no data transmission over the Internet can be guaranteed as completely secure. While we strive to protect such information, we cannot ensure or warrant the security of any information transmitted to us and you do so at your own risk.

You are solely responsible for ensuring that you do not disclose your account access information to third parties. This includes but is not limited to not disclosing such information to anyone, ensuring that sufficient security software is installed and running on your computer, smartphone or tablet, that your network firewall is of sufficient quality and that your wireless connection is encrypted to a degree that will prevent third party access. We are not responsible for any failure by you to secure your own device and its access to the Internet or your use of public, unsecured networks. We are also not responsible for any failure by you to eliminate malware. These failures and others can make you vulnerable to privacy breaches and would put you and your data at risk.

When you visit our Websites, a cookie may be placed within the memory of your internet access device. We may use permanent cookies or server-side artifacts to help us track use of our Websites by users, including casual visitors to our Websites—such as the number and frequency of visits to our pages and which parts of our Websites are visited. This information provides us with constructive feedback about our Websites so that we can identify the most effective areas and improve the less popular ones.

Cookies cannot determine the identity of individual users. It is a feature of your internet browser which you can disable at any time. However, if you refuse or disable cookies, you may be limited in some areas of our Websites.

Similarly, we may also collect information regarding the type of device, your operating system, the browser you use, your internet service provider, your domain name, your internet protocol (IP) address, the date and time that you accessed our service, the website that referred you to our Websites, the web pages you requested and the subject of the ads you click or scroll over, and use such information to evaluate service performance and service quality and to optimize the user’s experience of our Websites. To collect this information, we use cookies, web beacons and similar technologies.

We are committed to complying with Canada’s Anti-Spam Legislation. Where we have your consent or it is lawful to do so, we may provide you with direct marketing communications about our products and Services which may be of interest to you. Such information may be sent to you by post, email, telephone or SMS.

If you have consented to receiving marketing materials from us, you can withdraw your consent to receiving those communications at any time by:

• using the “unsubscribe” mechanism in our emails;
• if you have created an account on one of our Websites, logging into your account and changing your contact preferences; or
• contacting our Privacy Officer using the contact information provided below. 

However, we reserve the right to send you transactional or informational emails such as customer service communications in connection with the products and Services you have purchased or changes to our Websites, your account or our policies.

You have the right to know what personal information we have about you and to correct any inaccuracies. If our Websites allow you to create an account, your personal information is available when you log in to your account and you may correct this information at any time. Otherwise, please direct any such requests by email to hello@formulafig.com or by one of the other means listed below under the heading “Contacting Us”.

Your request will be investigated as soon as possible and you will be provided with a written response.

We may retain your personal information as long as is necessary in order to manage our relationship with you (or fulfill the purposes for which it was collected) or as otherwise permitted by law. The length of time we retain personal information varies and may extend beyond the end of your relationship with us.

If you have any questions or comments about this Policy, your information, our third-party disclosure practices or your consent choices, please contact our Privacy Officer at privacy@formulafig.com. You may also contact us at:

Fig Facial Inc.
2050 W.4th Ave
Vancouver BC V6J 1M9
Attention: Managing Director