ETHIQUE BEAUTY PRIVACY POLICY 

 

 

LAST UPDATED AND EFFECTIVE:  February 1, 2025 

 

  1. Our Collection of Your Personal Data 

 

Ethique Consumer Products, Inc. (“Ethique”, “Ethique Beauty”, "us," "we," or "our") offers and maintains the website(s) located at ethique.com and ethique.co.nz, including all subdomains and subparts, as well as our social media accounts on Facebook, Instagram, YouTube, Google, Pinterest, TikTok, and Twitter, and other platforms (collectively, the “Site”).  When you visit the Site, you may choose to provide us with personal data that identifies you.  This Privacy Policy explains how we process and use your personal data, and it applies regardless of how you access the Site.   

 

Please take time to read this Privacy Policy carefully.  Please also review our Terms of Use. 

 

BY CHECKING THE BOX PROMPT BEFORE SUBMITTING DATA TO US, YOU EXPRESSLY AGREE TO THE COLLECTION, USE, DISCLOSURE, RETENTION, AND DESTRUCTION OF YOUR PERSONAL DATA SUBMITTED TO US IN ACCORDANCE WITH THIS PRIVACY POLICY.  

 

If you live in a state, like California and others, that extends comprehensive privacy rights respecting Personal Data to its residents, the subsection below titled “Comprehensive States’ Privacy Rights,” within Section 5, includes a description of your rights and our handling of your Personal Data. 

  1. Personal Data We Collect 

 

When you provide it to us, we collect information that identifies you (“Personal Data”), such as your: 

 

  • Name 

  • Email address 

  • Address 

  • Telephone number 

  • Birthday 

  • Payment information 

  • Account log in information, including password 

  • Content of your interactions with or messages to us, including applications, emails, texts, chats, voice recordings, and communications through social platforms or other feedback 

  • Product experience information, including any personal health information you choose to share with us 

 

When you visit the Site, we collect data from the device or browser through which you access the Site (“Log Data”), such as: 

 

  • Your internet protocol (“IP”) address 

  • Browser type 

  • Browser version 

  • Internet activity information, including your browsing history, search history, and information regarding your interaction with our website or advertisements 

  • Statistics on your activities on the Site (such as the date and time of visits, the pages viewed, time spent at the Site) 

  • Information about how you came to the Site 

  • Data collected through cookies, chat applications, or other similar technologies discussed in more detail in the section below on cookies. 

Much of this Log Data does not identify you personally. However, we may associate this Log Data with your Personal Data. When we do, we will treat any such combined data as Personal Data until such time as it can no longer be associated with you or used to identify you.   

  1. How We Use Your Personal Data 

 

We use your Personal Data for the purposes for which you provided it, including to: 

 

  • fulfill your product or service needs; 

  • register your online account; 

  • advise you about products, services, offers, or events that may be of interest to you; 

  • enroll you in subscription services, such as email or text message marketing; 

  • provide information that you request; 

  • maintain our own accounts for billing and delivery;   

  • advise you about products, services, offers, or events that may be of interest to you; and 

  • provide customer service to you.   

 

We may also use your Personal Data or Log Data to administer our internal business activities, including to: 

 

  • design and arrange the Site content and functionality in the most user-friendly manner; 

  • monitor the safety of our products; 

  • better understand customer trends and requirements and visitors to the Site; 

  • create non-personally identifiable data to be used for marketing;  

  • monitor and train to ensure quality customer service; 

  • use third party services, such as Google Analytics, that collect, monitor, and analyze Log Data to market to you and provide you with a personalized experience; 

  • offer you access to and secure our digital properties from unauthorized access, scams, malicious code, theft, losses, or other harms, including monitoring of your use and communications;  

  • detect unauthorized activity on the Site; 

  • investigate violations of law and generally to protect the rights and interests of Ethique Beauty, its employees, customers, and others; 

  • comply with our legal obligations, including reporting safety data to FDA; 

  • manage your account; and 

  • provide a service that is reliable, responsive, and efficient. 

 

If you sign up to receive recurring, marketing text messages from us, we collect your name, the mobile telephone number you provide, and your opt-in consent information, including your written or electronic signature, and use or disclose it to: 

  • send recurring, marketing text messages to the phone number you provide at varying frequencies using an automatic telephone dialing system 

  • provide customer service to you via text message or telephone, including a welcome message about your subscription in our text messaging program and responses to your requests for help by emailing hello@ethique.com 

  • cancel your subscription to our text messaging program when, at any time, you text STOP to the number from which you are receiving our messages or change your communications preferences on our Site 

  • confirm when we cancel your subscription to our text messaging program with a single, autodialed text message  

  • engage and use one or more third-party service providers to provide software we use to perform the above functions, but we never sell text messaging originator opt-in data or consent to third parties.  

 

You do not have to opt in or agree to receive text messages as a condition of purchasing any products or services.  Message and data rates may apply for any messages you receive from or send to us. If you have any questions about your text plan or data plan, it is best to contact your wireless provider. Ethique Beauty and the mobile carriers (for example, T-Mobile) are not liable for delayed or undelivered messages. 

 

We may use third-party services and advertising networks, such as Google Analytics, that collect, monitor, and analyze Log Data to deliver online behavioral advertising that serves ads to you on our behalf on other sites throughout the Internet.  We may also contract with third-party vendors to send email to customers whom we think may be interested in our products or services.  

 

  1. How We Disclose Your Personal Data 

We will not disclose your Personal Data to third parties, except for the uses and in the manner described in this Privacy Policy. There are certain circumstances in which we may disclose your Personal Data to certain third parties after obtaining your consent.  We may also use de–identified or anonymized versions of your Personal Data for any purpose.  By using the Site or submitting your Personal Data to us, you expressly consent to our disclosing your Personal Data, as set forth below. All the below categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties. 

For purposes consistent with this Privacy Policy, we may disclose your Personal Data to: 

Ethique Beauty affiliated entities 

 

  • our parent companies, subsidiaries, and/or affiliates 

Third-parties we engage to perform business-related functions for Ethique Beauty or provide services to customers 

  • third parties who provide services to our customers or with whom we partner to do business; 

  • third parties who assist with our marketing, including chatbot applications, marketing agencies, and analytics companies, such as Google Analytics, that collect, monitor, and analyze Log Data;  

  • third party providers of database, software, email, security, backup and disaster recovery services;  

  • payment processors; 

  • our insurance carriers;  

  • professional service providers, such as consultants, attorneys, and accountants  

Third parties to whom we disclose your Personal Data have agreed to be bound to maintain and use it securely for limited purposes and only in accordance with this Privacy Policy. 

 

Social media platforms  

  • including Facebook, Instagram, YouTube, Google, Pinterest, TikTok, and Twitter, and application developers who specialize in social commerce  

  • so you can connect to us, share your interests, express opinions about products and services, purchase our products, and generate interest in our products and services among members of your social networks  

If you use third party social media features available on our Site, we or the third party may collect or share your data, including your Personal Data.  If you do not want us to be able to access information about you, including Personal Data, from Third Party Sites, you must limit data collection and disclosure in the privacy settings on the Third Party Sites.  We reserve the right to remove the Personal Data or other data of any person for any reason we, in our sole discretion, deem appropriate. 

 

Successors who acquire your Personal Data 

 

  • if we sell, merge, reorganize, dissolve, or similarly change our ownership or corporate structure  

Government or third party lawyers  

if required to do so by law or in our good faith belief that such action is necessary to: 

  • comply with a legal obligation, such as to report a serious adverse event to FDA;  

  • protect or defend our rights, interests, or property, or that of third parties;  

  • prevent or investigate possible wrongdoing in connection with the Site or any of our parks;  

  • act in urgent circumstances to protect the personal safety of users of the Site or the public; or  

  • protect against legal liability. 

 

 

Summary of Disclosures of Personal Data 

We collect the Personal Data described in the table below directly from you or automatically when you visit the Site.  

 

Category 



Examples 

Purposes 

Disclosed to 

Identifiers 

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, or other similar identifiers. 

Fulfill product or service needs; conduct marketing, including analytics functions; process payments; secure digital and physical properties; and other business purposes set forth in Section 3 above 

Ethique Beauty entities; service providers; social media platforms; government authorities if reporting is required 

Consumer records information 

Name, address, telephone number, financial information, medical information. Some personal information included in this category may overlap with other categories. 

Medical information is only collected if you report an adverse event and only shared if it is required to be reported to FDA. 

 

Fulfill product or service needs; conduct marketing, including analytics functions; process payments; secure digital and physical properties; and other business purposes set forth in Section 3 above 

Ethique Beauty entities; service providers; government authorities if reporting is required 



1Internet or other similar network activity 

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. 

Fulfill product or service needs; conduct marketing, including analytics functions; process payments; secure digital and physical properties; and other business purposes set forth in Section 3 above 

Ethique Beauty entities; service providers; social media platforms 

Professional or employment-related information. 

Employer other employment-related information. 

Applicable to stylist and salon customers only 

Fulfill product or service needs; conduct marketing, including analytics functions; process payments; secure digital and physical properties; and other business purposes set forth in Section 3 above 

Ethique Beauty entities; service providers; social media platforms 

 

 

  1. Your Rights About The Processing Of Your Personal Data 

You have the right to consent or withdraw your consent to the processing of your Personal Data at any time, subject to exceptions defined by law.  If you change your privacy preferences in the future, that will not limit the lawfulness of any processing performed based on your prior consent.  To withdraw consent, please email us at hello@ethique.com and specify what you would like us to do.  You may have additional rights, under the laws of your jurisdiction, with which we comply.   

To stop email communications from us, you can also follow the unsubscribe instructions set forth at the bottom of our promotional e-mail messages.  You may also access and correct some of your Personal Data by logging into your online account, if you have one.  If you choose to limit our use of your Personal Data, you may not have access to certain functionality of the Site, such as promotions, product information, or opportunities.   

Comprehensive States’ Privacy Rights  

If reside in a state that offers comprehensive privacy rights respecting your Personal Data, you have the following rights: 

  • Access:  You have the right to access a copy of your Personal Data that we hold about you, upon receipt of a verified request.  

  • Accuracy:  You have the right to correction of any inaccurate or out of date Personal Data.   

  • Deletion:  You have the right to delete your Personal Data, upon receipt of a verified request, with some exceptions. 

  • Equal Treatment:  You have the right to equal treatment regardless of your exercise of your privacy rights. 

  • Sensitive Personal Data:  You have the right to limit, with some exceptions, our use of your sensitive Personal Data, including identification numbers (like Social Security number), financial account and access information, precise geolocation data, personal demographic information (like your race, religion, philosophical beliefs), genetic or biometric information, and information about your health or sexual activity. However, we do not collect or use Sensitive Personal Data. 

Opt Out:  You have the right at any time to opt out of the sale of your Personal Data, the use of your Personal Data for profiling, or the sharing of your Personal Data for targeted or cross-context behavioral advertising.  You, or a person authorized by you under the laws of your state to act on your behalf, may request the following information or exercise any of the above rights by emailing us at hello@ethique.com. 

  • the categories of Personal Data we collected, sold, or disclosed in the prior 12 months; 

  • the pieces of Personal Data we collected about you in the prior 12 months;   

  • our business purposes for collecting or selling Personal Data;  

  • the categories of sources from which we collected Personal Data in the prior 12 months; 

  • the categories of third persons with whom we sold or shared Personal Data in the prior 12 months;  

  • the categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;  

  • the names and addresses of the third parties that received the information; and,  

  • if the nature of the third party's business cannot be determined from their name, examples of the products or services they marketed.  

We may provide this information in a standardized format that is not entirely specific to you.  Before we may fulfill a request to access, correct, limit the use of, or delete your information, we are required to verify your identity.  We will ask you to verify your name, address, email address, and telephone number. When providing us this information, you represent and affirm that all information provided is true and accurate. If we are unable to verify that the consumer submitting the request is the same individual about whom we have collected Personal Data, or an authorized agent, we may contact you for more information, or we may not be able to meet your request.  Only you, or an agent legally authorized to act on your behalf, may make a verifiable request related to your Personal Data. If you are making a request as the authorized agent of a consumer, we will ask you also submit reliable proof that you have been authorized in writing by the consumer to act on such consumer's behalf. 

 

We will make every effort to respond to your request within 45 days from when you contacted us. If you have a complex request, we may require up to 90 days to respond. We may contact you within 45 days from the date you contacted us to inform you if we need more time to respond. 

 

We do not offer ways to limit the use or disclosure of Sensitive Personal Data, as we do not collect or use Sensitive Personal Data.    

 

Personal Data does not include: publicly available information; de-identified or aggregated consumer information; or information excluded from the scope of your state’s privacy law, such as health or medical information covered by the Health Information Portability and Accountability Act (HIPAA) or personal information covered by certain sector-specific privacy laws, such as the Fair Credit Reporting Act (FCRA). 

 

  1. Notice of Financial Incentive 

 

Ethique Beauty offers customers the opportunity to participate in Ethique Rewards which may provide benefits, including the opportunity to earn points that can be redeemed for discounted products on the Site, to those who choose to join. Those benefits are described along with other material terms and conditions in our Terms of Use. Our collection of customers’ Personal Data (including name, email address, and other Personal Data as described in Section 2 above) allows Ethique Beauty to operate the Ethique Rewards and provide membership benefits. We use the Personal Data of Ethique Rewards to both award and redeem points. Otherwise, the types of Personal Data we collect from Ethique Rewards are generally similar to the types of Personal Data that we collect from customers who are not Ethique Rewards. The amount of Personal Data that we collect from a member or non-member may vary and is dependent on the level of interactions and engagement that the member or non-member has with us. The value of benefits to Ethique Rewards members varies significantly as individual members take advantage of benefits to varying degrees. 

 

  1. How We Secure Your Personal Data 

 

We secure your Personal Data by: keeping Personal Data up to date; storing and destroying it securely; not collecting or retaining excessive amounts of data; protecting Personal Data from loss, misuse, unauthorized access and disclosure, alteration, and destruction; and ensuring that appropriate technical measures are in place to protect Personal Data.   However, no network, server, database, or Internet or e-mail transmission, is ever fully secure or error free. Therefore, you should take special care in deciding what Personal Data you send to us electronically.  For more information on the security of your Personal Data, please reference our Terms of Use. 

 

  1. How Long We Keep Your Personal Data 

 

We will retain your personal data as long as necessary to carry out the function for which you provided it to us, including maintenance of your account. You may close your account, unsubscribe to emails, and otherwise limit our use of your Personal Data by contacting us. However, we may retain your Personal Data for an additional period as is permitted or required under applicable laws. Even if we delete your Personal Data, it may persist on backup or archival media for an additional period of time. 

  1. Use of Cookies 

We use cookies on our Site.   

What Are Cookies?  

A cookie is a piece of information that is placed on your web browser or device when you access and/or use the Site.  Cookies store text and can later be read back by the Site or third parties.   Cookies can remember the information you access on one webpage to simplify your subsequent interactions with the Site or to use the information to streamline your transactions on related webpages.  

Why We Use Cookies  

We use cookies to recognize your browser and you as a unique visitor to the Site through an anonymous unique identifier.  We use cookies to: 

  • recognize when you are logged in to your account on the Site; 

  • monitor and analyze how you use the Site or interact with us; 

  • remember your preferences to make your online experience easier and more personalized;  

  • route Site traffic to effectively distribute the Site workload across servers;  

  • use analytics, such as Google Analytics, to help understand how visitors come to and use the Site, including through combination with third-party cookies of our service providers; 

  • provide information to us about which advertisements you see and click or to show you ads on or off the Site; and 

  • test new features.  

How You Can Manage Cookies  

You can manage cookies through the Site's option settings, found in our cookie banner at the bottom of our homepage or through your web browser's option settings.  You may be able to be notified when you are receiving new cookies and disable or delete cookies. Please refer to your web browser's help section for information on whether you can and how to do this. The links below provide information about cookie settings for the browsers supported by the Site: 

Many of the third party technologies that enable targeted banner advertising also allow you to opt out. Such third party service providers include Adroll, Rubicon, Google, Media Math, Perfect Audience, Quantcast, Retargeter, and Yahoo! among others.  You can control your preferences directly with each such third party service provider.  

To see how to opt-out of Google Analytics Advertising Features, visit Google Ads Settings, Ad Settings for mobile apps, or any other available means (for example, the NAI's consumer opt-out listed below). Google also provides a Google Analytics opt-out plug-in for the web.   

You can find more information on how Google Analytics works in this Google guide and on Facebook App Events here. 

You can learn more about cookies at the following third party websites: 

  1. Use of Automated Assistant Chatbot 

We offer an Automated Assistant on the Site that you may engage with to answer your questions. Our Automated Assistant is a chatbot. When you engage with our Automated Assistant, you are not conversing with a human.  A chatbot is a computer program that uses artificial intelligence (AI) and natural language processing to understand customer questions and automate responses to you, simulating human conversation.  

Our Automated Assistant operates like an interactive FAQ, responding to a set of anticipated questions with answers authored by humans and produced when prompted by a recognized question. It can transfer you to our human support staff if it is unable to answer your questions or if you ask to speak to a representative.  

We offer the Automated Assistant to make information about our products, services, and events immediately available to Site visitors. When you engage with our Automated Assistant, we record your communications with us and use them to provide further customer service to you, market to you, and improve the experience of our Automated Assistant for other Site visitors.  You are not required to engage with our Automated Assistant and may reach our human support staff at hello@ethique.com. 

  1. What Data Is Not Covered By The Privacy Policy? 

 

The limitations in and requirements of this Privacy Policy do not apply to: 

 

  • Third Party Sites:  Any data you disclosed on websites not operated or controlled by us (“Third Party Sites”), even though we may provide links to them on the Site or in our emails. We are not responsible for the policies and practices employed by, or the content of, Third Party Sites. We suggest contacting those sites directly for information about their privacy policies and practices.   

 

  • Non-Personally Identifiable Data: Any non-personally identifiable data we collect, including, without limitation, Log Data, domain names of your Internet Service Provider, your approximate geographic location, a record of your usage of the Site, the time of your usage, and aggregated personally identifiable information, but only to the extent the foregoing cannot be used to specifically identify you.  

 

  • Aggregated Personal Data: Any aggregated Personal Data that can no longer be used to identify you will be treated as non-personally identifiable data under this Privacy Policy. 

 

  1. We Do Not Collect The Personal Data of Children 

 

We do not intentionally or knowingly collect any Personal Data from children under the age of sixteen (16), nor do we target our emails to them.  Children under the age of sixteen (16) should not submit any Personal Data through the Site.  We encourage parents and legal guardians to monitor their children's use of the Internet and instruct them to never provide Personal Data through the Site.  If you believe a child under the age of sixteen (16) may have provided Personal Data to us through the Site, please contact us at hello@ethique.com, and we will use reasonable efforts to delete it from the Site and our files.  

 

  1. International Privacy Laws 

 

If you are visiting the Site from outside the United States, please be aware that you are sending information (including Personal Data) to the United States where our servers are located. That information may then be transferred within the United States or back out of the United States depending on the type of information and how it is stored by us. We will hold and process your Personal Data in accordance with privacy laws in the United States and this Privacy Policy. Please note that privacy laws in the United States may not be the same as, and in some cases may be less protective than, the privacy laws in your country, and while in the United States Personal Data may be subject to lawful access requests by government agencies.    

 

  1. Changes To This Privacy Policy 

 

We may occasionally make changes to this Privacy Policy.  If we wish to use your Personal Data for a new purpose not covered by this Privacy Policy, we will provide you with a new Privacy Policy explaining this new use prior to commencing the processing of your Personal Data pursuant to the new Privacy Policy and setting out the relevant purposes and processing conditions. If we change this Privacy Policy, your checking the box prompt before submitting Personal Data to us will signify your express consent to new uses of your Personal Data.  

 

  1. How You Can Resolve A Privacy Dispute With Us 

If you have a complaint about this Privacy Policy or our privacy practices, we will work with you in an attempt to resolve your complaint.  Please contact us at hello@ethique.com.  Please also refer to the arbitration procedures described in the Dispute Resolution section of the Site’s Terms of Use.  BY CHECKING THE BOX PROMPT BEFORE SUBMITTING YOUR PERSONAL DATA TO US, WE EACH AGREE TO SETTLE DISPUTES ONLY BY NON-CLASS, INDIVIDUAL ARBITRATION, INSTEAD OF SUING IN COURT (EXCEPT CERTAIN SMALL CLAIMS).  THE RULES IN ARBITRATION ARE DIFFERENT.  THERE IS NO JUDGE OR JURY, LIMITED DISCOVERY RIGHTS, AND REVIEW IS LIMITED, BUT AN ARBITRATOR CAN AWARD THE SAME DAMAGES AND RELIEF, AND MUST HONOR THE SAME LIMITATIONS STATED IN THE AGREEMENT, AS A COURT WOULD.   

To initiate an arbitration proceeding, you must send us a notice of your complaint that includes a written statement of your name, address, and contact information, the facts giving rise to your complaint, and the relief you are requesting (the “Dispute Notice”).  The Dispute Notice must be emailed to hello@ethique.com as described in the Dispute Resolution section of the Site’s Terms of Use.  If we do not reach an agreement to resolve your privacy complaint within sixty (60) days after we receive your Dispute Notice, you may commence an arbitration proceeding under the Dispute Resolution section of the Site’s Terms of Use.     

  1. How Can I Contact You? 

 

If you have any questions about this Privacy Policy, our practices, or your dealings with us, or to exercise any and all of your rights, please contact us at hello@ethique.com.