The Perry + Hudson Corporation
Privacy Statement
Effective Date: July 18, 2017

Introduction
The Perry + Hudson Corporation (“P+H”) values and respects the privacy of its customers. This Privacy Statement describes how P+H collects, uses, shares, retains, and protects personal information, and the choices you can make regarding your personal information. Click on any heading below to go directly to that section of the Privacy Statement. This Privacy Statement governs the collection, use, and disclosure of “personal information,” as defined in applicable privacy legislation, collected by P+H branded websites and domains, such as www.8facesbeauty.com and any other website that points to this Privacy Statement, unless a statement posted on a specific P+H website states that a different privacy statement applies. All employees and those working on behalf of P+H are responsible for following this Privacy Statement. P+H has designated a Privacy Officer who is responsible for overseeing P+H’s compliance with this Privacy Statement. Please see "How to Contact Us" for information on how to contact the designated P+H Privacy Officer.

TABLE OF CONTENTS:
INFORMATION WE COLLECT
1.Collection of Personal Information Online
- Information You Provide
- Information Collected by Automatic Means
2.P+H Private Label Credit Products

HOW WE USE INFORMATION
HOW WE SHARE INFORMATION
1.Service Providers and Business Partners
2.Legal, Enforcement, Security, and Investigation
3.Sale or Transfer of Business or Assets
4.Aggregate or De-Identified Data

HOW WE RETAIN & PROTECT INFORMATION
YOUR CHOICES
1.How P+H Obtains Your Consent
2.Withdrawal of Consent
3.Individual Access to and Correction of Personal Information

OTHER IMPORTANT CONSIDERATIONS

Do Not Track
Interest-Based Advertising
Social Media Widgets
Links to Other Websites
Children
Changes to this Privacy Statement
How to Contact Us

INFORMATION WE COLLECT

P+H may collect personal information when you:
Purchase, order, return or exchange any of our products online;
Request a copy of an invoice or electronic invoice;
Request a quote, product information or special order any of our products;
Contact P+H customer service representatives or other employees by phone;
Visit our websites;
Enter into a contest or respond to one of our surveys; or
Provide us with comments or suggestions.

P+H may also collect personal information from public sources and from third-parties where permitted by law. Below you will find specific information about P+H collection practices online.

A. Collection of Personal Information Online
(1) Information You Provide

When you visit P+H websites, P+H may provide you with the opportunity to become a registered online user, but will not require that you register. If you register, you will be asked to provide limited contact information and you may also sign up for e-mail newsletters. P+H may use third party companies to authenticate and validate the information you provide to P+H. Your registration information may be merged with additional information we already possess or information provided by the third parties to enhance our marketing efforts. The information you provide while visiting P+H websites may also be combined with marketing research from internal and external sources and may be used to determine informational and shopping preferences.

If you choose to purchase products online from P+H websites you generally will need to provide the following information, and potentially other specific information, so that we can fulfill your order:

First and Last Name
First and Last Name of person authorized to pick-up the product (if other than yourself)
Contact Phone Number(s)
Shipping/Billing Address
Email Address
Payment Information

P+H requests a phone number in case one of our representatives need to reach you. P+H requests an email address because we may send transactional e-mails acknowledging receipt of your order and providing updates on the processing of your order, and potentially to request your feedback related to your shopping experience. You may also be given the choice of receiving future marketing e-mails or newsletters at the e-mail address you provide. Your order information will also be used to track and analyze shopping trends.

(2) Information Collected by Automatic Means
When you visit P+H websites, interact with e-mails from P+H, or access P+H online advertising, P+H may collect certain information by automated means, using technologies such as cookies, Web server logs, and Web beacons. This information may be used to provide a better-tailored and more personalized shopping experience, and for market research, data analytics, and system administration purposes. For instance, P+H may use this information to determine whether you've visited our website before, to store your preferences and settings, to provide sign-in authentication, and for compliance with our legal obligations, policies, and procedures. P+H may also collect data about your activities on our websites for use in providing advertising tailored to your individual interests, as described in Interest-Based Advertising below.

P+H websites may use cookies (such as HTTP or HTML5 cookies) and other types of local storage (such as browser-based or plugin-based local storage). Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings. P+H may use “session” cookies (which do not remain on your computer after you close your browser) and “persistent” cookies (which do remain on your computer until you delete them or they expire.) Your browser may provide the ability to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. Please note, however, that if you disable cookies, you may not be able to use all of the features and functions of our websites.

P+H websites, e-mails, and electronic newsletters may contain tags known as “Web beacons” or “single-pixel gifs,” which are small electronic images used to help deliver cookies on our sites, count visitors to our webpages, determine whether e-mails are opened, and for other operational purposes. We may work with other companies by sharing information about the use of our beacons or to place beacons on their sites or in their advertisements to let us develop statistics on how often clicking on an advertisement or product on one website results in a purchase or other action on other sites. Our webpages may also contain Web beacons from third parties, which help us compile aggregated statistics regarding the effectiveness of our promotional campaigns or other website operations. These Web beacons may allow the third parties to set or read a cookie on your computer.

E-mails from P+H may use links designed to lead you to P+H materials or third-party materials on the Web, after redirection through P+H servers. The redirection system allows P+H to change the destination URL of these links, if necessary, and to determine the effectiveness of our marketing initiatives. Such web links may also allow P+H to determine whether you have clicked a link in an e-mail, and this information about the interaction may be connected to your personal information. If you do not want P+H to collect information about the links that you click, you can choose not to click links in an e-mail that P+H sends.

P+H websites and applications generally use Web server logs to record information about your use of the services, such as your device type, operating system type, browser type, domain, system settings, and IP address, as well as the language your system uses and the country and time zone where your device is located. These logs also may record information such as the address of the Web page that referred you to our website, and other information about your interaction with our websites, such as which pages you visit. This is a common practice that supports the operation and protection of our websites and applications.

P+H may use third parties to perform certain functions on our websites, such as to provide instant surveys. P+H may also use third-party Web analytics services on our websites, such as those provided by Google Analytics, to help us analyze how users use our websites. These providers may collect various data points associated with your visits to our websites, including your IP address, and they may place cookies to help with the analysis. To learn more about Google Analytics and how to opt-out, click here.

P+H may also collect information from commercially available sources to whom you have given consent to share your personal information or who provide anonymous demographic information associated with a geographic area. The information P+H collects from its commercial sources may be used along with the information P+H collects from you when you visit a P+H website. For example, P+H may compare the geographic information acquired from commercial sources with the IP address collected when you visit our website to derive a general geographic area in order to provide you with information or promotions relevant to your geographic area.


HOW WE USE INFORMATION

We may use the personal information we collect for a range of business purposes, including to:
Identify customers and to establish and maintain a relationship and communications with them through various channels;
Provide customers with ongoing service (such as to process orders, payments, returns, warranties, and rebates), to complete deliveries, and to better assist customers when they visit or call us;
Evaluate and respond to requests, inquiries, and applications;
Conduct and administer contests, surveys, and sweepstakes;
Provide customers with information about other P+H products and services, or those of companies with whom we are working, that may be of interest to them;
Customize experiences online, including customized advertisements and offers;
Operate, evaluate, and improve P+H’s business and products (including developing new products; managing communications; performing market research and data analytics; determining and managing the effectiveness of advertising and marketing; analyzing products, websites, and applications; administering websites and applications; and perform accounting, auditing, billing, reconciliation and collection activities);
Protect against and prevent fraud and unauthorized transactions, investigate and manage claims, reduce risk exposure, and generally improve and provide security; and
Comply with and enforce applicable legal and audit requirements.


HOW WE SHARE INFORMATION

We do not sell, trade, or otherwise transfer personal information to unaffiliated third parties without your consent, except as described below.

A. Service Providers and Business Partners
We may disclose your personal information to companies that provide services to us (such as providers of hosting, support, delivery, survey, printing, e-mail, data enhancement, and repair services) or that help us market our products and services. These companies may need access to information about you in order to perform their functions. In some instances, we may ask these companies to collect your personal information on our behalf. These companies are not authorized to use the information we disclose to them, or that they collect on our behalf, for any other purpose without your consent and we use contractual and other measures to ensure that such information is protected in accordance with this Privacy Statement. With your consent we may disclose limited information about you to a third party who may also use the information for their own specific purpose. For instance, we may provide information on your behalf to a supplier in connection with warranty or product safety issues, or we may share limited information with a business partner who is jointly providing a product or service to you or is running a jointly branded promotion with us.

B. Legal, Enforcement, Security, and Investigation
We may disclose personal information about you (1) if we believe we are required to do so by law, regulation or legal process, such as a court order or subpoena; (2) as we deem appropriate or necessary in response to requests by government agencies, such as law enforcement or police services authorities, or tax authorities; (3) when we believe disclosure is appropriate or necessary to protect the rights, property, or safety of P+H, our customers, or others, including to prevent physical, financial or other harm, injury or loss, or to collect debt you owe; or (4) in connection with an investigation of suspected or actual unlawful activity.

C. Sale or Transfer of Business or Assets
We reserve the right to transfer personal information we have about you in the event we sell, finance, or transfer all or a portion of our business or assets (including, without limitation, in the event of a reorganization, dissolution, or liquidation). The use of such personal information, however, would still be restricted to that outlined in this Privacy Statement.

D. Aggregate or De-Identified Data
We may share or make public aggregate or de-identified data derived from personally identifiable information. Such information, however, will not identify you or any other individual.

E. Corporate Group
We may share your information within our corporate group for the purposes contemplated in this Privacy Statement. Where we share your information within our corporate group, we use contractual and other measures to ensure that such information is protected in accordance with this Privacy Statement.


HOW WE RETAIN & PROTECT INFORMATION

P+H may process and store your personal information at a P+H facility in Canada. In addition, some of your information may be used, processed and/or stored by a P+H service provider, agent or supplier which may be located outside of Canada. Information located outside of Canada may be subject to access by law enforcement or other governmental agencies in those countries which such information is situated pursuant to lawful orders or legal process. While your personal information may be subject to the laws of those jurisdictions, P+H policies require that personal information used, processed and/or stored outside of Canada are always subject to protections comparable to those required under the applicable laws of Canada and will not be disclosed to third parties except with consent or as set out in this Privacy Statement. If you would like to obtain access to written information about P+H policies and practices with respect to its service providers located outside of Canada or otherwise have any questions regarding these service providers, please contact P+H Privacy Officer at the How to Contact Us address below.

P+H maintains administrative, technical, and physical safeguards designed and intended to protect personal information against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure or use. Personal information collected by P+H, whether in electronic form or paper form, is protected by security measures appropriate to the sensitivity of the information. The personal information you provide P+H is stored on computer systems located in controlled facilities which have limited access. P+H requires that highly confidential information be transmitted through the use of secure methods.

P+H evaluates its equipment and security procedures regularly and modifies them as necessary. Despite these safeguards, due to inherent uncertainty in the use of the Internet and information systems and the potential for unlawful attacks by third parties, P+H cannot guarantee that the use of our systems, websites, or applications will be completely safe or secure.

P+H may process and store your personal information at a P+H facility in Canada. In addition, some of your information may be used, processed and/or stored by a P+H service provider, agent or supplier which may be located outside of Canada. Information located outside of Canada may be subject to access by law enforcement or other governmental agencies in those countries which such information is situated pursuant to lawful orders or legal process. While your personal information may be subject to the laws of those jurisdictions, P+H policies require that personal information used, processed and/or stored outside of Canada are always subject to protections comparable to those required under the applicable laws of Canada and will not be disclosed to third parties except with consent or as set out in this Privacy Statement. If you would like to obtain access to written information about P+H policies and practices with respect to its service providers located outside of Canada or otherwise have any questions regarding these service providers, please contact P+H Privacy Officer at the How to Contact Us address below.

Please do not transmit sensitive personal information (such as credit card numbers) using your personal e-mail account. E-mail providers typically do not automatically encrypt outgoing messages. If you receive an e-mail or telemarketing call from someone claiming to represent P+H and asking for your personal information, DO NOT RESPOND. If P+H needs information from you on-line, P+H will provide you with a secure online form. If P+H needs information from you verbally, P+H will request the information only when you initiate the call to P+H or if you are speaking with a P+H employee in-person.


YOUR CHOICES

A. How P+H Obtains Your Consent
You provide your consent to the collection, use and disclosure of personal information in accordance with this Privacy Statement when you voluntarily provide the requested information. You provide your implied consent to the use of the kinds of automatic data collection methods described in this Privacy Statement by your continued use of the P+H website or applications. You provide your implied consent to the collection, use and disclosure of personal information with respect to telephone calls with P+H by engaging in such calls. If P+H obtains information from third parties other than public sources, P+H requires those third parties to confirm that they have your consent to disclose your personal information for use by P+H.

B. Withdrawal of Consent
You have the right to withdraw your consent to certain uses and disclosures of your personal information. However, there are certain circumstances where you must provide your consent to the collection, use and disclosure of your personal information based on the action you are taking. In addition, P+H is not permitted to destroy business or accounting records of transactions that it is required to keep to comply with statutory or other legal obligations, assert its legal rights, or comply with its obligations to the provider of the debit or credit card you used. However, P+H will not use your personal information subject to the foregoing for other commercial purposes once you withdraw your consent. In some circumstances, the withdrawal of consent to certain uses or disclosures of personal information may mean that P+H is no longer able to provide certain products or services to you or P+H may be unable to perform certain transactions for you. You may make a written request to P+H Privacy Officer at the How to Contact Us address below. When submitting a withdrawal of consent, you will be asked to provide suitable identification or to otherwise identify yourself.

C. Individual Access to and Correction of Personal Information
P+H strives to keep accurate information by using technology and management processes and policies. Upon receipt of a written request, P+H will provide individuals with reasonable access to the personal information they provided to P+H as well as the ability to correct the information, if necessary. To protect your privacy and security, P+H will also take reasonable steps to verify your identity before releasing any information to the requesting party and before any corrections will be made. P+H reserves the right to request appropriate proof of the requested corrections. If you have chosen to become a registered user on any P+H website and would like to view, change, update or delete any of your registration information, log in and click Your Account at the top of the screen. You will be taken to a page where you can access your information so that you can edit it. Otherwise, to obtain access to the personal information you’ve provided to P+H, you may submit a written request to P+H Privacy Officer at the How to Contact Us address below.


OTHER IMPORTANT CONSIDERATIONS

A. Do Not Track
We do not collect personally identifiable information about users’ online activities over time and across third-party websites and we do not process or respond to "Do Not Track" signals from your browser or other mechanisms that enable consumer choice regarding the collection of personal information about one's online activities over time and across third-party websites or online services.

As described in the Interest-Based Advertising section below, however, we do participate in online advertising networks administered by third parties, and we may share information about activities on our websites with those networks, which may track your online activities over time and across third-party websites.

B. Interest-Based Advertising
P+H may collect data about your activities on our websites for use in providing advertising tailored to your individual interests, and we may share information about activities on our websites with advertising networks administered by third parties. These ad networks track your online activities over time and across websites by collecting information through automated means, and they use this information to show you advertisements that are tailored to your individual interests. The information they collect includes information about your visits to our websites, such as the pages you have viewed. This collection and ad targeting takes place both on our websites and on third-party websites that participate in the ad network, such as sites that feature advertisements delivered by the ad network. As a result, you may see certain ads on other websites based on prior activity on our websites, and vice versa.

The Digital Advertising Alliance of Canada (DAAC) has created guidance for online advertisers and provided a mechanism for such advertisers to comply with users’ choices regarding interest-based ads. To learn more about ad networks, including how to opt out of interest-based ads, click here.

C. Social Media Widgets
P+H websites and applications may include social media features (for example, a Facebook “Like” button). These features are connected to third-parties and may allow such third parties to collect certain information, such as your IP address and which pages you visit on our websites. These social media features are not operated by P+H. Your interactions with these features are governed by the privacy policies of the company providing the features.

D. Links to Other Websites
P+H websites and applications may provide links to third-party websites for your convenience and information. For instance, they may link to websites of product suppliers, manufacturers, and service providers. If you access those links, you will leave the P+H website. P+H does not control those sites or their privacy practices, which may differ from P+H practices. P+H does not endorse or make any representations about third-party websites. The personal data you choose to provide to or that is collected by these third parties is not covered by the P+H Privacy Statement. P+H encourages you to review the privacy policy of any company before submitting your personal information to that company.

E. Children
Generally, P+H does not knowingly collect personal information from persons under the age of 18. Nor does P+H target its websites to children under 13. P+H encourages parents and guardians to take an active role in their children’s online activities and interests. If P+H determines that personal information has been provided by a person under the age of 18, P+H will delete that information as soon as practical unless such deletion is inappropriate given the context (for example, employment applications, loss prevention, fraud and other investigative purposes). If you become aware that such personal information has been provided by a person under the age of 18, please submit a written request to P+H Privacy Officer at the How to Contact Us address below so the information can be deleted.

F. Changes to this Privacy Statement
If P+H changes this Privacy Statement, P+H will post the revised statement in its entirety on www.8facesbeauty.com and other applicable websites with an updated revision date. If P+H makes material changes to the way it collects or uses personal information, P+H may also notify you by other means such as sending an e-mail or posting a notice on the home page.

G. How to Contact Us
P+H values your opinions. If you have a privacy inquiry, you may direct your inquiry, compliment or complaint to P+H Privacy Officer at info@8facesbeauty.com or by submitting a written request to:

The Perry + Hudson Corporation
Attention: Privacy Officer
131 Marlborough Avenue
Toronto , Ontario
M5R 1X5