FACEMETHOD INC., an Ontario corporation that operates the restoration studio commonly known as Sous La, is committed to respecting and protecting your privacy and the personal information that you share with us on this website. When you visit the website www.souslaface.com (“this Website” or “our Website”), just as with other sites on the Internet, the owner of the site has the ability to collect a variety of information about you and your activities on the site.

The following is Sous La's privacy policy. This Privacy Policy describes our policies and procedures on the collection, use and disclosure of Your information when using our website (https://souslaface.com also referred to as Service) and explains Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve your experience. By using our Service, You agree to the collection and use of information in accordance with this Privacy Policy.

The policy applies only to this Website and does not cover information provided on websites linked to our Website for purchasing or other purposes. Your use, and your privacy rights, in connection with any visits to those linked websites are covered by the privacy policies and terms of use that are posted on those sites. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Sous La may update this privacy policy from time to time. We will post all updated policies on this page. You should consult this page frequently so that you are aware of our updated policies. This privacy policy was last updated on October 14, 2020.

Types of Information We Collect

Personal data is any information that relates to an identified or identifiable individual.

While using Our website or on our property, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. we may use that information to improve the content of this Website, to notify you about updates to this Website, and to contact you directly regarding products or promotions we believe may be of interest to you. We may also use it to analyze your shopping or browsing history, your use of this Website, and demographic information (gender, age and location, for example) about you and Sous La's other online customers.

If you apply for a job with Sous La, we may collect information from your resume and other employment-related submissions

Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Age
• Usage Data

If you do not want your personal information collected, please do not submit it to us. If you submit this information and later would like us to remove it from our records, please contact us at info@souslaface.com.

Please provide your full name, email address and phone number so that we can be sure to correctly remove you from our system. Please note this may not remove you from receiving mail communication from us.

In addition to information that we collect from you directly, Sous La may gather information associated with your social media account if that information is available to Sous La. This includes your profile information, email address, name and posted photographs.

Except as described below in this section and under the “Disclosure of Information” section, we do not give or sell any user information to any third party, but Sous La may disclose your personal information when required by law or court order.

Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Usage Data is collected automatically when using our website.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service.

You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser. Learn more about cookies here: Cookies: What Do They Do?

We use both session and persistent Cookies for the purposes set out below:

1. Necessary / Essential Cookies
   Type: Session Cookies
   Administered by: Us
   Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
2. Cookies Policy / Notice Acceptance Cookies
   Type: Persistent Cookies
   Administered by: Us
   Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
3. Functionality Cookies
   Type: Persistent Cookies
   Administered by: Us
   Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
4. Tracking and Performance Cookies
   Type: Persistent Cookies
   Administered by: Third-Parties
   Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new advertisements, pages, features or new functionality of the Website to see how our users react to them.

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract:the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.

We may share your personal information in the following situations:

• With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to advertise on third party websites to You after You visited our Service, for payment processing, to contact You.
• For Business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other Legal Requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.

Service Providers have access to Your Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose.

We use Google Analytics to monitor and analyze the use of our Service. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

We may use Email Marketing Service Providers, including Mailchimp to manage and send emails to You. Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC.

For more information on the privacy practices of Mailchimp, please visit their Privacy policy: https://mailchimp.com/legal/privacy/

The Company uses Google Ads (AdWords) and Facebook to advertise on third party websites to You after You visited our Service. We and Our third-party vendors use cookies to inform, optimize and serve ads based on Your past visits to our Service.

Google Ads (AdWords) remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Facebook is a remarketing service provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950

To opt-out from Facebook’s interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

When shopping for products on Sous La store we will not store or collect Your payment card details. That information is provided directly to Our third-party payment processor, Squareup.com whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

Their Privacy Policy can be viewed at https://squareup.com/ca/en/legal/general/privacy

We may use the third-party Service Providers Google Places to provide better improvement of our Service.

Google Places is a service that returns information about places using HTTP requests. It is operated by Google.

Google Places service may collect information from You and from Your Device for security purposes.

The information gathered by Google Places is held in accordance with the Privacy Policy of Google: https://www.google.com/intl/en/policies/privacy/

Legal Basis for Processing Personal Data under GDPR (General Data Protection Regulation)

For the purpose of the GDPR:

• You can be referred to as the Data Subject or as the User as you are the individual using the Service.
• The Company is the Data Controller.
• Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
• Data Controller refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights Under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

• Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
• Request correction of the Personal Data that We hold about You. You have the right to to have any incomplete or inaccurate information We hold about You corrected.
• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
• Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
• Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
• Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

Your Rights Under the CPA

For the purposes of the CPA:

• Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
• Business refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of Ontario.
• Consumer means a natural person who is a Ontario resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
• Sale means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s Personal information to another business or a third party for monetary or other valuable consideration.

Under this Privacy Policy, and by law if You are a resident of Ontario, You have the following rights:

The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.

The right to access / the right to request. The CPA permits You to request and obtain from the Company information regarding the disclosure of Your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party’s direct marketing purposes.

The right to say no to the sale of Personal Data. You also have the right to ask the Company not to sell Your Personal Data to third parties. You can submit such a request by visiting our “Do Not Sell My Personal Information” section or web page.

The right to know about Your Personal Data. You have the right to request and obtain from the Company information regarding the disclosure of the following:

• The categories of Personal Data collected
• The sources from which the Personal Data was collected
• The business or commercial purpose for collecting or selling the Personal Data
• Categories of third parties with whom We share Personal Data
• The specific pieces of Personal Data we collected about You

The right to delete Personal Data. You also have the right to request the deletion of Your Personal Data that have been collected in the past 12 months.

The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your Consumer’s rights, including by:

• Denying goods or services to You
• Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
• Providing a different level or quality of goods or services to You
• Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your CPA Data Protection Rights

In order to exercise any of Your rights under the CPA, and if you are a Ontario resident, You can email or call us.

The Company will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

Do Not Sell My Personal Information

We do not sell personal information. However, the Service Providers we partner with (for example, our advertising partners) may use technology on the Service that “sells” personal information as defined by the CPA law.

If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CPA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that you use.

You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

From Our “Cookie Consent” Notice Banner

The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.

Mobile Devices

Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:

• “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
• “Limit Ad Tracking” on iOS devices

You can also stop the collection of location information from Your mobile device by changing the preferences on your mobile device.

“Do Not Track” Policy as Required by Freedom of Information and Protection of Privacy Act (FIPPA)

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Information you provide on this Website may be disclosed by Sous La to any of its affiliates and to third-party service providers who manage our customer information and perform services on our behalf. These services may include, without limitation, administering promotions or contests, administering surveys, and communicating with users.

If Sous La, or the assets of Sous La, were to be sold or merged with another business, our successor would have all of the information you provide.

If you were to give us your name, mailing address, shipping address and/or email address, you might be added to our marketing database. If you are added to our marketing database, you may later opt out of receiving email communications by clicking the “unsubscribe” link on one of our emails and you may opt out of receiving other communications by sending an email to info@souslaface.com and stating that you would like to opt out of email communications from Sous La.

While this Website is a general audience site, Sous La will never knowingly request or collect personal information from any person under 13 years of age without prior verifiable parental consent. We assume that any user of this Website is 13 years of age or older, but if we have good reason to believe that a user is not, we will ask for verification. Children under age 13 should always ask their parents or guardians for permission before providing any personal information to anyone online. If we become aware that an individual is under the age of 13 and has submitted any information to Sous La for any purpose without prior verifiable parental consent, we will delete his or her information from our files. In addition, if a parent or guardian becomes aware that a child has submitted personal information, that parent or guardian should tell us that they would like this information deleted from our records by contacting us via email at info@souslaface.com. We will delete the child’s information from our existing files. We reserve the right, in our discretion, to do any one or more of the following in order to verify a minor’s parental permission to use this Website:

• Request a signed form from the parent via mail or fax;
• Request a credit card number, which we will then verify;
• Take calls from parents on a toll-free telephone number staffed by trained personnel;
• Request an email from a parent accompanied by digital signature; or
• Request an email accompanied by a PIN or password.

We understand the utmost importance of protecting the security of the personal information that you share with us. Unfortunately, however, no data transmission over the Internet can be guaranteed to be 100% secure. Sous La uses certain commercially reasonable safeguards to protect our Website users against unauthorized use or disclosure of personal information. While we strive to protect this personal information, WE CANNOT REPRESENT, WARRANT OR GUARANTEE THE SECURITY OF ANY INFORMATION YOU TRANSMIT TO OR FROM OUR SITE, AND YOU TRANSMIT ANY INFORMATION AT YOUR OWN RISK.

If you use this Website, you are responsible for restricting access to your computer and ensuring that your computer is free from all types of malicious code, spyware, viruses, Trojans, etc. that may track any data you enter via this Website.

Sous La reserves the right to monitor all network traffic to this Website to identify and/or block unauthorized attempts or intrusions to upload or change information or cause damage to this Website in any fashion. Anyone using this Website expressly consents to such monitoring.

You should never give information in response to an email that purports to be from Sous La asking you for your personal information. We will never request your password, user name, credit card information or other personal information through email and we urge you not to respond to any such requests.

This site contains links to other sites operated and maintained by third parties. Privacy policies for such linked sites may be different from our privacy policy. Sous La is not responsible for the privacy practices or the content of such websites. You should always read the privacy policy for a linked site before disclosing any personal information on such site.

Your California Privacy Rights (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if you are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified on this page. You are responsible for periodically visiting our Website and this privacy policy to check for any changes.