Last Updated: December 14, 2023

Expanscience Laboratories, Inc. dba Mustela (“Mustela”) with principal offices at 60 East 56th Street, 6th Floor, New York, NY 10022 operates the websites located at the URL mustelausa.com. This Privacy Policy governs the foregoing websites and any other websites that display or link to this Privacy Policy (collectively the “website”).

This Privacy Policy informs you about our practices regarding the treatment of information we collect from you online (e.g., through our websites) and offline, the kinds of information we may collect, how that information is used, with whom we share it, and how you can opt-out of a use or correct or change such information. In this Privacy Policy, any reference to “us”, “we”, or ourselves is a reference to Mustela and the particular entity that you have a relationship with and any reference to “you”, “your”, and “yourself” is a reference to you as an individual who has a relationship with is or is in contact with us.

In general, we process personal information for our legitimate purposes of running our business; complying with applicable laws; and protecting our websites, our business, our customers, and any individuals who use our website, our services, or transact business with us. We also process personal information as necessary to enter into, or perform under, a contract with you; or with another party which is to your benefit. Finally, some processing of your personal information may be subject to your consent (e.g. if you enter a sweepstakes or promotional event). If we use consent as the basis for our processing, we will request it at the time we collect such personal information.

If you have any questions about our privacy policies, please contact us at customerservice@mustelausa.com. By providing your personal information to Mustela, you signify your acceptance of the Terms of Use and agree that Mustela may collect, use, and disclose your personal information as described herein.

1. Scope
This Privacy Policy applies to everyone who interacts with us as a customer who has purchased any of our products or services, a user of any apps we provide, anyone who signed up to receive marketing materials from us, anyone who enters any of promotions/competitions, anyone who interacts on social media with us and other online or offline offerings (together with any and all future online and offline offerings, the “Services”). As this Privacy Policy covers a range of individuals and different types of relationships and interactions with us, not all aspects of this Privacy Policy will apply to you.

2. Information We Collect
A. Personal Information. The types of personal information we collect (directly from you or from third party sources) and our privacy practices depend on the nature of the relationship you have with Mustela and the requirements of applicable law. Below is more information on the ways we collect personal information and how we use it.

B. Types of personal information. Mustela collects personal information from its current, prospective, and former customers, visitors, and guests (collectively “Individuals”) through the following channels:

a. Information Provided Directly to Us: When you use the Services, contact us directly, or engage in certain activities, such as registering for an account with Mustela, placing an order on our website, or signing up to receive emails about our latest products and services, we may collect and process a wide range of personal information such as the following types of information: personal contact details, such as your name, email address, address (billing and delivery), phone number(s), and payment information, such as a credit card number, billing address, and/or other related information required to complete the purchase (such payment information, “Financial Information”). Financial Information is kept encrypted.

b. Communications: We may collect personal information from you such as your email address, phone number or mailing address when you choose to request information about our Services.

c. Survey and Reviews: We (or third parties acting on our behalf) may contact you to participate in research, surveys or beta testing or to provide reviews and testimonials. If you decide to participate, you may be asked to provide certain information, which may include personal Information. All information collected from your participation in our research, surveys, reviews or testimonial process, or beta testing is provided by you voluntarily. We may use such information to improve our products and/or Services, and in any manner consistent with this Privacy Policy.

d. Sweepstakes and Contests: If we run a sweepstake or contest, we may ask you to provide contact information (e.g., a phone number or an email address) or other personal information. Your contact information may be used to reach you about the sweepstakes or contest, and, to the extent permitted by law, for other promotional, marketing and business purposes. In compliance with the laws of your jurisdiction, as a participant you may have the opportunity to opt-out of any communications that are not related to awarding prizes.

e. Automated Data: We may collect certain information automatically through our Services and/or other methods of technical analysis, such as your IP address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services.

3. How We Use Your Information
By providing personally identifiable information to us, we can perform a number of business functions, such as providing products, services, or information you requested.

Transactional Purposes. Mustela will process personal information to fulfill requests for products, Services or information, including to: a. Respond to questions, comments, and other requests; b. Provide access to certain features of the Services; c. Personalize product recommendations; d. Communicate with you about logistical matters, including product deliveries and shipping; e. Conduct internal research and development; and f. Review and respond to requests for customer support.

Administrative Purposes. Mustela will process personal information for administrative purposes, including to: a. Measure interest in our products and Services; b. Develop new products and Services; c. Ensure quality control; d. Send emails or text messages to the email address or telephone number you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, delivery updates, or system maintenance; e. Process payment(s) for products or services purchased; f. Process applications and transactions; g. Prevent potentially prohibited or illegal activities; h. Maintain and administer our Services; and, i. Enforce our Terms of Service.

Marketing. Mustela will process personal information to provide you with marketing materials that may be of interest.

Research and Development. Mustela will process personal information alone or in the aggregate with information obtained from other sources, in order to help us improve our existing products and Services or develop new products and Services.

Anonymous and Aggregated Information. Mustela does use personal information and other information about you to create anonymized and aggregated information, such as de-identified demographic or psychographic information, information about the computer or device from which you access the Services or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not personal information, and is thus not subject to this Privacy Policy.

Other. As noted earlier, Mustela will process personal information for which we have a legitimate interest, such as fraud protection or compliance with legal obligations, or any other purpose disclosed to you at the time you provide personal information or with your consent.

4. Cookies, Pixels, and Similar Technologies
We (along with third parties that provide content, advertising or other functionality on our Services), may use cookies, pixel tags, local storage and other technologies (“Technologies”) to automatically collect information through the Services. Technologies that are essentially small data files placed on your computer, tablet, mobile phone or other devices that allow us to record certain pieces of information whenever you visit or interact with our website, services, applications, messaging and tools, and to recognize you across devices.

Our uses of such Technologies fall into the following general categories:

a. Operational. We may use Technologies that are necessary to the operation of our Services. This includes Technologies that allow you access to our websites, Services, applications, and tools; that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of functions such as shopping carts, saved search or similar functions.

b. Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use our Services, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, services or tools.

c. Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into the Service or keeping track of your specified preferences, interests or past items viewed so that we may enhance the presentation of content.

d. Advertising-Related. We may use first-party or third party cookies and web beacons to deliver content, including ads relevant to your interests, on our Services or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement. We may also use third parties to serve targeted advertisements to people similar to our customer base (e.g., by uploading

a hashed customer list to Facebook Custom Audiences) or incorporating a pixel from the third-party on our Site. Even if you have disabled certain cookies, advertisements may still be displayed to you through these third-party channels.

5. How We Share Your Information
We share information collected through the Services with the following categories of parties:

a. Vendors and Service Providers. We may share any information we receive with select vendors and service providers to help fulfill orders.

b. Marketing. Mustela may allow third party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities on our Services (e.g., your IP address, page(s) visited, time of day).

c. Legal Disclosure / Law Enforcement. We may access, preserve and disclose your personal information, other account information and content if we believe doing so is required or appropriate.

d. Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of company assets or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such event, Mustela will endeavor to direct the transferee to use personal information in a manner that is consistent with the Privacy Policy in effect at the time such personal information was collected.

6. Managing Your personal information / Changing Marketing Preferences
We want to communicate with you only if you want to hear from us. You have the right to object to and opt-out of certain uses and disclosures of your personal information. We can be contacted at customerservice@mustelausa.com.

7. Security & Retention
The security of your personally identifiable information is important to us and Mustela is committed to handling such information carefully. We maintain physical, electronic and procedural safeguards to guard your personally identifiable information. We retain personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.

8. Children’s Privacy
Our Services are not directed to children under the age of 13. In addition, you are not permitted to use our Services if you do not meet the minimum age requirement applicable to our Services in your jurisdiction. We do not knowingly collect personal information from children under the age of 13. If you learn that your child has provided us with personal information without your consent, you may alert us at customerservice@mustelausa.com.

9. California Residents

A. WHAT PERSONAL INFORMATION WE COLLECT

Below identifies the categories of personal information we have collected over the preceding 12-month period, as well as examples in each category.
Category: Examples of personal information in this Category
Identifiers: Name, email address, billing address, shipping address, phone number
Commercial information: Purchase history
Geolocation data: Internet protocol (IP) address, billing address, shipping address, Internet or other electronic network activity information IP address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.
Financial, medical, or health information: Payment information, such as credit card number (all encrypted)

B. WHAT PERSONAL INFORMATION WE SHARE

California residents have the right to opt out of our disclosures of personal information that we have disclosed to third parties for valuable consideration. What is covered as a “sale” under California law is not yet clear, but we currently do not “sell” your information as we understand it.

C. YOUR RIGHTS

As a resident of California, you have certain rights, such as:

a. Right to access personal information. You may be entitled to receive the specific pieces of your personal information we have collected in the 12 months preceding your request.

b. Right to data portability. You may be entitled to receive a copy of your electronic personal information in a readily usable format.

c. Right to know. You may be entitled to receive information regarding the categories of personal information we collected, the sources from which we collected personal information, the purposes for which we collected and shared personal information, the categories of personal information that we sold and the categories of third parties to whom the personal information was sold, and the categories of personal information that we disclosed for a business purpose in the 12 months preceding your request.

d. Right to deletion. You may be entitled to request that we delete the personal information that we have collected from you. We will use commercially reasonable efforts to honor your request, in compliance with applicable laws. Please note, however, that we may need to keep such information, such as for our legitimate business purposes or as required to comply with applicable law.

e. Right to opt-out of certain sharing with third parties. You may be entitled to direct us to stop disclosing your personal information to third parties for monetary or other valuable consideration. As noted above, we do use trusted partners for interest based advertising.

You may freely exercise these rights without fear of being denied goods or services. If you are a California resident and would like to exercise one of your rights, please contact us using the details at the bottom of this Privacy Policy, including but not limited to customerservice@mustelausa.com.  Please note that California law requires us to verify the requests we receive from you when you exercise certain of the rights listed above. We (or third parties we engage to assist us) may ask you to provide certain information to us for us to verify the request.

10. Updating this Privacy Policy
We reserve the right to change, modify, add, or remove portions of this Privacy Policy at any time. You should check this page periodically for changes. Your continued use of this Site following the posting of changes to this Privacy Policy will be considered your consent to those changes.

11. Contact Us.
If you have any questions or suggestions regarding this Privacy Policy, please contact us as follows:

By mail:

Laboratoires Expanscience, Inc. dba Mustela
60 East 56th Street
6th Floor
New York, NY 10022

By email: customerservice@mustelausa.com