PRIVACY POLICY

Effective Date: 22.01.2021

We, Asambeauty US Inc., (collectively, “Asambeauty”, “we”, “us”, or “our”) are committed to protecting and respecting your privacy.

This policy (together with our Terms of Service and any other documents referred to herein) sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.

This policy applies to information we collect:

• On Asambeauty’s website (asambeauty.com/us/)(the “Site”);

• In email, text, and other electronic messages between you and Asambeauty or our Site; and

• When you interact with our advertising and applications on third-party websites and services.

This policy does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by any third party (including our affiliates and subsidiaries); or

• Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on our Site. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you may choose not to use our Site. By accessing or using our Site, you agree to this Privacy Policy.

CHANGES TO THIS PRIVACY POLICY

Asambeauty reserves the right to change this Privacy Policy from time to time, at our sole discretion. Any changes we make to our Privacy Policy will be reflected on this page, with the date of the latest revision identified at the top of the page. If we make material changes to how we treat our users' personal information, we will notify you by email to the email address specified in your account. Your continued use of our Site after we make changes is deemed to be acceptance of those changes. You are responsible for ensuring that we have an up-to-date, active, and deliverable email address for you and for periodically visiting this page to check for any changes to our Privacy Policy.

WHAT OUR PRIVACY POLICY COVERS

This privacy policy discusses the “personal information” Asambeauty obtains from you via the Site. When we use the term “personal information” we are referring to information that is connected to your name. This may include things like:

• Information by which you may be personally identified, such as name, postal address, e-mail address, telephone number or ANY OTHER INFORMATION THE SITE COLLECTS THAT IS DEFINED AS PERSONAL OR PERSONALLY IDENTIFIABLE INFORMATION UNDER ANY APPLICABLE LAW ("Personal Information");

• Details of transactions you carry out through our Site and of the fulfilment of your orders;

• Information that is about you but individually does not identify you;

• Information about your internet connection, the equipment you use to access our Site and usage details; and

• Any other information you may choose to submit to the site via comment or email.

We collect this information:

• Directly from you when you provide it to us;

• Automatically as you navigate through the Site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies; advertising

• From third parties, for example, our business partners. This privacy policy does not cover information that you submit on other websites, even if we communicate with you on those sites. For example, if you post something on Facebook, Twitter or Youtube, that information is governed by the privacy policies on those websites, and is not governed by this policy.

Information You Provide to Us

The information we collect on or through our Site may include:

• Information that you provide by filling in forms on our Site, including information provided at the time of registering to use our Site, subscribing to our email service, participating in an event, contest, or promotion, or requesting further services;

• Information we request when you report a problem with our Site, or any of our product offerings;

• Records of correspondence between you and Asambeauty;

• Details of your visits to our Site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access; and

• Details regarding other people, including email information and names of recipients of gifts purchased through the Site. Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site;

• Information about your computer and internet connection, including your IP address, operating system, and browser type;

• Information about your mobile device and network, including the hardware model, operating system and version, unique device identifiers, and information about your use of our Site. To facilitate your use of certain Site features, we may request your permission to collect information about the location of your device and access information from certain native applications on your device. The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Site and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns;

• Store information about your preferences, allowing us to customize our Site according to your individual interests;

• Speed up your searches; and

• Recognize you when you return to our Site.

• The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer or mobile device. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site.

• Web Beacons. Pages of our Site (and our emails) may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that help deliver cookies and permit us, for example, to count users who have visited those pages (or opened an email) and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

HOW WE USE YOUR INFORMATION

We may use information that we collect about you or that you provide to us:

• To present or improve our Site and its contents to you;

• To provide you with information or products that you request from us or which we feel may interest you;

• To respond to your comment or questions, and provide you with customer service;

• To monitor Site trends and activities;

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;

• To notify you about changes to our Site or any products we offer or provide through it; and

• Towards any other purpose for which the information is collected.

Where We Store Your Data

The information we collect from you is governed by U.S. law. However, the data may be transferred to, and stored at, a destination outside of the United States of America (USA). It may also be processed by staff operating outside the USA who work for us or for one of our suppliers or affiliates. Such staff may be engaged in, among other things, the fulfillment of your order, the processing of your payment details and the provision of support services. By submitting your personal information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Who We Share Your Information With

We may periodically share some information about you in the following manner (and pursuant to this Privacy Policy):

• To our parent company;

• To contractors, service providers, and other third parties we use to support our business;

• Provide our customer list, and the personal and/or delivery information contained therein, to third parties who may, in our estimation, offer products of interest to you, provided that, you may opt-out of such sharing with third parties by exercising your rights under the Your Choices section below;

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request;

• If we believe that you are breaching the Asambeauty Terms of Service or other policies, or if disclosure is necessary or appropriate to protect the rights, property, or safety of Asambeauty, our customers, or others;

• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Asambeauty’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Asambeauty about our customers is among the assets transferred; or

• With your consent. We may disclose information about identifiable individuals to our advertisers, or provide them with aggregate information about our users (for example, we may inform them that 700 women under the age of 25 have clicked on their advertisement on any given day). We may also use such aggregate information to help our advertisers display their advertisement to their target audience.

YOUR CHOICES

Asambeauty strives to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Options:

• To update or correct personal information relating to your account: You can update or correct your name, e-mail address and other preferences by logging into your account or send an email through www.asambeauty.com/us/contacts.

THIRD PARTY USAGE & INTEREST-BASED ADS

Third Party Advertisement and Analytic Services

Customized Ad Campaigns. We may also work with third party social media sites, such as Facebook, to serve ads to you as part of a customized campaign.  The Site may integrate with social networking services.  We do not control such services and are not liable for the manner in which they operate.  While we may provide you with the ability to use such services in connection with our Site, we are doing so merely as an accommodation and, like you, are relying upon those third party services to operate properly and fairly.  Our pages on such social networking services are subject to the privacy practices of such providers.  If they provide us with information, we will use it as set forth in this policy.

Internet-Based Ads. We may allow others to serve advertisements on our behalf across the Internet and to provide analytics services. These entities may use cookies, device identifiers, web beacons and other technologies to collect information about your use of the services and other websites and mobile apps, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked and conversion information. You do have the ability to control certain advertising practices.  We comply with the Self-Regulatory Principles for Online Behavioral Advertising as administered by the Digital Advertising Alliance (DAA).  You can learn more about interest-based advertising and opt-out of targeted advertising from certain providers with whom we work by visiting theDAA’s consumer choice page.  The opt-out process through the DAA relies upon the placement of an opt-out cookie on your device.  We do not respond to or honor “do not track” (a/k/a DNT) signals or similar mechanisms automatically transmitted by web browsers for which we are cannot evaluate your choice.

For targeted advertisements delivered through mobile Apps, you can install theDAA’s AppChoices app on your device to opt-out of targeted advertising by certain providers and can also select a system level advertising preference feature on your device (such as “Limit Ad Tracking” on Apple devices or “Opt out o Ads Personalization” on Android devices).

Information may be used by Asambeauty and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our services and other websites and better understand your online activity.

Third Party Sites

Our Site may, from time to time, contain links to and from the Sites and/or Apps of our partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.

6.1 Use of Google Ads Conversion-Tracking

With your consent, we use the online advertising program "Google Ads" and, within the framework of Google Ads, the conversion tracking of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). We use the service of Google Adwords to draw attention to our attractive offers with the help of advertising media (so-called Google Adwords) on external websites. In relation to the data of the advertising campaigns, we can determine how successful the individual advertising measures are. We pursue the interest to show you advertising that is of interest to you, to make our website more interesting for you and to achieve a fair calculation of advertising costs.

The cookie for conversion tracking is set when a user clicks on an ad placed by Google. Cookies are small text files that are stored on your computer system. These cookies usually lose their validity after 30 days and are not used for personal identification. If the user visits certain pages of this website and the cookie has not yet expired, Google and we can recognize that the user clicked on the ad and was redirected to this page. Each Google Ads customer receives a different cookie. Cookies can therefore not be tracked across Ads customers' websites. The information obtained using the conversion cookie is used to generate conversion statistics for Ads customers who have opted in to conversion tracking. The clients learn the total number of users who clicked on an ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive information that personally identifies users.

We use the setting "Advanced Conversions". In addition to your e-mail address, we can also transmit your address as hashed (pseudonymized) data to Google in order to assign certain events on our site (so-called conversions, e.g. product purchase) to the interaction with a Google Ads ad and thus to measure the effect of the ads and advertising campaigns we have placed. The transmission as hashes ensures that your data is not transmitted as clear data. An assignment to Google Ads ads is therefore only made in a pseudonymous manner and no identifiable email addresses and addresses are transmitted to Google. These hashes are matched with any other hashed data available at Google (in particular from clicks on Google Ads ads) and assigned in this way, without the knowledge of the email address and address itself being required. You can find more information about "Enhanced Conversions" from Google Ads at: https://support.google.com/google-ads/answer/9888656?hl=en

If you do not want to participate in the tracking, you can block this use by deactivating the Google conversion tracking cookie via your internet browser under user settings. You will then not be included in the conversion tracking statistics.

You can find more information about Google's privacy policy at the following web address: http://www.google.de/policies/privacy/. You can permanently block cookies for ad preferences by setting your browser software to prevent them or by downloading and installing the browser plug-in available at the following link: https://support.google.com/ads/answer/7395996. Please note that certain features of this website may not work or may only work to a limited extent if you have disabled the use of cookies.

DATA SECURITY

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site and App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to or from our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

Compliance Hotline (whistleblower system): You can use our externally hosted compliance hotline to report indications of rule violations in the BHI Group. This allows us to follow up on indications of serious violations or misconduct that pose a high risk to the company and its employees in an appropriate and fair manner. The Compliance Hotline is available as a communication channel for both employees and external whistleblowers worldwide. The hotline can be reached at: https://compliance.stroeer.de

Status: 30.06.2022